United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01-93/085
September 1993
PB94-963704
x°/EPA Superfund
Record of Decision:
Pease Air Force Base
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. 12. 3. Reclpllnt'l A_alon No.
PAGE EPA/ROD/R01-93/085
4. Tltll and Subtltll 5. Rlport Dati
SUPERFUND RECORD OF DECISION 09/27/93
Pease Air Force Base (Operable Unit 2), NH 6.
Second Remedial Action
7. Author(a) 8. Plrformlng Organization Rlpt. NO'
9. Plrformlng Organization Nama and Addr... 10 ProJlct TaakIWork Unit No.
11. Contract(C) or Grant(O) No.
(C)
(0)
12. Spon80rlng Organization Naml and Add,... 13. Type of Raport & Period Covlred
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Suppllmlntary Notl'
PB94-963704
16. Abstract (Limit: 200 word.)
The 3-acre Pease Air Force Base (Operable Unit 2) site is part of the 4,300-acre
inactive Air Force base located in Newington and Portsmouth, Rockingham County, New
Hampshire. Land use in the area is predominantly commercial and residential, with
wetlands and woodlands areas located on site. Current land use at the site is
institutional, agricultural, abandoned land, and unoccupied residential. Three
drainage ditches, the Upper Newfields Ditch, the Southern Ditch, and the Test Cell
Ditch, which receive runoff from the site, intersect the water table and are discharge
points for shallow ground water. The site has been divided into several zones. Zone 3
includes Buildings 244, 113, 229, 222 (Jet Engine Test Cell), 228, 119, 120, and 227.
The Jet Engine Test Cell (JETC), known as Site 34, consists of Building 222, the JP-4
Tank Area, the Fuel Oil Tank/Waste Fuel Separator Area, the manhole area, the holding
tanks area, and the aircraft parking apron. From 1970 until its closure in 1991, the
Air Force used the JETC to test jet engines through complete power ranges using a
process during which water was injected into the exhaust s.tack to reduce exhaust
temperature, hydrocarbon emissions, and noise. Runoff from the tests and washdown
activities was routed through an oil/water separator and then discharged directly into
(See Attached Page)
17. Documlnt Analyela a. Dncrlptora
Record of Decision - Pease Air Force Base (Operable Unit 2), NH
Second Remedial Action
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (PAHs), metals
(arsenic, chromium, lead)
b. IdantllllratOpan-Endld Tlrm.
c. COSATI FllldlGroup
18. Availability Statlmlnt 19. Security Class (thIs Rlport) 21. No. of Pag..
None 144
20. Security Class (thIs Page) 22. Price
None
(s.. ANSI.Z39.18)
SHlnstructlons on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI5-35)
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EPA/ROD/R01-93/085
Pease Air Force Base (Operable Unit 2), NH
Second Remedial Action
Abstract (Continued)
the Test Cell Ditch. A number of investigations conducted as part of the Department of
Defense's Installation Restoration Program (IRP) in 1983, identified records that
documented that releases of chemical waste from the JETC to surrounding soil had occurred
fr9m the oil/water separator. In 1989, modifications were made to eliminate wastewater
discharged to the storm drain by collecting the water in two 3,000-gallon underground
storage tanks (USTs). A pilot ground water remediation system, consisting of two bedrock
recovery wells and a ground water treatment plant (GWTP), was constructed at Site 34
during 1990 and 1991. Ground water from the recovery wells is treated to remove iron,
manganese, and dissolved organic contaminants, and then discharged onsite to the base
sanitary sewer system. In addition to these actions under the IRP, the JETC drain system
was reconfigured, and holding tanks were installed to eliminate discharges of effluent
from the exhaust stack area to the Test Cell Ditch; floor drains in the Test Cell Bay were
plugged to prevent contaminant discharges to the Test Cell Ditch; a heating oil tank
suspected of leaking was abandoned; a buried JP-4 tank was removed; and an aboveground
JP-4 tank equipped with appropriate spill containment was installed. This ROD addresses
sources of contamination, ground water treatment, and debris removal at the JETC, as OU2.
Future RODs will address ground water contamination in Zone 3 as well as sediment in site
drainage ditches and wetlands, if necessary. The primary contaminants of concern
affecting the soil, debris, and ground water are VOCs, including benzene, TCE, toluene,
and xylenes; other organics, including PARs; and metals, including arsenic, chromium, and
lead.
The selected remedial action for this site includes excavating approximately 11,900 yd3 of
soil from the JP-4 Tank Area, the Fuel Oil Tank/Waste Fuel Separator Area, the manhole
area, and the holding tank area; temporarily storing and dewatering 5,350 yd3 of
contaminated excavated soil onsite; treating the excavated soil offsite using
incineration, thermal desorption, or asphalt batching, or disposing of it at a RCRA or
Subtitle D landfill; disposing of excavated contaminated material at a location to be
determined during the RD phase; backfilling approximately 6,550 yd3 of soil not requiring
treatment that was excavated to access contaminated soil; replacing the excavated areas
with clean fill; treating ground water extracted as part of the excavation and/or
dewatering process using the existing pilot GWTP, which utilizes potassium permanganate
injection in conjunction with flow equalization, greensand filtration, and activated
carbon adsorption, with onsite discharge to surface water; removing remaining onsite USTs
and associated piping from the manhole and Test Cell Ditch; and conducting environmental
monitoring. The estimated present worth cost for this remedial action is $1,169,298,
which includes an estimated total O&M cost of $111,351.
PERFORMANCE STANDARDS OR GOALS:
Cleanup goals are based on State ARARs and SDWA MCLs. Chemical-specific soil cleanup
goals include 1 mg/kg for benzene, ethylbenzene, toluene, and total xylenes.
Chemical-specific ground water cleanup goals include arsenic 50 ug/l; benzene 5 ug/l;
15 ug/l; and TCE 5 ug/l in the excavation dewatering process, and benzene 0.005 mg/l;
toluene 1 mg/l; and total xylenes 10 mg/l for application of the leaching model.
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Record of Decision
ForA
Source Area Remedial Action
At
Site 34
".
Pease Air Force Base~ NH
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September 1993
Prepared for:
Headquarters Air Force Base Disposal Agency (HQ AFBDA)
The Pentago~ Washingto~ DC 20330
Air Force Center for Environmental Excellence
Base Closure Division (AFCEElESB)
Brooks Air Force Base, 'IX 78235-5328
. -.
Prepared by:
Roy F. Weston, Inc.
1 Weston Way
. West Chester, PA 19380-1499
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Contents
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RECORD OF DECISION
SITE 34
Table of Contents
SITE NAME, LOCATION, AND DESCRIPTION
.................
Pae:e No.
1
SITE HISTORY AND ENFORCEMENT AcrIVITIES . . . . . . . . . . . . . . 6
A.
B.
Site Use and Response History
Enforcement History
. . . . . .
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. . . . .
. . . . .
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COMMUNITY PARTICIPATION
......
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SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE
ACTION
..............
. . . . . . . . . . . . . . . . . . .' . . .
.........
SUMMARY OF SITE CHARACTERISTICS
A.
B.
. C.
D.
E.
...-.........
. . 6
.9
.. .' . -
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10
11
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13
Site Geology. . . .
Site Hydrogeology
Site Soarce Area. General Characteristics
, . Groundwater' . .' . .. - - - ~,
Surface Water/Sediment
. . . ... . . .: 13,
-.... .. . .. .. e", 16
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SUMMARY OF SITE RISKS
A.
B.
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Human Health Risk ~ent
Ecological Risk Assessment
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DEVELOPMENT AND SCREENING OF ALTERNATIVES
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33
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A.
B.
Statutory RequirementslResponse Objectives,.
Technology and Alternative Development and S~mg ". '.
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DESCRIPTION OF ALTERNATIVES
A.
Source Control Altemati~ .AnJyzed
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SUMMARY OF THE COMPARATIVE ANALYSIS
OF ALTERNATIVES --... ......
A..
B.
C.
D.
E.
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Overall Protection of Human Health and the Enviro~~- r:
Compliance with ARARs .. - . . . . . . . . - . . . . . .'~;;. ". . .
. .
Long.Tcrm Effectiveness. . . -- . . . . . . . .. ':;; ~ . . . .,_.."
Reduction in Toxicity, Mobility, or Volume Through Treatment
Short-Term Effectiveness' ~-~~ . .' . . ...- ,,' ~ .~ :~'-u ~ .
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Contents
x.
XL
Xll.
XIIL
S34ItOD.1XI'
F.
G.
H.
I.
RECORD OF DECISION
SITE 34
Table of Contents
(Continued)
Pa~e No.
Implementability ................................... 45
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Commwrity Acceptance ............................. .47
TIlE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
A.
B.
C.
D.
Methodology for Soil Cleanup Goal Determination. . . . . . . . . .. 51
Groundwater Treatment Goals . . . . . . . . . . . . . . . . . . . . . . . . .. 52
Target Surface Water Disc~e Concentrations. . . . . . . . . . . .. 53
Description of Remedial Components. . . . . . . . . . . . . . . . . . .. 54
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . .. 57
A.
B~
C.
D.
E.
The Selected Remedy is Protective of Human Health and the .
Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 57
The Selected Remedy Attains ARARs .................... 51
The Selected Remedial Action is Cost Effective. . . . . . . . . . . .. 60
The Selected Remedy Uses Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the Maximum Extent Practicable. . . . . . . . . . . . . . . . . . . . . . .. 62
The Selected Remedy Will Satisfy the Preference for Treatment
That Permanently and Significantly Reduces the Toxicity,
Mobility, or Volume of the Hazardous Substances as a
Principal Element. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' 64
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . .. 64
STATE ROLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 65
~CES/GLOSSARY ..............................66/68
APPENDICES
A.
B.
C.
D.
E.
Tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. A-I
ARARs for Pease AFB ............................. B-1
Declaration of Concurrence. . . . . . . . . . . . . . . . . . . . . . . . .. C-l
Responsiveness Summary. . . . . . . . . . . . . . . . . . . . . . . . . . .. D-l
Administrative Record Index. . . . . . . . . . . . . . . . . . . . . . . . .. E-I
iv
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Fhrore No.
1
2
3
4
5
6
7
8
9
S34RDD.1XT
SITE 34
RECORD OF DECISION SUMMARY
List of Figures
Title
Pae:e
General Locations of the IRP Zones and Sites. . . . . . . . . . . . . . . . . . . 2
General Vicinity Land Use Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Sources of Grotmdwater and Surface Wats:r Contamination. . . . . . . .. 18
Stratigraphic Cross Section D-D' Showing Extent of
Organic Contamination in JP-4 Tank Area .................... 20
Stratigraphic Cross Sectio~ E-E' Showing Extent of
Organic Contami11ation in JP-4 Tank Area .................... 21
Delineated Wetlands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28
Proposed Excavation for Removal of Soil Contaminated,
with Organics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
Remedial Process Flow Sheet for Alternative SA . . . . . . . . . . . . . . .. 49
Available Staging Area . . . . . . . . . . ~ . . . ., . . . . . . . . . . . . .'. . . .. 56
v
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Table No.
1
.2
3
4
S
6
7
8
9
10
11
S34RCD. 'IXT
SITE 34
RECORD OF DECISION SUMMARY
List of Tables
Tit~ -
Pa2:e
Snmmary:Jf Stage 2 and 3 Activities. . . . . . . . . . . . . . . . . . . . . .. A-I
Chemicals of Concern in Soil (0 to 2 feet) ................... A-3
Chemical~
. Concern in Soil (0 to 15 feet) .................. A-4
Snmmary C.:. ;: ota! Lifetime Cancer Risks and Hazard
Indices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
Snmmary of Detailed Alternatives Evaluation. . . . . . . . . . . . . . . .. A-7
Risk-Based Concentrations for L .mdwa.ter .................. A-8
Selection of Groundwater Cleanup Goals for Application
of Leaching Model - Organics in Groundwater. . . . . . . . . . . . . .. A-9
Selection of Cleanup Goals for Organics in Soil. . . . . . . . . . . . .. A -12
Cancer Risks a. Hazard Indice~ alculated Based
on ARARs - Soil. . . . . . . .. ......................... A-14
Groundwater Treatment Goals for Excavation Dewatering . . . . . . .. A-l~
ARARs for Alternative SA - Excavation and Off-8ite
Treatment and/or Disposal of Contaminated Soil, and
On-8it.e Groundwater Treatment and Off-Site Disposal
-!)r Excavation Dewatering. ... . . . . . . . . . . . . . . . . . . . . . . . . .. A -19
vi
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DECLARATION
SITE NAME AND LOCATION
Pease Air Force Base (pAFB), Site 34
New Hampshire
ST ATEJ.'\1ENT OF BASIS AND PURPOSE
This decision document presents a selected remedial action designed to reduce potential
leaching of soil cont;tminants to groundwater at Site 34, Pease AFB, NH. This decision
document was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act as amended by the Superfund Amendments and
Reauthorization Act of 1986, and, to the extent practicable, the National Contingency Plan.
Through.this document, the Air Force plans to remedy the threat to human health, welfare, or
the environment posed by CODt;tm;nm-ed soil associated with Site 34. This decision is based
on the Administrative Record for the site. The Administrative Record for this site is located
at the Information Repository in Building 43 at Pease International Tradeport (Formerly Pease
AFB, New Hampslrlre). The Administrative Record Index as applies to Site 34 may be found
in Appendix E.
The State of New Hampshire Department of Environmental Services (NHDES) and the U.S.
Environmental Protection Agency (USEPA) concur with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Site 34 soils, if not addressed by
implementing the response action selected in the Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELEL'"llill REMEDY
This action addresses the principal threat posed by Site 34 by preventing endangerment of
public health, welfare, or the environment by implementation of this ROD through remediation
SJ.4ROD.TXT
vii
09f17193
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or the s.. J; thereby minimi7ing the leaching potenri, of soil cont~min~ntS to groundwater.
The selected remedy includes the excavation of conT~minated soils and drainage piping
associated with Site 34. Also included is groundwater extraction and treatment for excavation
dewatering purposes. The treatment andlor disposal of soils removed from the site will include
one of the following; thermal desorption elsewhere on the base, asphalt batching of: . soils
at an off-base vendor location, or disposal at a Subtitle D Landfill or RCRA facility, as deemed
necessary at the time of remediation.
Groundwater will be extracted durin:
il removal ac:.. .des and extraction will continue until
backfilling with cL .,: fill is completeci. Contamin::tted groundwater will be extracted via a well
and sump extraction system and will be treated at the existing Pilot Groundwater Treatment
Plant (GWTP) at ;ite 34. The 'oundwater treatment techno~:gy to be used includes
greensand filtration followed by activated carbon adsorption. Additional storage capacity
would be required during remedial activities as the rate of extraction will likely be greater than
the existing 20-25 gpm capacity of the GWTP.
The preferred discharge method for the treated water is the base wastewater treatment facility
as the pilot GWTP already discharges to the base sewer system. However, coordination with
the City of PO~-:-o".outh as the current operator, would be required prior to any additional
discharges. Tre i water must meet ':':e prc=t:leatment standards established by the operator of
the base waste'~r tteatment facility. illtimate discharge will be to the Piscataqua River
under a National Pollutant Discharge Elimina.tion System (NPDES) permit.
STATUTORY DETERMINATIONS
The selected remedy is. protective of human health and the environment, complies with federal
and state requirements, that are legally applicable or relevant and appropriate to tr~ remedial
action, and is cost-effective. This remedy uses permanent solutions aI:'~ .':ternativ, ~.tment
technologies to the 11:. .:num extent practicable. The method of dispc . Jr treatn: Jf the
excavated soils will be ;.:.etermined during the remedial design phase. The determination will
"
,
SJ.4ilQD.1XT
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09(17193
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rctle.ct the requiC"eme:ll ofCERCLA 112C(b)(I) that sta.tes "ReIi1ediai actions in which trCatmClt
which. pemwlc:r.ly and significantly reduces the volume. toxicity or mobility hazardous
substances. poilutznts or contaminants is a principal elem~ are to be preferred over remedial
alternatives not jnvolving such treattnent". A review will be conducted by the Air Force, the
USE? A, and th: NHDES within fh'e years after remediation to ensure that the remedy
provided a~ua.to protection of hu..-nan health and the environment.
The foregoing represents the selection of a remedial action by the United States Air Force and
the U.S. Environmental P~tcc+.ion Agency, Region I, with concurrence of the New Hampshire
Department of Envi:-oIImental Services.
Concur nnd Recommended far immed.ia:.c implementation:
Date:
1/1-~/~Y
.I I
,
JAMI;$ F. eo..; TRIGHT
Deputy Assistant Secretary of the ~jr Forca
. (Installations)
BY:'?~~ ~i:
Paul G. eough
D=:
9-'L,7-f .:;
Title:
Acting R....-gional Administrs1or, USEPA
$3411.0D:n"T
ix
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RECORD OF DECISION SUMMARY
I. SITE NAl'\1E, LOCATION, AND DESCRIPTION
Pease AFB is a National Priorities List site consisting of numerous areas of contamination.
This ROD addresses sources of contamination at the Jet Engine Test Cell (JETC) (also
designated as Building 222 or Site 34). The JETC site occupies approximately 3 acres in the
central portion of the former base. The JETC was used by the Air Foree to test the
performance of jet engines through complete power ranges.
The former base is located in the Town of Newington and the City of Portsmou~ both of
which are in Rockingham County, New Hampshire. As shown in Figure 1, Pease AFB is
located on a peninsula in southeastern New Hampshire. The peninsula is bounded on the west
and southwest by Great Bay, on the northwest by Little Bay, and on the north and northeast
by the Piscataqua River. The City of Portsmouth is located southeast of the base. Pease AFB
occupies 4300 acres and is located. approximately in the center of the peninsula.
The current land uses at Pease AFB are institutional, woodland, agricultural, abandoned land,
and residential (CUITe!d.y unoccupied). Commercial and residential areas are located off base
along Spaulding Turnpike, approJrimately 1,000 feet northeast of the Pease AFB eastern
boundary, and Interstate 1-95, which is located along the southeastern base boundary. The.
largest commercial complex is a shopping mall 'located on the eastern side of Spaulding
Turnpike. Figure 2 is the general land use map for the Industrial ShopIParking Apron (ISIP A)
area of Pease AFB, and shows the location of the JETC within the I SIP A.
Prior to the construction of Pease AFB, the area at what is currently the JETC was primarily
woodlands. The wetlands CUITeI1tly located on-site were not present before construction of the
JETC facility, based on review of historic aerial photos. The development of the wetlands is
thought to be due to the grading and paving activities associated with the aircraft parking apron
and Dover Avenue.
S34ROD.1XT"
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LEGEND: GENP.AUZED LAND USE
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01-" .,....... --....-
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~~..!""1;7if,<.~t;- -P.ijI;C;"?f.~~~~;""'''. ,-
,.,~ :,'. T' . " . ~ ." .. 1'~', . .
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The primary soW'Ces of historic and current land use information for the JETC area include the
USGS topographic quadrangle maps (Portsmouth Quadrangle, photorevised, 1981), aerial
photographs (1958 to 1986), and a series of maps prepared for the New Hampshire Coastal
Zone Study (1975). .
Facilities adjacent to the JETC include an aircraft hangar (Building 227) to the north-northwest,
the former Munitions Maintenance Squadron (Building 113), the former Jet Engine
Maintenance Building (119) to the northeast, and the aircraft parking apron to the west.
Building '227 is currently leased from the Pease Development Authority (PDA) by Business
Express (a Delta Commuter Airline) for aircraft storage and maintenance. Buildings 113 and
119 were given the designation Site 32/36, and are also being investigated under the IRP.
. Building 113 is currently leased to the U.S. Navy, and Building 119 is currently used by the
PDA for maintenance activities. The aircraft parking apron is used for aircraft parking,
refueling, and minor aircraft maintenance.
Surface' drainageways at Pease AFB flow radially away from the center of the peninsula,
toward Great Bay to the west, Little Bay to the northwest and north, and the Piscataqua River
to the east. Great Bay, Little Bay,. and the Piscataqua River are all tidally influenced and,
consequently, are subjected to semidiumal variation in water levels.
The peninsula has relatively low relief, with the runway and aircraft parking apron located on
the topographically highest portion of the peninsula. The runway and aircraft parking apron
are on a surface drainage divide, with runoff to the northeast of the divide ultimately
discharging to the .Piscmqua River, and runoff southwest of the divide ultimately discharging
to Great Bay.
Locally, the surface hydrology of the JETC may be divided into four hydrologic zones: the
paved and storm-drained aircraft parking apron, the relatively well-drained areas immediately
adjacent to the aircraft parking apron, the poorly drained wetlands, and three drainage ditches,
S34ROD.1XT
4
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of which the Test Cell Ditch is one. The relationship of the 100-year floodplain to the JETC
site is not known since floodplain location maps are not available for Pease AFB.
Surface relief in the area is minimal. The change in elevation from a given low point to the
adjacent high is only 10 feet, and slopes are gentle. The highest elevations, approximately 60
feet above mean sea level (ft MSL), are on the aircraft parking apron. The aircraft parking
apron is constructed of portland cement concrete, and the joints between the concrete slabs
have been sealed. The aircraft parking apron is, therefore, relatively imperm~able. The surface
of the aircraft parking apron is graded such that most :"'Jnoff is directed .:Jrm drain catch
basins for eventual discharge to Mcintyre Brook. McIn:.-..,: Brook flows E::e southwestern
edge of the runway toward Great Bay. Snowfall on the aircraft parking .-...)n is cleared and
banked on adjacent areas, including the area around Building 222. These snowbanks contribute
meltwater to the site.
Building 222 is on a relative topographic high, and there is a localized drainage divide. Runoff
from Building 222 and areas southwest of the divide flows toward the Test Cell Ditch. Runoff
trom the Building 222 parking lot and areas northwest of the divide flows toward a northern
ditch (Upper Newfields Ditch), which runs parallel with, and approximately 400 feet northwest
ot: the Test Cell Ditch. A third drainage ditch, the Southern Ditch, which begins
approximately 300 feet southeast of the Test Cell Ditch, joins the Test Cell Ditch at Dover
Avenue. The Test Cell Ditch receives most of the surface runoff from the site (excluding the
storm-drained areas of the aircraft parking apron). The Test.Cell Ditch and the Southern Ditch
discharge to the storm drain system under Dover Avenue for eventual discharge to Grafton
Ditch. Flow in Upper Newfields Ditch flows under Dover Avenue near Building 119.
All three ditches intersect the water table and, hence, are discharge points for shallow
groundwater. This is indicated by dry period flows in the ditches. During prolonged dry
periods, the ditches may be dry for most of their lengths as the water table drops. Pumping
the GWTP recovery wells affects flow in the Test Cell Ditch because the water table is
lowered by pumping. In the past, the Test Cell Ditch received cooling and washdown waters
discharged from the JETC. The JETC is no longer in use; however, prior to its being taken
S34ROD.TXT
5
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out of service, discharges of these waters were rerouted to two holding tanks that are
periodically emptied for off-site disposal. Much of the runoff from other areas of the site
either pools or infiltrates in the wetlands, and does not reach the drainage ditches as overland
flow. There is little runoff from the wetlands; they are primarily an area of infiltration,
evapotranspiration, and groundwater recharge. The wetlands are discussed in greater detail in
Subsection 2.4.7 of the Draft Final Site 34 RI Report (F-499).
n. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site Use and Response History
The JETC was constructed in the late 1960s and has been in operation from 1970 until closure
of the facility in 1991. The JETC was used to test jet engines through complete power ranges.
During an engine test, water was injected into the exhaust stack to reduce exhaust temperature,
hydrocarbon emissions, and noise. A single test could use 3,000 gallons or more of water.
Additional water and wastes (i.e., fuel, hydraulic fluid, and cleaning solvents) were generated
during washdown activities in the test bay area. Liquids from the facility were routed through
an oil/water separator and then discharged to the Test Cell Ditch. In 1989, modifications were
made to eliminate wastewater discharged to the storm drain by collecting the water in two
3,000-gallon underground storage tanks (USTs). A UST for jet fuel (JP-4) was located on-site.
A more detailed description of site history is presented in Sections 1 and 3 of the Draft Final
Site 34 RI Report (F-499).
The JETC was f1rst identified as an area of possible environmental concern in 1983 during the
Installation Restoration Program (IRP), Phase I Problem IdentificationlRecords Search (F-7S).
The purpose of that study was to identify and evaluate suspected problems associated with past
practices at Pease AFB. Records show that releases from the JETC to surrounding soils
occurred from the oil/water separator. Product was visually observed in an excavated septic
tank trench near Building 222 during Phase 1. Following the Phase I study, Phase II Site
Investigations, Stages 1 through 3 were initiated under the IRP.
SJ.41tOD.1XT
6
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The Phase II, Stage 1 (September 1984 to January 1986) investigation consisted of completing
two borings to the southeast of Building 222. One soil sample was collected from each boring
for chemical analysis. The results of this investigation are reported in the Phase II, Stage I
ContirmationiQuantif1.cation Final Report (F-44).
The Phase II, Stage 2 (October 1987) Site Investigation effort focused on further characterizing
the extent of soil contamination and the effect of site activities on groundwater, surface water,
and sediment. Stage 2 activities included a soil-gas survey; six soil borings; installation of one
bedrock well; and soil, groundwater, surface water, and sediment sampling for laboratory
analyses. The results of the Stage 2 investigation are reported in the Stage 2 Draft Final
Report (F-4SS) and Interim Technical Report (ITR) No.2 (F-4S3).
Based on the data generated during Stage ~ additional field investigations and Interim
Remedial Measures (IRMs) were implemented as part of Stage 3. The 1990 Stage 3 field
investigations included installing two bedrock wells, test pit Investigations, and wetlands
delineations. IRMs consisted of soil and sediment removal along the Test Cell Ditch and the
design and installation of a pilot groundwater treatment plant (GWTP).
A pilot groundwater remediation system (GRS) was constructed as an IRM at Site 34 during
1990 to 1991. The goals of the GRS were to limit the migration of cODt~minants in
groundwater, to remove CODt~minant mass from the subsurface, and to evaluate potential
treatment technologies to be used in the final site remediation.
The GRS consists of a groundwater recovery system and a GWfP. The groundwater recovery
. .
system consists of two bedrock recovery wells located at the southeastern end of the source
area in the dissolved contaminant plume. The average combined yield from the recovery wells
is approximately 21 gallons per minute (gpm). Groundwater from the recovery wells is treated
to remove iron, manganese, and dissolved organic cont~minants. Treated groundwater is
discharged to the base sanitary sewer system.
f
S34ROD.1XT
7
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Unit processes used at the GWTP are flow equalization, greensand filtration, and activated
carbon adsorption. During the first 17 months of operation, from March 1991 through July
1992, the GRS recovered and treated approximately 9.5 million gallons of groundwater.
The effluent from the GWTP consistently meets drinking water standards, the requirements
agreed on by NHDES and the Air Force for discharge to the base sanitary sewer system. The
plant has not presented any major operational difficulties.
The GRS has had more than adequate success in meeting its objectives: the groundwater
recovery system has shown to be effective in capturing both overburden and bedrock water-
bearing unit cont~minants, and. the GWTP unit processes have been effective in removing
organic. and inorganic constituents. Based on past operations. only minor modifications are
recommended for continued operation of the Site 34 GRS during the interim period until final
remedial activities are implemented.
Table 1 in Appendix A summarizes the Stage 2 and 3 field investigation activities. Based on
the data collected from these IRP investigations, a Site Characterization Summary (SCS) (F-
482) was prepared for the JETC. The SCS included a working conceptual model and presented
data. required to complete a Baseline Risk Assessment (BRA) and Feasibility Study (FS).
The data required to complete a BRA and FS were collected during the 1991 Stage 3 field
investigation. The 1991 field investigations included installing 13 bedrock and 5 overburden
wells and 19 piezometers; completing soil borings; and sampling and analysis of groundwater,
soi.4 sediment, and surface water. A surface geophysical survey was also performed to provide
information on bedrock topography and potential fractures in the JETC area.
In addition to these activities, several other actions have been taken to reduce the potential for
environmental impacts resulting from JETC operations. These actions and their objectives
include:
S34It.OD.lXT
8
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.
Reconfiguration of the JETC drain system and installation of holding tanks to
eliminate discharges of effluent from the exhaust stack area to the Test Cell
Ditch. .
.
Plugging of floor drains in ~~ - ~st Cell Bay to prevent contaminant discharges
to the Test Cell Ditch. Fluic.. ~rated in the bay are collected with absorbent.
material and containerized fc. )per disposaL
.
In-place abandonment of a heating oil tank suspected of leaking.
.
F. 1val of the buried JP-4 tank and installation of an aboveground JP-4 tank
eq _?ped with appropriate spill containment.
B. Enforcement History
In 1976, the Department of Defense (DOD) devised a comprehensiv~ ~RP to as. ,55 and control
migration of environmental contamination that may have resulted from past operations and
disposal practices at DOD facilities. In response to the Resource Conservation and Recovery
Act of 1976 (RCRA) and in anticipation of CERCLA, DOD issued a Defense Environmental
Quality Program Policy Memorandum, dated June 1980 (I:.?M 8G-6), requiring
identification of past hazardous waste dispo&;J sites on DOD ~;;;::lcy installations.
The
program was revised by DEQPPM 81-5 (11 Df;-~:nber 1981), which reissued and amplified
all previous directives and memoranda on the IRP.
Pease AFB was proposed to be added to the National Priorities List (NPL) in 1989 and ~
listed on the NPL in 1990. On 24 April 1991, the Air ?o~ U.S. Environmental Protection
Agency (EP A), and New Hampshire Department of Environmental Services (NHDES) signed
a Federal Facilities Agreement (FF A) establishing the protocol and timetable for conducting
the Remedial InvestigationIFeasibility Study (RIfFS) process at Pease AFB. As part of this
timetable, the Air Force, in an effort to streamline activities, designed a basewide strategy plan
fOI" conducting an RIlFS. This strategy plan grouped the numerous sites into seven: :5 or
operable un:"':; based on ge: . "lphic location, potential r~~tors, and potential futtL~s.
RIlFS rep „ill be prep,,- ~:>r each zone. Howevc' .or to inch: 'n of Pease Ai _In
the NPL, sites (inc1udi.::..~ 'lle JETC) were on an 2.. rated RIlFS approach because of
the potential threat they posed to human health and the environment. The Air Force, EPA, and
SJ.4RDO.iXT
9
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NHDES agreed that the source area RIfFS reports, and the remedial actions at these five sites,
would continue on an accelerated schedule toward source area cleanup.
In. COMMUNITY. P ARTICIP ATION
Throughout the site's recent history, there has been community concern and involvement.
EPA, NHDES, and the Air Force have kept the community and other interested parties apprised
of site activities through informational meetings, fact sheets, press releases, and public
meetings.
In January 1991, the Air Force released a community relations plan that outlined a program
to address community concerns and keep citizens informed and involved during remedial
activities. This plan is currently being updated and is scheduled for completion by summer
1993.
. '
Numerous fact sheets have been released by the Air Force throughout the IRP at Pease AFB.
These fact sheets are intended to keep the public and other concerned parties apprised of
developments and milestones in the Pease AFB IRP. The fact sheets released to date that
concern the JETC are summarized as follows:
Fact Sheet Release Date
Pease AFB Installation Restoration Program Update October 1991
Pease AFB Installation Restoration Program Update December 1992
Underground Storage Tank Program Overview January 1993
Interim Groundwater Treatment - Sites 8, 32/36, and 34 January 1993
Proposed Plan for Site 34 Source Area March 1993
In addition to the fact sheets, a number of public meetings have been held concerning the
remediation of Site 34. On 14 November 1991, an IRP update public meeting was held., and
'S34IWD.TXT
10
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on 12 January 1993, an IRP f"-:lic workshop and meeting were conduc"'-:l to provide the
public with information on the Status of the IRP at Pease AFB. On 30 ..";h 1993, the Air
Force conducted a public hearing and information session for the JETC (Site 34) Proposed
P~ during which oral comments on the Proposed Plan were received. A transcript of oral .
comments re,;: "-'~d duri;- -is meeting and the Air Force's response to comments are included"
in the attachesponsh,i,-._~.;;s summary (see Appendix D). A full transcript is available in the
Admini<:;trative Record file at Pease AFB. In addition, a public comment period for the
Proposed Plan was conducted between 14 March and 14 April 1993. Responses to writte:
comments received during this period. are also included in Appendix D.
A complete In: _~rmation Repository containing documents relating to the Pease AFB IRP is
maintaU;1ed at Pease AFB in Building 43. An Administrative Record containing
correspondence pertaining to the Pease AFB IRP is also located in Building 43 at Pease AFB.
An index of the Adminiqmtive Record is maintained at EP A Region I Headquarters in Boston,
Massachusetts.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The JETC (Site 34) is one of several contaminant 5 :ces within Zone 3. Zone 3 is a grouping
of IRP sites and UST sites within the ISIP A area and is shown in Figure 1. The remedy
presented in this Record of Decision (ROD) .:~~~_~vides for source control at the JETC:
Remediation at a Superfund site typically involves activities to remove or isolate contar,;inant
source materials in conjunction with activities that mitigate migration of contamination through
groundwater and/or surface water pathways. This ROD addresses only source control measures
at the JETC. Management of contamination in groundwater for Zone 3 (operable unit 3) will
be addressed in separate zonewide documents, including a separate Zone 3 ROD.
S,: -'"Ce mat
at the JETC have been iden:
as source area soil and associ,-. USTs.
Although $C. . "".;;nts in site drainage ditches ar:~dands areas may represent an additional
source, they are not addressed in this document, but will be addressed as part of the Zone 3
remedial decision process. Groundwater and surface water are not considered source materials;
S34ROD.1XT
11
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however, treatment goals were generated for these media, as they may be affected by source
control activities.
The selected source control remedy was developed to reduce migration of cont~min~nts from
the source area soils to groundwater. In S1Jmmary, the remedy provides:
.
Excavation of cont~min~ted soil from the JP-4 Tank Area, the Fuel Oil
TanklWaste Fuel SeparatOr Area, the manhole area and holding tanks area, and
tranSport to an approved off-site treatment/disposal facility.
.
Dewatering of the site during soil excavation and treatment of the extracted
groundwater at the existing on-site treatment facility, with subsequent discharge
to the base sanitary sewer.
.
Backfilling of the excavation with excavated soil not requiring treannent or
clean fill.
.
Environmental monitoring during remedial operations.
.
Removal of USTs and drain piping from the manhole to the Test Cell Ditch.
The remedial action will address the objectives discussed in the following paragraphs.
The results of the BRA for Site 34 soils indicated that no significant adverse health effects on
human receptors are expected. This includes exposure resulting from incidental ingestion of~
or dermal contact with, contmnin::tted soil. The results of the ecological risk assessment
indicated that no significant adverse effects on ecological receptors resulting from site-related
cont~m;nation are expected. However, the potential may exist for conrnminants to leach from
source area soils into groundwater, resulting in human ingestion of, or direct contact with,
cont::tminated groundwater that may present a health risk.
In consideration of the aforementioned conditions, the remedial response objective for source
control actions at the JETC is to minimi7,c the leaching of conrnmin::tnts from the source area.
SJ.4ROD.TXT
12
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soil into groundwater, thereby reducing the potential for the public to ingest or directly contact
conramin:ltp.d groundwater that may present a health risk.
The remedy at the JETC is for contaminant source control only. The intention for this remedy
is to limit cont~minant leaching from soils to groundwater. Owing to the complexity of
groundwater flow in the vicinity of the JETC and the priority of other sites and groundwater
cont~min:lnt plumes, groundwater issues will be better evaluated on a zonewide or operable unit
basis, rather than a site-specific basis. This site was targeted for source control because it was
considered an area of high conrnmin:ltion and remedial activities for source control could be
started prior to completion of the full groundwater evaluation.
v. SUMMARY OF SITE CHARACI'ERlSTICS
Section 1 of the Draft Final Site 34 FS Report (F-504) contains an overview of the RI activities
conducted at the JETC, and Table 1 in Appendix A of this document presents a summary of
RI activities conducted at Site 34. The significant findings of the RI are presented in this
subsection.
A.. Site Geology
The bedrock in the vicinity of the JETC (Building 222) has been identified from samples
obtained from a total of 26 locations as split-spoon samples, well cuttings, and cores. The
identified rock types consist of quartzite, felsite, and diabase. The rock types have been
. tentatively classified as belonging to the Kittery Formation, the Exeter diorite, and the diabase
dikes of the White Mountain Series.
The bedrock surface beneath the JETC is irregular, probably as a result of preglacial
preferential erosion. Overall, the bedrock ranges from highs of 0 ft BGS (outcrop
approximately 15 feet northeast of Building 222) to lows of greater than 45 ft BGS. A
bedrock high located under Building 222 is bordered on the east and west by steep-sided, broad
valleys. Another bedrock high exists east-northeast of Building 222.
S34ROD.TXT
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The upper few inches to approximately I foot of thickness of bedrock at the JETC was found
to be weathered and highly fractured, based on cores collected from eight boreholes. The
weathered and/or fractured bedrock is probably transmissive and grades downward into a more
competent bedrock. A well-sorted gravel that overlies the bedrock ranges from a few inches
to more than I foot in thickness. The gravel unit usually consists of angular bedrock fragments
and was field-identified with the overlying till unit. This suggests that the weathered/fractured
zone is widely distributed around the bedrock high located under Building 222.
At the JETC, the locations of fractures were determined by use of the very low-frequency
electromagnetic method. Bedrock lineaments at the JETC consist of a set of eight lineaments
that trend approximately N42°E to N54°E. A second set of four lineaments occurs that trends
NiioW to NI8°W. Two other lineaments that occur at the JETC have orientations that trend
N800E and N24°W. The lineaments that trend approximately northeast-southwest probably are
related to the regional strike of the bedrock, while lineaments oriented to the northwest-
southeast are probably related to cross fractures or faults in the .bedrock.
The lineaments of greatest potential concern for cont~minant and water migration near Building
222 are the five lineaments that surround the Building 222 bedrock high. The set of lineaments
that trends approximately N45° E may represent fractures, faults, or preglacial drainageways.
These lineaments may be paths of least resistance for water migration under and away from
Building 222.
In addition to the descriptions of the natural fractures, the rock quality determination (RQD)
of the core was determined. The RQD of a core is equal to the sum of the length of the core
pieces separated by natural fractures that are greater than 4 inches long, divided by the length
of cored interval (expressed as a percentage). At the JETC, the RQD values indicate that
portions of the bedrock are highly fractured, which is indicative of higher potential for
groundwater movement through the rock type.
The unconsolidated overburden, except for the weathered bedrock and manmade fill, at Pease
AFB appears to correlate with the Wisconsinan age glacial episode. Based on prese~t and
S34ROD.TICr
14
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historic ~-;lling lformatior: at Pease AFB, the stratigraphic units are ;;;,ivided . :to four units
as follows (in descending order from youngest to oldest):
.
Upper Sand (rS).
Marine Clay -::. Silt (MCS).
Lower Sand (L.3).
Glacial Till (GT).
.
.
.
Each of these units is prese~- at the JETC. The nature and distribution of these overburden
units have contributed to the distribution and migration of contaminants into the surrounding
,: "-
The uppermost surficial materials observed at the JETC are Recent swamp (Le., bog or marsh)
deposits. These deposits are especially common over the MCS unit, and accumulate in the
poorly drained areas only. The thickness of the swamp or peat deposits varies between I foot
and 2 feet. Locally, these low-lying surficial units have been modified by the Air Force using
~ining or cut-and-fill practices.
Also present at the surface ~he JETC are fill materials. The fill material varies from an
unconsolidated, tan, fine- to :dium-grained sand near: '; underground storage tanks (USTs)
to a highly compacted, reddish brown fill under the flight apron. Unconsolidated sand fill near
the USTs and the leaching f ~ipes ranged in thickness from 6 to 8 ft BGS; in places it was
present from the ground 5Ur- ... to bedrock.
The youngest glacial overburden unit at the JETC is the US. In places, the US is difficult to
distinguish from the fill, or where the ~CS unit is absent from the LS. The US consists of
poorly sorted sand with some silt and gravel at the JETC. At many locations in the vicinity
of the JETC, the US has been !'~~'-aced by fill. especially near the USTs and the flight apron.
material to well-laminated.
JS is the M The MCS ranges in thickness from 0 to 22
:'. dark gray, pl~Lic clay with minor very thin interbeds of silty
:bedded, fine s<.' =:ts, and clays. The dark gray, plastic clay
Stratigraphically underlying -
feet and varies in texture fr:
SJ.4ROD.1XT
15
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and elastic silt is defined as a mappable unit at the JETC as one progresses away from the
bedrock high toward bedrock lows. The MCS unit grades into an interbedded fine sand and
silt unit near the bedrock high. At the site, contacts betWeen the MCS, US, and LS are
gradational.
The LS at the JETC consists of a poorly sorted, silty sand, with some medium gravel and sand.
The LS was absent only in the vicinity of the bedrock high, near Building 222, where, in the
absence of the MCS, granular deposits were considered part of the US unit.
The GT was found on-site as a more loosely compacted till located near bedrock lows. At
some locations, an interval of well-sorted gravel underlies the GT and was sometimes field-
identified as weathered bedrock.
B. Site Hydrogeology
The three hydrogeologic units that have been identified and evaluated for the JETC area are
as follows:
.
Overburden - The saturated overburden deposits, including artificial fill, but
not the basal glacial till.
.
Shallow Bedrock and Glacial Till - The highly weathered and/or fractured
interval of crystalline rock that extends from the base of the lower glacial sand
to the top of the competent bedrock. Its thickness is typically 10 to 20 feet.
.
Deep Bedrock - Generally competent bedrock beneath the shallow bedrock.
Groundwater flow is primarily in unweathered fractures.
Hydraulic tests and water level data indicate that the hydrogeologic units in the JETC area are
hydraulically connected, even though each unit has distinct hydrologic properties. 'fl?e degree
of interconnection at any locality depends on the specific lithology of the overburden, the
degree of fracturing and weathering, and the location and amount of groundwater pumping.
In the JETC area, under natural conditions, groundwater discharge from all hydrogeologic units
is to surface streamS.
S34ROD.'IXT
16
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.--
c. Site Source Area General Characteristics
Soil cont::Jmination is present in four distinct areas at the JETC: the JP-4 Tank Area, the Fuel
Oil Tank/Waste Fuel.Separator Area, the manhole area, and the holding (septic) tanks area (see
Figure 3). This subsection SlImmarizes the contaminants found in these source areas (i.e., area
of soil cont::Jmination). Additional information regarding the nature and extent of soil
contaminants is presented in Subsection 1.5.1 of the Draft Final Site 34 FS Report (F-504).
Organic cont::Jminants present in soil at the site consist of three groups of compounds: aromatic
VOCs, chlorinated VOCs, and P AHs (SVOCs). One or more of these groups have been
detected in surface (0 to 2 ft BGS) soil samples and subsurface (greater than 2 ft BGS) soil
samples to a maximum depth of 13 ft BGS.
Metals concentrations in subsurface soil present above established background levels coincide
with areas of organic contamination and are interpreted as additives in JP-4 fuel and fuel
(heating) oil used at the JETC. Principally arsenic, chromium, nickel, and sodium are present
in areas of hydrocarbon contamination at concentrations above established background levels.
Barium and lead concentrations present in surface soil above background levels are not
associated with the JETC source area or JETC activities.
The highest levels of organic contamination detected in subsurface soils were in the JP-4 Tank
Area. The JP-4 Tank Area is located east of the JETC. Contaminants found in soil in the-
JP-4 Tank Area consist primarily of aromatic VOCs and P AHs. JP-4 was also identified by
Fill fingerprint analyses. No incidences of sp~s or other releases from the JP-4 tank have
been reported since its installation in 1970. However, based on the distribution and levels of
organic compounds present in soil samples collected adjacent to the tank, the JP-4 tank is the
most likely source of the soil contamination in this area. In October 1991, the JP-4 tank was
emptied to avert any future potential releases. In addition, contaminants detected along the
southeastern edge of the JP-4 Tank Area may be attributable to contaminants that were
processed through the leaching field.
S34ROD.1XT
17
fJ9Ia7H]
"~
0"
-------
8 Legend
~ 1'11111110<1 rIoor Orolos
~ Floor Drain
-50- Slo.m O.aln
o Mil Manholn
~ Troollno
A
n
c
o
E
F
8 II
II
8
-------
Figures 4 and 5 are stratigraphic cross sections that show a schematic represen~tion of the
distribution of soil CODmmination for the JP-4 Tank Area, and the relationship between the soil
contamination and the groundwater flow system. These figures illustrate that the migration of
contaminants in soil is controlled primarily by the slope of the bedrock surface. P AHs are the
only organic compounds detected in the Fuel Oil TanklWaste Fuel Separator Area, which is
located adjacent to the southern comer of the JETC. Relatively low (<2 mg/kg) levels of
P AHs were found in fill material at sample depths of 4 and 6 ft BGS, and in the MCS unit at
a sample depth interval of 4 ft BGS. Since P AHs are common constituents of heating oils, the
most likely source of the low levels of P AHs in soil is the abandoned steel heating oil tank.
Another possible source of the P AH contamination is the waste fuel separator. JP-4-
contaminated effluent from the JETC may have been released to the soil through breaches in
the separator.
Effluent received by the waste fuel separator was normally a mixture of hydraulic fluids,
degreasing solv~ JP-4, and emulsifiers. The emulsifiers were used to enhance the solubility
of the petroleum-based products that accumulate on the floor of the JETC. Both the .heating
oil tank and the waste fuel separator were installed in the late 1960s, during
JETC construction. Since the heating oil tank was abandoned in 1987 and the waste fuel
separator has not been in use since mid-1990, they are no longer a source of soil contamination
at the JETC.
Soil contamination in the manhole area was detected only in the MCS unit and consisted of
P AHs and aromatic and chlorinated VQCs. The primary contributor to total P AH levels in the
manhole area is naphthalene. Aromatic VOCs present in the manhole area consist primarily
of BTEX compounds. The primary contributors to the total chlorinated VOCs are 1,1,1-
trichloroethane and chlorobenzene. The probable sources of these contaminants are spent
solvents used in post-test engine cleaning at the JETC. Washdown liquid containing solvents
collected in the test cell floor drains may have been released through breaches in the drainage
pipe leading to the stormwater manhole or tbe waste fuel separator. In addition, con~minants
that have accumulated in the manhole area =:::.ay be migrating to the east, toward the Test Cell
Ditc~ along the bacldilled trench that was completed for drain pipe installation.
S34R0D.1XT
19
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~ ' STRATIGRAPHIC CROSS SECTION EoI:'
~ SHOWING EXTENT OF ORGANIC CONTAlllNATION
.. THE JP'" TANK AREA
-.
-------
Soil contamination in the holding tanks area consiSted primarily of P AHs and was present only
in satUrated soil samples (Le., at the top of the shallow water table). In additio~ Fill analysis
reported target VOCs also present in this area. No identification or quantification of VOCs
was reported. Contamination in this area was evident prior to December 1989. Petroleum
contamination in saturated soil and groundwater was obvious during holding tank installation.
A potential source of soil cont:tmination in this area is contaminated effluent from the manhole
area.
Contaminant Mobilitv
The fate and transport of cont:tm;nants within a soil matrix are dependent on the chemical
properties of the contaminants, soil types, stratigraphy, and climatic conditions. Contaminant
fate and migration are further controlled by transport and attenuation processes. Important
transport processes include surface water and groundwater movement, leaching, and erosion.
Attenuation processes include retardation resulting from sorptio~ volatilizatio~ photo-
oxidatio~ photolysis, and chemical and biological degradation.
The major contaminants found at the JETC are components of JP-4 and fuel oil. Significant
components of JP-4 include benzene, toluene, ethylbenzene, xylenes, and other complex
aromatic hydrocarbons, such as isopropylbenzene. Naphthalene and phenol compounds are
also present. Fuel oil contains many of the same compounds as JP-4 and is predominantly a
mixture of straight-chain hydrocarbons, aromatic hydrocarbons (including trimethyl-benzenes),
and some P AHs. Fuel oil also may include some additives, which may contain phenols,
naphthalenes, and heavy metals, such as nickel, chromium, vanadium, zinc, and arsenic (F-
299).
The fate of JP-4 in the soil environment is a function of the solubility, volatility, sorptio~ and
degradation of its major components. Because of their high volatility, moderate solubility, and
moderate adsorption to soils, the major components of JP-4 and fuel oil are relatively mobile
and nonpersistent in soil systems. For JP-4 released to surface soils, volatilization to the
atmosphere is the primary fate for most of the JP-4 hydrocarbons (F-299). In cases in which
S34ROD.TX'f
22
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the source of contamination is leaks '''''".)m US"::
-he volatile components do n'
:lave an
opportunity to evaporate before pene~ .~g the s. , and can possibly ~nter the water table.
Biodegradation of the petroleum hydrocarbons comprising JP-4 fuel is expected to be rapid
under conditions favorable to microbial activity, especially in an initially aerobic environment
(F-299). Because of lower levels of oxygen and organic carbo~ contaminant persistence in
deep soils and groundwater may be greater than in shallow soils. Benzene is the most mobile
and soluble of the aromatic hydrocarbons, and that portion that does not volatilize, sorb, or
degrade will . .-:~ into the groundwater. The other aromatic hye ;carbons ar.; ::ss mobile
and may be ! the sou..' i groundwater.
The P AH compounds, except for the naphthalenes, are strongly sorbed to soils and are slightly
mobile to immobile and, therefore, tend to persist in the soil until they are degraded. Thus,
these compounds are not likely to be found in the groundwater.
D. Groundwater
Soil at Site 34 is ~ concern because of the potential for leaching of organic contaminants to
groundwater ane. :face water /}roundwater characteristics are presented as a background for
source control ~;:vities. A r;;;.nedy for g::-:.:mdwater 'Will be discussed in the Zone 3 RI and
FS Reports.
..
Site Groundwater General Characterisri~
Physiochemical Considerations
Many of the conrnminants detected in soil and sediment were also detected in groundwater.
These contaminants (mostly aromatic hydrocarbons and naphthalene) have relatively low to
moderate mobility and are stable. Contaminants detected in groundwater and not detected or
detected at low concentrations in soil or sediment are normally compounds that are highly
mobile, such as TCE and DCE, and may have been leached from the soil or ::!igrated from
outside the JETC area.
S34ROD.TXT
23
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JP-4 tends to infiltrate into porous, sandy. soils, and since it is lighter than water it tends to
accumulate at the soil-groundwater interface. There, the more soluble components dissolve into
the groundwater and migrate with the groundwater at a rate determined by their retardation
factors until they degrade or are discharged to the surface. In cases in which sufficient amounts
of JP-4 have been spilled, a separate light, nonaqueous-phase liquid (LNAPL) may form on
the surface of the water table. To date, free-phase product has been observed at only one
groundwater monitoring point (piezometer 753) during two rounds of water level measurements
(January and April 1989).
Relatively low levels of chlorinated VOCs, such as TCE and DCE, have been detected in
groundwater samples. ~ese compounds have specific gravities greater than water and may
exist as dense, nonaqueous-phase liquids (DNAPLs). However, the fact that the concentrations
of these compounds in the groundwater are well below their aqueous solubilities, and the
probability that the principal sources of chlorinated VOCs originate outside of the JETC area,
suggests that separate dense phases are not likely to exist in groundwater at the JETC.
Conceptual Site Model of Migration Pathways
Based on hydraulic tests and water level data., the deep bedroc~ shallow bedrock, and
overburden water-bearing units in the JETC area are hydraulically connected. Although each
water-bearing unit bas distinct hydrologic properties, there is communication among units. The
interaction of the three water-bearing units is due to three site conditions: fracturing and
subsequent weathering of the bedrock, overburden deposition, and excavation activities.
Field data that support the premise that the three water-bearing units are in communication
include: (1) the partial dewatering of the overburden and the shallow bedrock water-bearing
units observed when groundwater is pumped from the two bedrock groundwater recovery wells
. (634 and 635); (2) the lack of clay and silt and the presence of porous. fill in direct contact
with bedrock observed in soil borings and test pits; and (3) the similarities in the organic
chemical composition between groundwater sampled from the deep bedrock water-bearing unit
and soil sampled from characterization borings.
S34ROD.TXT
24
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The migration of contaminants from the unsaturated overburden soils to the shallow
groundwater flow zone is enhanced by recharge of stormwater. Water level data do not
indicate that groundwater in the JETC area has a specific recharge point or area. In additio~
groundwater recharge should be significant in backfilled areas associated with JETC
construction and subsequent site modifications (Le., holding tanks and leaching field
lnstallations). Geotechnical analysis of two fill samples collected at the JETC reported
porosities of 29% and 40%. Consequently, these fill areas would rapidly absorb stormwater
and provide a vertical conduit for groundwater recharge. Furthermore, Building 222 is situated
over a bedrock high (bedrock outcrops just east of. the building), and much of the adjacent fill
areas are relatively thin and unsaturated. Groundwater recharge in these areas is directly into
the shallow bedrock water-bearing unit.
With the exception of arsenic, the distribution of metals in groundwater in the JETC area is
not apparently the result of the lear.h1ng of metals in source area soils. This premise will be
further evaluated and discussed in the Zone 3 FS Report.
Groundwater discharge to surface water bodies within and adjacent to the site is considered an
important contaminant migration pathway in the JETC area. The hydraulic gradient in the
overburden water-bearing unit indicates that groundwater, in general, flows eastward from the
source area and is captured by the Test Cell Ditch and other topographically low areas within
the wetlands.
The Test Cell, Upper Newfields, and Southern Ditches may receive contaminants through
discharges from the overburden groundwater flow zone, from stormwater runoff, or from storm
drain discharges (Test Cell Ditch only).
Based on the location of the JETC source areas, the overburden groundwater gradient, and
stormwater drainage, the Test Cell Ditch is the only plausible surface water pathway for the
migration of cont~minants origjn~ting from the JETC source areas. Since the completion of
the sediment/soil removal IRM and the reconfiguration of the JETC drainage system,
SJ.4ROD.1XT
25
-------
cont::!minated effluent is no longer a contributor to surface water or sediment cont;\mination in
the Test Cell Ditch.
Cont::!minant levels in the overburden groundwater flow zone are relatively low; groundwater
sampled from well 5016 had a detected total VOC concentration of 3.4 ILg/L. Therefore,
groundwater discharging into the Test Cell Ditch also would have relatively low VOC
concentrations, and may be further diluted from stonnwater runoff captured by the 'ditch. This
is substantiated by trace levels (3.2 ILg/L) of total VOCs found in the surface water at staff
gage 806.
Groundwater cont:fmination will be more fully evaluated in the Zone 3 RI and FS Reports and
will be discussed in the rest of this document only with regard to actual source control issues.
E. Surface Water/Sediment
Surface water and sediment were not evaluated in the Draft Final Site 34 FS Report. The
sediment and surface water are cmrently under evaluation in the Zone 3 FS Report, which will
include the groundwater~ sediment, and surface water at the JETC. The delineated wetlands
for Site 34 and Zone 3 are presented in Figure 6.
A complete discussion of the nature and extent of cont:fmination and contaminant fate and
transport is presented in Sections 4 and 5 of the Draft Final Site 34 RI Report.
VL SUMl\1ARY OF SITE RISKS
A. Human Health Risk Assessment
A BRA was performed to estimate the probability and magnitude of potential adverse human
health and environmental effects from exposure to cont:fminants associated with the site. The
public health risk assessment followed a four-step process: (1) conrnm;nant identification,
which identified those hazardous substances that, given the specific site conditio~ were of
significant concern; (2) exposure assessment, which identified actual or potential exposure
pathways, characterized the potentially exposed populations, and determined the extent of
S34IlOD.1'XT
26
-------
possible exposure; (3) toxicity assessment, oxhich considered the types and magnitudes of
adverse hez... effects assc.. :.~~d ",,-;r.h er ~ to hazardous substances; and (4) risk
characterizatio~ which integrated the three ear.l:;;r steps to ~'::-:.2e potential and actu2l
risks posed by hazardous substances at the site, including carcinoge::::; and noncarcinogemc
risks. The results of the hu::::m health and ecological risk assessments for the JETC 2.:~
discussed in this subsection and the following subsection, respectively.
The BRA for this site is limited to the source areas evaluated in tl::
; 34 RI and FS Reports.
Nineteen cc
:JJinants of ,::Jncem were sei-~!ed for 0 to 2 ft E
and ~ . contam:.:':?D.ts of
concern were selected for 0 to 15 ft BGS soiis. The cont~minants of concern CODS""":C".lte z.
representative subset of the more than 21 and 37 contaminants identified at the site for
o to 2 and 0 to 15 ft BGS soils, respectively, during the RI. The cont~minants of concern were
selected to represent potential site-related hazards based on toxicity, concentratio~ .frequency
of detection, and mobility and persistence in the environment. The cont~minants of concern
are listed in Tables 2 and 3 in Appendix A. A summary of ':.:ealth effects of each of th~
cont~m;nants of concern is presented in Section 6 of the Dra:..
-Jal Site 34 RI Report.
P~tential human health effects associate.: with exposure to the contaminants of concern were
~ :Jated quantitatively or qualitatively through the development of several hypothetical
exposure pathways. These pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future '.!Se5, and location of the site.
The site is intermittently used for industrial purposes, and future land use is assumed to be
industrial. This,:. ;umption is based on-~ current plans of the Pease Development Authority
(PDA) to attract industrial tenants to the base as a means of boosting the local economy,
. .
because the local economy was adversely impacted by the base closure.
Of the three potential receptors (building workers, maintenance workers, and trespassers) for
the soil pathway, the maintenance worker was selected as the most reasonable maximally
:. - :posed individual (RME) under. 'lITent a:-::ure potential land use. The risk from exposure
to surface (0- to 2-foot-deep) soils was. .rated for the current and future maintenance
worker, and the risk from exposure to surface and subSurface (0- to I5-foot-deep) soils was
SJ4ROD.TXT
27
-------
.
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-
-------
evaluated for the future maintenance worker. The exposure routes that were evaluated for the
soil pathway were incidental soil ingestion and dermal contact with soil.
The following is a brief sl1mmary of the exposure pathways evaluated. A more thorough
description is presented in Section 6 of the Draft Final Site 34 Rl Report. For each pathway
evaluated, an average and a reasonable maximum exposure estimate were generated
corresponding to exposure to the average and the maximum concentration detected in that
particular medium.
Currently, the JETC is not being used; however, it is expected that it will resume an industrial
use soo~ and that the future use of this area will be industrial. The current use receptor
chosen as the RME for the soil pathway was the maintenance worker. The current
maintenance worker exposure was assumed to be 2 hours/day, I day/wee~ 50 weeks/year, for
25 years. The maintenance worker was also chosen as the future RME for the soil pathway;.
however, the exposure frequency is greater because the site will be more active in the future.
The future maintenance worker is projected to be potentially exposed for 2 hours/day, 250
days/year, for 25 years.
Excess lifetime cancer risks were determined for each exposure pathway by multiplying the
lifetime averaged dose by the chemical-specific cancer slope factor. Cancer slope factors have
been developed by EP A from epidemiological or animal studies to reflect a conservative upper
bound of risk posed by potentially carcinogenic compounds (Le., the actual risk is unknown.
but is likely to be lower than the calculated risk). The resulting risk estimates are expressed
in scientific notation as a probability (e.g., I x 10..0 for 1/1,000,000) and indicate (using this
example) that an average individUal is not likely to have greater that a l-in-l-million chance
of developing cancer over 70 years as a result of site-related exposure, as defined, to the
compound at the stated concentration. Current EP A practice considers carcinogenic risks to
be additive when assessing exposure to a mixture of hazardous substances.
The hazard quotient was also calculated for each pathway as a measure of the potential for
noncancer health effects. A hazard quotient is calculated by dividing the exposure duration-
SJ.4ItCD.iXT
29
09IfT7193
-------
averaged dose by the reference dose (RID) or other suitable benchmark for noncancer health
effects for an individual compound. Reference doses have been developed by EP A to protect
sensitive individuals over the course of a lifetime and to reflect a daily exposure level that is
not likely to present an appreciable risk of an adverse health effect. RIDs are derived from
epidemiological or animal studies and incorporate uncertainty factors to help ensure that
adverse health effects will not occur. The hazard quotient is often expressed as a single value
indicating the ratio of the stated exposure, as defined, to the reference dose value. The hazard
quotient is only considered additive for compounds that have the same or similar toxic
endpoint, and the sum is referred to as the hazard index. (For example: the hazard quotient
for a compound known to produce liver damage should not be added to a second whose toxic
endpoint is kidney damage).
Table 4 in Appendix A depicts both the cancer and/or noncancer risk summary for the
contaminants of concern in soil evaluated for the JETC to reflect present and potential future
exposure pathways corresponding to the average and the reasonable maximum exposure
scenarios.
From the summary table, it may be noted that the cumulative cancer risk falls within the EP A-
acceptable risk range of 10-4 to 10~. A majority of the contaminants of concern do not result
in an individual risk greater than I O~. Of the several contaminants whose risks do exceed 1 O~,
most do not exceed a risk of approximately 1 O-s. A more complete discussion of the risks
associated with Site 34 is presented in Section 6 of the Draft Final Site 34 RI Report. The
hazard indices for soil were all below the EP A criterion of 1.
Because the human health risk due to receptor contact with contamin~terl soils does not exceed
the EP A acceptable risk range., remediation at Site 34 is instead based on the potential of soil
contaminants to leach to groundwater and contribute to unacceptable human health risks
through the groundwater exposure pathways. At this time of the Draft Final Site 34 FS (F-
504), the groundwater risk assessment for Zone 3 (including Site 34) was not complete.
However, as of the writing of this ROD, the Draft RI for Zone 3 (F-546) has been completed,
SJ.4ROD.1XT
30
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and the risk assessment indicates that the human health risks through groundwater exposure
pathways at Site 34 exceed acceptable levels.
B. Ecological Risk Assessment
Because ecological receptors are not likely to regularly come in contact with deep soils, the
potential risks to ecological receptors at the JETC were evaluated for surface soils (0 to 2 ft
BGS) only. The ecological receptors selected to evaluate potential environmental risks (i.e.,
the short-tailed shrew and the American robin) were chosen because they are representative of
the extensive small m~mmal and ground-foraging "avian communities normally found in this
habitat type, shrew and robin exposure includes potential bioaccumulation of contaminants
identified in surface soil and their transfer across trophic levels, and adequate data exist to
determine the likelihood of impact. Short-tailed shrew and American robin exposure routes
evaluated in the ecological risk as5es$Tt1ent were incidental" soil ingestion and ingestion of
earthworms.
The potential risks to the short-tailed shrew and American robin were assessed by comparing
estimated daily doses with Critical Toxicity Values (CfVs). Hazard quotients were calculated,
for each contaminant, by dividing the estimated daily intake by the CTV. Hazard quotients
were summed across all exposure pathways for each contaminant to develop specific hazard
indices. Contaminant-specific hazard indices (average and maximum concentrations) were then
added to provide cumulative hazard indices for the shrew and robin. A hazard index of greater
than 1 is usually considered the benchmark for concern.
Hazard indices for the short-tailed shrew and American robin are presented in Tables 1.8-1 and
1.8-2 of the Draft Final Site 34 FS Report. The cumulative hazard indices for the shrew
ranged from 305 to 951; the primary contributors to these indices were lead and barium intake
via the invertebrate (earthworm) ingestion pathway. Neither the average nor the maximum
cumulative hazard index for the robin exceeded 1. Concern over the uncertainty associated
with the exposure results was expressed in the conclusions of the Draft Final Site 34 RI Report.
The main concern was related to the impact of anthropogenic contamination that is not site-
S34ROD.TXT
31
-------
related on the outcome of the ecological assessment. Inorganic contaminants 5
JS lead and
barium were detected at the highest concentrations in areas adjacent to the vehi; ,?arking area
and may be more related to normal airfield operation and general industrial use at the base
rather than to site-related activities. When the incremental hazards from these suspected
anthropogenic cont:lminants (lead and barium) are subtracted from the total hazard indices,
risks from JETC-related activities approach EPA's target range. Therefore, the ecological
receptors at the JETC site were not found to be at risk as a result of site-related contamination.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal author . ~s, the le~ 1gency's (Le., Air Force) primary responsibility at NPL and
imilar sites is to uL-.:take remedial actions that are pr:>tective of . .:.nnan health and the
environment. In addition, Section 121 of CERCLA establishes several statutory requirements
and preferences, including that remedial actions must be protective of human health and the
envirQnment; the remedial action, when complete, must comply with all federal and state
environmental standards, requirements, criteria, or limitations, unless a waiver is invoked; the
remedial action selected must be cost effective and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable;
and a preference for treatment remedies that permanently and significantly reduce the toxicity,
mobility, or volume (TMV) of the hazardous substances is a principal element for selection
over remedies not involving such treatment. Response alternatives for addressing JE7'.: sou:rce
areas were developed to be consistent with these Congressional mandates.
Based on preliminary information relating to types of cont:lminants, environmental media of
concern, and potential exposure pathways, remedial action objectives were developed to aid
in the development and screening of alternatives. These remedial action objectives were
developed to mitigate existing and future potential threats to public health and the environment.
The remedial response objective for source control actions at the JETC was to minimi7.e
leaching of cont~minants from the source area soils into groundwater or surface water, thereby
SJ.'ROD.1XT
32
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reducing the potential for the public to ingest or directly contaCt contaminated groundwater or
surface water that presents a health risk (cumulative cancer risk greater than 10-4, or a hazard
index greater than I for each contaminant of concern). Any further reduction in risk through
soil exposure pathways would be a benefit; however, risks from direct contact with, or
ingestion of, source area soils do not exceed the aforementioned criteria and, as such,
remediation based on risk due to site soils is not required. However, as discussed previously,
the Draft Zone 3 risk assessment indicates that groundwater at Site 34 does exceed acceptable
risk levels and as such source actions at Site 34 are expected to reduce groundwater levels.
B. Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial actions are evaluated and
selected. In accordance with these requirements, a range of alternatives was developed for the
site.
With respect to source control, the FS developed a range of alternatives in which treatment that
reduces the TMV of hazardous substances is a principal element. This range included an
altema!ive that removes or destroys hazardous substances to the maximum extent feasible, thus
etiminaring or minimi7ing to the degree possible the need for long-term roanagement. This
range also included alternatives that treat the principal threats posed by the site but vary. in the
degree of treatment employed and the quantities and characteristics of the treatment residuals
and untreated waste that must be managed, alternatives that involve little or no treatment but
provide protection through engineering or institutional controls, and a no action alternative.
In Section 3 of the Draft Final Site 34 FS Report, technologies were identified, assessed, and
screened based on implementability, effectiveness, and cost. These technologies were placed
in the categories identified in Section 300.430( e)(3) of the NCP. Section 4 of the Site 34 FS
Report presented the remedial alternatives developed by combining the technologies. The
purpose of the initial screening was to reduce the number of potential remedial actions for
further detailed analysis while preserving a range of options. Each alternative was then
evaluated in detail in Section 5 of the Site 34 FS Report.
SJ.4ROD.iXT
33
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In summary, of the eight source control remedial alternatives screened in Section 4 of the Site
34 FS Report, five were retained for deL: ~d analysis. The following table identifies the five
alternatives that were retained through. the screening process:
I I .. !
Alternative No. Description
1 No action (including monitoring).
2A In situ soil aerobic biological treatment with soil vapor extraction.
and on-site groundwater extraction and treatment with on- and off-
site groundwater disposal.
3A Excavation of contaminated soil; on-site ex situ solid-phase
biological/vapor extraction treatment of contaminated soil; on-site
d.i;: )sal of tt?'1ted soil; grr -:dwater pumping and treating for
ex. :fation de.vatering; an: :ated groundwater discharge to sanitary
sewer.
4 Excavation of contaminated soil; thermal desorption of contaminated
soil; on-site disposal of treated soil; pumping and treating of
groundwater for excavation dewatering; and treated groundwater
discharge to sanitary sewer.
SA Excavation of contaminated soil; off-site treatment/disposal of
contaminated soil; backfilling of excavation with clean fill;
groundwater pumping and treating for excavation dewatering; and
disposal of treated groundwater to sanitary sewer.
. ..
ilL DESCRIPTION OF ALTE&"'iATIVES
This subsection provides a narrative summary of each alternative evaluated. A detailed tabular
assessment of each alter!:
-------
Alternative 1 - No Action
The no-action alternative was evaluated in detail in the Site 34 FS Report to serve as a baseline
for comparison with the other remedial alternatives under consideration. Under this alternative,
no treatment or containment of source areas would occur. This alternative does include deed
restrictions for the property and a long-term soil" monitoring program. The GWTP currently
operating at the site would continue to operate until the zonewide groundwater issues are
addressed in the Zone 3 RIfFS. This alternative would not meet the cleanup objectives for this
site.
Estimated time for design and construction: None.
Estimated time for operation: 30 years.
Estiinated capital cost: $8,300.
Estimated O&M (present-worth): $358,700.
Estimated total cost (present-worth): $367,000.
Alternative 2A - In Situ BioloirlcallSVE Treatment
This alternative involves the use of an in situ treatment system that would consist of aerobic
biological treatment and soil vapor extraction (SVE) as a means of providing oxygen to the
subsurface. The components of this alternative are as follows:
.
Removal of rem3ining USTs and associated piping at the site.
.
Groundwater extraction at a rate of 80 gpm to dewater the overburden to
enhance SVE and aerobic biological treatment.
.
SVE and gaseous-phase carbon treatment of the collected vapors.
.
On-site treatment via chemical precipitation. multimedia filtration. and carbon
adsorption of extracted groundwater prior to process use or discharge.
.
Nutrient addition to a fraction of the treated groundwater and reinjection of the
nuttient-rich mixture to stimulate the natural aerobic microorganisms for
biological degradation of organic conrnmin3nts.
.
Discharge of excess treated groundwater to the sanitary sewer and/or storm
drainage system.
S3'&OD.TXT
35
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.
Environmental monitoring to evaluate the effectiveness of the remedial action
during the remedial process that consists of vapor sampling and analysis an~
after completion of the remedial actio~ consists of soil sampling and analysis.
Estimated time for design and construction: 18 months.
Estimated time for operation: 4 years.
Estimated capital cost: $1,669,200.
Estimated O&M (present-worth): $864,600.
Estimated total cost (present-worth): $2,534,000.
Alternative 3A - Ex Situ Solid-Phase BiolomcaI/SVE Treatment
The components of this alternative are as follows:
S34ROD.TXT
.
Groundwater extraction at a rate of 30 gpm to dewater the CODt:lminated soils
in preparation for excavation.
.
SVE and gaseous-phase carbon treatment of the collected vapors.
.
On-site treatment of extracted groundwater with the existing GWTP that consists
of greensand filtratio~ activated carbon adsorptio~ and subsequent discharge to
the base sanitary sewer.
.
Excavation and ex situ solid-phase biological/vapor extraction treatment of 5,350
cubic yards (yd3) (or less, if field screening indicates that removal of the full
amount is not necessary) of cont:lmin:lted soil.
.
Backfilling of soils not requiring treatment (approximately 6,550 yd3) that were
excavated to access soils exceeding cleanup goals in the excavatio~ following
removal of cODt:lminated soils.
.
. Backfilling of treated soils into the excavation following remediation.
.
Environmental monitoring of soils' to evaluate the. effectiveness of the remedial
action during the remedial process.
.
Removal of ~aining USTs and associated piping at the site.
Estimated time for design and construction: 18 months.
Estimated time for operation: 18 months.
Estimated capital cost: $1,265,600.
Estimated O&M (present-worth): $469,200.
Estimated total cost (present-worth): $1,735,000.
36
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Alternative 4 - Thermal Desorotion Treatment
The components of this alternative are as follows:
.
Groundwater extraCtion at a rate of 30 gpm to dewater the contaminated soils
in preparation for excavation.
.
Excavation of 5,350 yd3 of contaminated soils (or less, if field screening
indicates that removal of the full amount is not necessary) and temporary
stockpiling in a controlled storage area on site. Mixing and screening of soils
would be performed prior to treatment.
.
Thermal desorption treatment of contamin~ted soils with a mobile unit. The unit
would have an estimated capacity of 50 tons/day, and one pass through the unit
would be required. .
..
On-site treatment of extracted groundwater with the existing GWTP and
subsequent discharge to the base sanitary sewer.
.
Bacldilling of soils not requiring treatment (approximately 6,550 yd3) that were
excavated to access soils exceeding cleanup goals in the excavation, following
removal of cont~minated soils.
.
Backfilling of treated soils into the excavation following remediation.
.
Environmental monitoring of soils to evaluate the effectiveness of the remedial
action during the remedial process.
.
Removal of rem~ining USTs and associated piping at the site.
Estimated time for design and construction: 2 years.
Estimated time for operation: 2 years.
Estimated capital cost: $3,512,000.
Estim~ted O&M (present-worth): Included in capital cost.
Estim~ted total cost (present-worth): $3,512,000.
Alternative SA - Off-Site Treatment
The components of this alternative are as follows:
S3«QD:rxr
.
Groundwater extraction at a rate of 30 gpm to dewater the contaminated soils
in preparation for excavation.
37
-------
.
Excavation of 5,35 of cOIl:::~ted soil.: (or less, .:- field screening
indicates that remov,,-. :he full amount is not necessary) and transport to an
approved off-site treatme::.ddisposal facility.
.
On-site treattnent of extracted groundwater with the existing GWTP, with
greensand filtration and carbon adsorption as process units and subsequent
discharge to the base sanitary sewer.
.
Backfilling of 6,550 yd3 of soils not requiring treatment that were excavated to
access soils exceeding cleanu? goals in the excavation, and additional backfilling
with clean fill following removal of:ontaminated soils.
.
Environmental monitoring of soils to evaluate the effectiveness of the removal
action. .
.
Removal of remaining USTs and associated piping at the sit:'
Estir-ted time ~Jr design and construction: 1 year.
. Estimated time for operation: 1 year.
Estimated capital cost: $1,614,000.
Estimated O&M (present-worth): Included in capital cost.
Estimated total cost (present-worth): $1,614,000.
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121 (b)( 1) of CERCLA presents several factors that must be considered when assessing
alternatives. Building on these specific statutory mandates, the NCP has promulgated nine
evaluation criteria to be used in as; individual' -'medial alternatives. A detailed analysis
was performed on the. altemative~
.:he nine evaluation criteria to select a site remedy.
A summary of the comparison of each. alternative's strengths and weaknesses with respect to
the nine evaluation criteria is presented as follows.
Threshold Criteria
The two threshold criteria that follow must be met for the
selection in accordance with the NCP:
~ernatives to be
~ble for
1.
Overall protection of human health and the environment addresses whether a
remedy provides adequate protection and describes how risks posed through
SJ4RQD.1XT
38
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2.
each pathway are elim;na~ reduce~ or controlled through treattnent,
engineering controls, or institutional controls.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether a remedy will meet all of the ARARs or other federal and
state environmental laws, and/or will provide grounds for invoking a waiver.
Primarv Balancing: Criteria
The following five criteria are used to compare and evaluate the elements of one alternative
to another that meet the threshold criteria:
3.
4.
Long-term effictiveness and permanence addresses the criteria that are used to
assess alternatives for the long-term effectiveness and permanence they afford,
along with the degree of certainty that they will prove successful.
Reduction of toxicity, mobility, or volume (I'MV) through treatment addresses the
degree to which alternatives employ recycling or treatment that reduces the
TMV of cont~minants, including how treatment is used to address the principal
threats posed by the site.
5.
Short-term effectiveness addresses the period of time needed to achieve
protection and any adverse impacts on human health and the environment that
may be posed during the construction and implementation period, until cleanup
goals are achieved.
6.
Implementability addresses the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implemen~
a particular option.
7.
Cost includes estimated capital, operation and maintenance (O&M), and present-
worth costs.
Modifying: Criteria
The modifying criteria that are used in the final evaluation of remedial alternatives generally
after public comment on the RIlFS and Proposed Plan are received are as follows:
S341l0D.1Xt'
39
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8.
State acceptance addresses the state's position and key concerns related to the
preferred alternative and other alternatives, and the state's comments on ARARs
or the proposed use of waivers.
9.
Community acceptance addresses the public's general response to the
alternatives described in the Proposed Plan and RI/FS Reports.
A detailed tabular assessment of each alternative according to the nine criteria is presented in
Tables 5.2-1 through 5.2-5 of the Site 34 FS Report.
Following the detailed analysis of each individual alternative, a comparative analysis, focUsing
on the relative performance of each alternative against the nine criteria, was conducted. This
comparative analysis is summarized in Table 5 in Appendix A. .
The following subsection presents the nine criteria, including the two modifying criteria not
discussed in the FS; a brief narrative summary of the alternatives; and the alternatives'
strengths arid weaknesses according to the detailed and comparative analysis.
A. Overall Protection of Human Health and the Environment
The no-action alternative (Alternative 1) would not meet this criterion in its entirety. The use
of deed. restrictions on property use would preclude use of site groundwater and future
activities that could disturb source area soils; however, this alternative does not provide any
minim;~tion of leaching potential of source. area soil contaminants to groundwater.
Additionally, Alternative 1 does not result in a reduction in soil contaminant TMV, except by
natural processes.
Alternatives 2A, 3A, and 4 provide on-site treatment of contaminated source area soils and,
therefore, reduce the potential for contaminant leaching from source area soils to groundwater.
This would result in a lower potential for human and ecological receptors to be exposed to
conViminated soils. All three alternatives result in a reduction of TMV of source area
contaminants in both soil and groundwater.
S34ROD.TXT
40
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Also, by treating the source area soils on-site, liability is not transferred from the original site
to an off-site disposal facility as for Alternative SA.
Alternative SA also minimi7.es the leaching of source soil contaminants to groundwater by
removing contaminated soils from the site. However, the degree of reduction in TMV of soil
contaminants at the off-site treatment/disposal facility is unknown because the process would
be determined at the time of remedial design to provide the most cost-effective solution.
Implementation of Source Control Alternatives 2~ 3~ 4, and SA would ultimately aid in
achieving the groundwater cleanup goals that will" be presented in the Zone 3 FS Report.
B. ComDliance with ARARs
Each alternative was evaluated for compliance with ARARs, including chemical-, action-, and
location-specific ARARs. These alternative-specific ARARs are presented in Appendix F of
the Site 34 FS Report.
In the long term, all of the source control alternatives, including the no-actionfmstitutional
control alternative, would achieve chemical-specific ARARs for soil; however, the alternatives
differ in the time it would take to achieve compliance.
With the exception of the no-actionfmstitutional control source control alternative (Alternative
1), all of the source control alternatives would meet, in time frames ranging from 1 to 4 years,
all soil ARARs. In this time frame, Alternative I woul~ most likely, not comply with the
State of New Hampshire requirement that soils containing spills of virgin petroleum products
achieve a 1 ppm total BTEX concentration. All other alternatives would meet this requirement.
The ability of source control alternatives to achieve chemical-specific ARARs in groundwater
was not evaluated in the Site 34 FS. However, all alternatives that involve extraction and
treatment of groundwater would achieve groundwater treatment goals and/or surface water
discharge treatment goals prior to groundwater disposal.
SJ.4ROD.'TXT
41
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It is expected that all alternatives would comply with action- and location-specific ARARs,
except the New Hampshire Virgin Petroleum Policy with regard to treated soil disposal. The
policy indicates that soil requiring treatment should not be placed within 0.5 mile of a water
supply well. As the Haven well is less than the prescribed 0.5 mile, Alternatives 3A and 4
would not meet this location-specific ARAR. However, it should be noted that a groundwater'
divide exists between Site 34 and the Haven Well, such that cont~m;TH!tion from Site 34
, groundwater is highly unlikely to reach the Haven Well as the groundwater flow is away from
the Haven Well.
c. Lon!!- Term Effectiveness
Since Alternative I would not be effective in reducing conrnm;nantleaching to groundwater,
potential human health and environmental risks associated with untreated source area soils
would still exist. As previously indicated, leaching would reduce the concentrations of
contaminants of concern, but this would require many years to achieve and would result in
continuing groundwater conrnm;n~tion.
Alternatives ~ 3A, 4, and SA all involve removal and/or reduction of cont~m;n~nt
concentrations in source area soil. It is expected that all of these alternatives would achieve
a residual soil BTEX concentration of 1 ppm; would, therefore, reduce further unacceptable
leaching; and, in ~ would reduce conrnm;nant concentrations in source area groundwater.
The I-ppm total BTEX limit is based on a state policy for virgin petroleum products (F-338)~
Therefore, these alternatives would provide the same level of long-term protectiveness to
human health and the environment and differ primarily in the time required to achieve cleanup
goals. Because it is difficult to predict the effectiveness of in situ treatment, it was assumed
at this time that this technology co~d achieve the same degree of organic contaminant removal
as alternatives involving excavation and treatment or disposaL All four of the action
alternatives would further reduce current risks to human health and the environment resulting
from ingestion of, and dermal contact with, cont~m;n~t~ soils. This would be attributable
predom;n~ntly to the treatment or removal of P AHs, which contribute to human health risks
exceeding 10-6. Alternatives 4 and SA would likely provide the greater decreases in risks, since
. S34ROD.1Xr
42
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the biological processes in Alternatives 2A and 3A may not provide as significant treatment
of P AHs. However, as the risk is below acceptable levels, this does not greatly affect
comparative effectiveness.
D. Reduction in Toxicitv. Mobilitv. or Volume Throul!:h Treatment
Because it does not involve treatment of source area soils, Alternative I would not provide a
reduction in contaminant TMV other than natural attenuation that would occur over many
years. It is expected that Alternatives ~ 3A, and 4 would all provide the same order of
magnitude reduction in TMV of source area soil contaminants through treatment.
Alternative SA, which involves excavation and off-site disposal of source area soils, would
greatly reduce the volume of soil contaminants present at Site 34; however, the degree of
overall reduction in contaminant TMV that would occur at an off-site facility is unknown, as
the treatment/disposal method would be determined at the time of remedial design.
All of the alternatives that incorporate extraction and treatment of groundwater would involve
some reduction in TMV of contaminants in source area groundwater.
E. Short-Term Effectiveness
Implementation of Alternative 1 involves the fewest short-term impacts on human health and
the environment because it does not involve activities that would disturb cont~minated soil.
However, this alternative would not provide any reduction in source area soil contamination
other than natural attenuation that would occur over time; therefore, protection of human health
and the environment would not be achieved for many years.
Alternatives 3A, 4, and SA all involve similar short-term impacts on site workers, the
surrounding community, and the environment as they all involve excavation and subsequent
handling of source area soils. However, because Alternative SA involves off-site disposal
rather than on-site treatment, there may be fewer impacts on site workers and the surrounding
community than for Alternatives 3A and 4 because of fewer on-site soil handling activities.
S34R.OD:rxr
43
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Ho\; ;;ver, there would be potential risks to communities associated with acciC
could occur during transport to the disposal facility.
. '1 spills that
Potential impacts on workers and the surrounding community would be associated with the
release of vapors (volatile BTEX constituents) and particulates during excavation and soil
handling activities. Methods that would be implemented to ensure the protection of workers
and area residents during soil excavation and treatment are considered reliable and include use
of interim geomembrane covers on exposed source area soils, use of appropriate worker
personal protective equipment (PPE), implementation of dust and odor suppression techniques
to control fugitive dust emissions, and cont:- ""}us air mor:itoring to ~valuate site conditions.
Implementation of Alternative 2A, which involves in situ treatment of source area soil, would
involve fewer short-term impacts on site workers and the surrounding community than
Alternatives 3A, 4, and 5A because it does not involve extensive excavation and subsequent
handling of source area soils. This alternative may, however, have a greater impact on
surrounding wetlands environments because of long-term (2 to 4 years) dewatering of source
area soils. The alternatives involving excavation (Alternatives 3A, 4, and 5A) would have a
slight impact on the wetlands because approximately 0.25 acre would be excavate:::: :~idlor used
as access to the excavated area and would require restoration. Wetlands deline. ~ for Site
34 and all of Zone 3 is shown in Figure 6. The area impacted as a result of dewatering for
Alternative 2A is difficult. to. predict; however, restoration would occur naturally when the
water table returns to its static level. Potential impacts on wetlands from Alternative 2A will
be evaluated after the Zone 3 groundwater modeling effort is completed.
Alternatives 3A, ., and SA, which involve installation of on-site treatment systems and/or
stockpiling of excavated soil, may require clearing of surrounding woodlands. However,
precautions would be taken to I:...: . .:~ the impacted areas by using existing cleared areas
effectively.
Alternative 5.-'-. -.:vould likely ach.:.:::ction sc J.er th< :he oth:.. -:ltematives b:. luse it
involves off-site disposal; however. this would depend ultimately on t:.:.. ::me frame ov~ which
SJ.4ROD.TXT
44
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the disposal facility can accept excavated soils. It is expected that Alternative 4 could achieve
protection in one constrUction season, while Alternative 3A could achieve protection in one or
two constrUction seasons. Alternative 2A would require several years to achieve protection.
As previously indicate~ Alternative I would not achieve protection for many years.
F. Imolementabilitv
Alternative I would be the most readily implementable alternative because it involves the
fewest remedial activities. Alternative 2A would be the most difficult alternative to implement
technically because it involves in situ treatment, which is, in general, not as well-proven and
more difficult to control than ex situ treatment processes. This alternative involves numerous
activities including dewatering of source area soils, distribution of nutrients, and
implementation of SVE. All of these activities would have to be carefully controlled to
maintain aerobic degradation. Many site-specific conditions could interfere with the
implementation of these activities, thus inhibiting the ability to achieve successful biotreatment
of source area soil contJ:lmination. Because Alternative 2A also involves more extensive
groundwater extraction than the other alternatives, the existing. groundwater treatment system
would have to be modifi~ thereby complicating the implementation of this alternative to a
greater level than the other remedial alternatives.
Alternatives 3A and 4, which both involve excavation and on-site treatment of source area
soils, would be similar in ease of implementation. Both of these technologies are fairly well-
developed and have been used successfully at other sites. However, site-specific conditions
could complicate implementation of these technologies at Site 34. For example, potential site-
specific difficulties associated with implementation of low-temperature thermal desorption
(Alternative 4) may include possible soil handling problems because of high moisture content
and/or silty soils that could significantly affect system throughput and cost. Both of these
treatment technologies would require preHminary bench-scale and, possibly, pilot-scale testing
prior to implementation of the technology. No major technical problems associated with
bench- or pilot-scale testing are expected.
S34ROD.1XT
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It is "expected that Alternative SA, which involves soil excavation and off-site disposal, would
be the alternative most easily implemented technically, except for Alternative 1.
In terms of administrative feasibility, Alternative 4 would be the most difficult alternative to
implement administratively because it would likely require the greatest time for obtaining
agency permits/approvals. Thermal desorption would require rigorous testing to ensure
compliance with applicable air quality requirements. Alternative SA, which involves off-site
disposal of source area soil, would require federal and state agency permits for off-site
transportation and disposal, which should be easy to obtain, and consultation with the selected
disposal facility to ensure that the excavated material is within specifications.
All of the alternatives involve technologies and services that are readily available through
multiple vendors. Treatment, storage, and disposal facilities also are readily available to accept
treatment residuals.
G. Cost
The estimated present-worth costs of the alternatives follow:
Present-W OM
Capital Cost 3O-Ycar ~t-Wonb O&:M Cost Cost
Remedial AJtIeI'naDYe
I. No Action/Instiludonal Controls $8.300 $358.700 $367,000
2A. In Situ Soil Aerobic Biological Treatment wi1b
SVE and Qo.5i11: Groundwara' Emaction aad
Trea!mcnt wi1b Oft. and Off-Sia: Disposal SI.669.200 Sa64,600 $2.534,000
3A. ExcavaDon aDd Oa-Site Ex Silu
BiologicaWapor &traction Tremnent of
Contamina!ed Soil and On-SiII: Disposal. and $1,265,600 $469,200 SI,735,000
On-Site Cirouadwa1c- Treatmeut and Otf-Site
Disposal for ExcanDon De.....~
4. ExcavaDon aDd Qo.5ite 1'bcrmII Desorption of AD O&:M costs bave been
Contaminated Soil and On-Sia: Disposal. and iDcorporlll:d iDto tile .,d; ."'d
On-Sitc Ciro~ Treatmeut and Otf-Site $3,512,000 C3pitaI COSt because of 1bc sbort $3,512,000
Disposal for Excavmion c.......;.., chnIiou of me ~ actioa.
5A. Excavabon and Otf-Site TreIImcDt and/or AD O&M costs have been
Disposal of Coatlminarcd Soil. IDd On-Site iDcorporlll:d into die ~..oIIIod
Groundwan::r Tn:mncnt and Off-Sill: Disposal SI,614,000 capital COSt because of die sbott SI,614,ooo
for Excavation Dewatering dandion of the r==fial actioa.
SJ4ROD.TXT
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H. State Acceptance
NHDES has been involved in oversight of the study of Pease AFB since the mid-1980s, as
summarized in Section II. NHDES, as a party to the FFA, has reviewed this document and
concurs with the selected remedy. A copy of the Declaration of Concurrence is attached as
Appendix C.
L Community Acceptance
The comments received during the public comment period and the public hearing on the
Proposed Plan and FS are summarized in the Responsiveness Snmmary (see Appendix D). The
selected remedy has not been significantly modified from that presented in the Proposed Plan.
X. THE SELECTED REl\1EDY
The remedy selected for the JETC (Alternative SA) involves the excavation of source area soils
(shown in Figure 7), with on-site treatment of groundwater extraeted for dewatering purposes.
The soil will be sent to an off-site treatment/disposal facility. A remedial process flow sheet
for Alternative SA is presented in Figure 8.
Several options are available for off-site treatment and/or disposal of contamin~ted soil at Site
34. The disposal will be in accordance with all applicable regulations at the time of disposal,
and the actual method of disposal or treatment will be determined during the design phase.
The treatment/disposal options include:
.
Remote (on-/off-base) treatment/disposal facilities such as:
Incinerators.
Low-temperature thermal treatment units.
Asphalt batching plants.
Landfills..
With respect to off-base facilities, it is important to consider possible treatment requirements.
EPA's land disposal restrictions and treatment standards would only apply if the contaminated.
SJ.4ROD.tXT
47
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.
~
/1 -
)
/ -.--'-
/
---.----.
l
I
_J
Sin: 34
(JETC)
0E
-----------.--.
.- 60 __d'
4-~'
.....---
"
._----___---------------_d_U- -_..
/'
"-
"""
/
/
J SUrf- conloU./e'8vation
60 Irr.~I;'" t~'(l!.tIng
,,-- .,.J
~
r1
~
~
8
lEGEND:
@) 6J4 Bedrock recovery we" . exlsllnq
& '" Propo.ed hybrid ,ecovery y.
~ f'.opo,ed excavated Con":II,
--481FT IMSl) . 2 'oollnlervat
10 0 II! JO «I
~F:..:..;..:~
SCAlE IN FEET
-.....-:
\!mr.:~-d=='
'. j..iit'IiWads
c
o
@
634
8... 34 (JETC)
. 1, A8cotd 01 I18clllon
Pe8II~ },,, force 88_. New HlmP8h/18
FIGURE 7
p"OPOSED EXCAVATION FOR REMOVAL OF
SOIL CONTAMINATED WITH ORGANICS
-------
Q c::I 30 GPM
~~
GROUNDWA TER
EXTRACTION
SYSTEM
~
EXCA VA TlON
Of SOIL
t
CLEAN FILL
LEGEND
GREENSAND
flLTRAllON
J UNITS
J6- DIAMElER
Q - 15 GPM EACH
TEMPORARY
STORAGE
WHEN REQUIRED
2 UNITS
50,000 GAL. EACH
4000 CY
TO
7000 CY
ANALYTICAL
TESTING
PREP ARA TlON
fOR
TRANSPORT
OISPOSAL
Off-SITE
GRANULA TED
ACl1VA TED
CARBON
J UNITS
60. DIAMElER
Q - 60 GPM EACH
SANITARY SEWER
DISCHARGE
Sile 34 (JETC)
. Stage 3, Record o' Decision
Pea88 Air Force 8a88, New Hampshire
FIGURE 8
REMEDIAL PROCESS FLOW SHEET
-------
soil were to be classified as a hazardous waste. The soil would be a hazardous waste if it
failed the TCLP test and was not considered exempt from RCRA because of the petroleum
product exemption. However, JETC soils were tested and did not exceed TCLP criteria and,
therefore, would be classified as nonhazardous materials. T ota! petroleum hydrocarbon (TPH)
concentrations in the' Test Cell Ditch sediments were in the same range of concentrations
(1,000 to 10,000 mg/kg) observed in soil samples from the site. It is therefore reasonable to
expect that the site soils would pass the TCLP as a nonhazardous waste, and treatment would
not be required before disposal. Subsection 2.2 of the Draft Final Site 34 FS Report discusses
the exclusion for petroleum-conrnmin~ted media that fail the TCLP.
There are at least two commercial landfii .J. the region that would accept the untreated soils.
This option would provide strictly for disposal, not treatment, of the cont~min~ted soils. The
nearest commercial incinerators designed to treat cont~min~ted soil are located several hundred
to more than 1,000 miles from the site. Off-site incineration is not a cost-effective method of
managing Site 34 soils.
Low-temperature thermal treatment, using technology as descnOed for Alternative 4, is a more
realistic option than incineration for the off-site treatment of nonha7~Tdous petroleum-
contaminated soils. A number of permitted facilities in New Hampshire are capable of
providing this service. The soil would be excavated and transported to the treatment facility,
and the decontaminated soil could either be returned to the site for backfilling, or used for
some other application (e.g., landfill cover). The use of a thermal desorption unit for severaI
sites may be a viable option depending on remediation activities planned for other sites on
base.
An option that provides for both treatment and resource recovexy is the incorporation of the
contaminated soils as aggregate into asphalt paving material. There are at least two asphalt
batching plants within 50 miles of the site that provide this service, one of which has already
been used to treat and dispose of the sediments removed from the Test Cell Ditch. The cost
of off-site treatment and resource recovery is comparable with off-site landfill disposal.
SJ.4ROD. TXT
50
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Asphalt batching or low-temperature thermal tr~ent appear to be the preferred options for
managing Site 34 soils on-base or off-site, provided the assigned facility complies with all
permit requirements. The petroleum-CODt~m;n~t~d soils would have to meet the qualification
and quantification standards established by NHDES policy and the specific standards of the
treatment facility. NHDES sets minimum requirements for analytical methods, acceptable'
limits, and frequency of sampling. Based on the Test Cell Ditch sediment removal and
disposal, the treatment and disposal of Site 34 soils in an asphalt batching process or on-base
thermal desorption unit appears to be feasible.
A. Methodology for Soil Cleanup Goal Determination
Since only sources of cont~mination at Site 34 are being addressed at this time, the only
medium evaluated in the FS and the ROD are site soils. The need for action on the site soils
was .initially evaluated for direct human and ecological receptor contact and the potential for
soil cont~min3nts to leach to and adversely impact groundwater above applicable standards.
Based on data developed in the RI and the BRA, remedial measures to address risk associated
with possible human and ecological receptor- exposure to source soils are not warranted because
present and future risks are within or below EPA's acceptable risk range. However, available
data suggest that area soils are a potential source of release of VOCs to groundwater. This
potential release may result in an unacceptable risk to'human receptors who may come in
contact with conrnmin~ted groundwater. Therefore, cleanup levels for soils were established
to protect the water-bearing unit from potential unacceptable soil leachate. The Summers
Model was used to estimate residual soil cleanup goals that are not expected to impair future
groundwater quality. Interim cleanup levels for groundwater were used as input into the
. .
leaching model Final groundwater cleanup goals will be developed as part of the Zone 3 FS.
Tables 6 and 7 in Appendix A present the input data for the leaching model.
If the predicted protective soil cleanup goal concentrations were not capable of being detected
with good precision and accuracy, then the practical quantification limits of the common soil
analytical methods were selected as the cleanup goals for soils. The cont~minants evaluated
S34ROD.1XT
51
09t111193
-------
~6J
(
for potential leaching cleanup goals were the' contaminants of concern in soil and contaminants
i
detected in both soil and groundwater. TAble 8 in Appendix A summarizes the soil cleanup
/
goals required to protect public health and the water-bearing unit from exceeding standards
I
based on leaching of chemicals from,f soils to groundwater. The leaching potential was
determined for organics only. The Summers Model results were then compared to maximum .
detected concentrations in soil and to~ values. Only one organic cont.amin~nt of concern
exceeded a Summers Model value. ~ 2-Butanone exceeded the leaching-based cleanup
gOa4 it was decided that as only one location exceeded the leaching-based cleanup goal, and
2-butanone is a common laboratory cont.aminant, it did not warrant remediation.
Since the model did not indicate the. need for remediation based on leaching potential alone,
the soil cleanup goals were based on the NHDES Virgin Petroleum Products Policy, which
allowed a maximum value of 1 ppm total BTEX in soil. The NHDES cleanup goals were
chosen because this regulation is appropriate. for this situation.. At the request of EP A Region
I, Table 9 in Appendix A was developed and presents the human health risks associated with
the soil cleanup goals chosen. It should also be noted at this time that monitor wells in the
source area (617 and 6041) clearly indicate that the groundwater at-Site 34 is being adversely
impacted. It is anticipated that somce area activities will help to reduce the groundwater
cont.aminant levels and result in a shorter time required for groundwater remediation.
These cleanup levels in soils are consistent with ARARs for groundwater, attain EPA's risk
management goal for remedial actions, and have been determined by EP A to be protective of
human health and the environment. These cleanup goals must be met at the time of
implementation. The area. of excavation is shown on Figure 7.
B. Groundwater Treatment Goals
The target levels developed in the FS are only intermediate values for groundwater treated in
. .
conjunction with source control actions; final groundwater remediation objectives have been
developed in the Zone 3 Draft FS.
S34ROD.1XT
52
-------
At ~e time of Site 34 FS Report preparario~ groundwater was not under evaluation at the
JETC; however, groundwater will be evaluated fully in the Zone 3 RI and FS Reports. Target
tre~tment levels for groundwater were developed for groundwater extracted during source area
remedial activities~ The target treatment levels, presented in Table 10 in Appendix A, are
based on MCts, not site-specific risk-based values. These levels are considered to be target'
treatment levels only for groundwater extracted for source area remedial activities.
The extraction of groundwater during remedial activities is only designed to provide easier
access to cont~minated soils. Source area groundwater and management of migration
groundwater has been addressed in a separate Zone 3 FS document. A risk assessment has
been performed on groundwater contamination at the JETC as part of the Zone 3 Draft RI
Report to determine whether groundwater remedial action is warranted, and fmal groundwater
cleanup goals have been established for Zone 3 in the Zone 3 Draft Feasibility Study.
C. Target Surface Water Discharge Concentrations
At the time of Site 34 FS Report preparation, surface water was not fully evaluated at the
JETC. Surface water bas subsequently been evaluated in the Zone 3 Draft RI and Draft FS
Reports.
However, target treatment levels for groundwater were developed in the Site 34 Draft Final FS
Report for discharge of treated groundwater to surface water during source area remedial
activities. The target treatment levels are presented in Tables 2.5-6 and 2.5-7 in the Draft Final
Site 34 FS Report, and are based on A WQC, not site-specific risk-based values.
These levels are considered to be target treatment levels for surface water discharge of treated
groundwater extracted for source area remedial activities. A BRA will be performed on
surface water cont~miriation as part of the Zone 3 RI Report to determine whether surface
water remedial action is warranted.
SJ.4IWD.lXT
53
-------
D. Description of Remedi..~. Compr ::lents
The remedy chosen for the JETC, whose main remedial goal is source control, will in'i.::>lve the
following key components:
.
Excavation of JETC soils that contain cont::lminant concentrations' exceeding
site-specific cleanup goals. A mobile laboratory will be on-site to confirm the
removal of cont.amin::'.:d material. The excavated material will be temporarily
stored and dewatered, on-site, prior to removal to the off-site facility.
.
The ex' "vation will :,. 1;ackfilled with clean fill to a level that matches existing
grade .;.... :he site.
.
Excavated contam.ir ":laterials will be transported to a treatment/disposal
location as soon a.:: . ..:eduling aile .' The type of disposal facility will be
chosen (Le., aspbaitoatch, RCRA ), Subtitle D landfill, on-base thermal
desorption unit, or other) at the tim:.: '.. .:emedial design based on cost and other
factors.
.
Groundwater extracted as part of the excavation and/or dewatering process will
be treated at the existing pilot GWTP. Holding tanks. will be provided for
storage of groundwater prior to treatment. .
..
Prior to completion of remedial activities, EP A and NHDES will conduct a
;eviewas part of the regulatorr approval m-ocess to ensur': ","1.t the remedial soil
::leanup goals have been me"
Figures 7, 8, and 9 provide a plan of the estimated excavation area, pro~ flow sheet, and
available staging area at Site 34, respectively. Detailed descriptions of the various components
are provided in this subsection.
It is expected that 5,- ) yd3 of soils from Site 34 will be excavated; volumes are presented in
the following table. Of the possible total of 5,350 yd3, up to 1,200 yrŁ may need to be
. . .
.'
excavated using wet excavation techniques and/or draining of the excavation via pumping from
. .
the bottom of the hole. As discussed previously, the fin::.!. volume rem~ved will be determined
at the time of remediation using field screening teclmiques. The cclumes preseLted are
est:imaL. 'IDd are subject to field verification.
S34RCD.lXT
54
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Total Volume Required for Excavation 11,900 yd3
Total Volume of Excavated Soils not Requiring 6,550 yd3
Treatment
Total Volume of Excavated Soils Requiring 5,350 yd3
Treatment
Cohesive Volume 1,660 yd3
Noncohesive Volume 3,690 yd3
Since a portion of the area to be excavated will result in destruction of adjacent wetlands,
erosion and sedimentation controls, as well as careful excavatio~ will be used in the soil
removal in these areas. Any wetlands adversely impacted will be restored.
During excavation and temporary storage activities, erosion runoff and VOC and particulate
emissions will be controlled via the use of a temporary runoff detention area. adjacent to the
stockpile,. and placement of a geomembrane on the stockpile and sideslopes of the excavation
areas. Continuous on-site air monitoring also will be conducted during excavation' and
stockpiling activities.
Some dewatering of the excavation area will occur with the use of well points, which will
extract groundwa~ at a rate of approximately 30 gpm. Following extraction, groundwater will
be stored in five 20,OOO-gallon storage tanks. Groundwater will then be treated at the existing
. .
pilot GWTP at Site 34, which consists of potassium permanganate injection in conjunction with.
greensand filtration for iron and manganese removal followed by activated carbon adsorption
for VOCs removal. Treated effluent. will meet groundwater treatment goals as presented in
Subsection 2.5 of the Site 34 FS Report, and will be discharged to the base sanitary sewer
system.
. .
Excavated soil could potentially be transported to an asphalt batch facility, RCRA TSD facility,
Subtitle D landfill, or an on-base mobile thermal desorption unit. The treatment/disposal
method will be chosen during remedial design phase based on cost and analytical testing prior
SJ4ROD.'TXT
55
-.-
-------
.
.
I
LEGEND:
I
/
--
---
WeU.nds boundary
UC1
~ 0.0
-,
I
I
I
~l
~
J~~ \\\
1~
C), .
. . \
! ~ i I
DOVE" AVENUE
"
()
(I
Jl
l-
{ ,
TEST
CEll
DITCH
r :.
11
J
AVAILABLE STAGING AREA
.100,000 t sa. FT
.~~
AIRCRAFT
PARKING
APRON
I Surf... contour/.lev.don
60 (FTIMSL). Erlsllng
, -- 10 IDOl IntMVai
/ TI..."no
: : :: Asphah ,ood.
r1
811. 34 (JETC)
~ 3, Aecor'd 01 D8c:lelon
,... Air Fon:e Be.., New H8mp8hl,.
FIGURE 9
AVAILABLE STAGING AREA
~
101 to . " 1011
...
SCALE II FEET
_u.-:
I!m:':~~''''''dc::r.=,
-------
to removal activities, and will reflect the statUtory preference for treatment contained in
CERCLA Section 121(b).
XI. STATUTORY DETERMINATIONS
The remedial action seleaed for implementation at the Pease AFB JETC site is consistent with
CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human
health and the environment, attains ~ and is cost effective. The selected remedy also
may satisfy the statUtOry preference for treattnent that permanently and significantly reduces
the TMV of hazardous substances as a principal element. Additionally, the selected remedy
uses alternate treatment technologies or resource recovery technologies to the maximum extent
practicable.
A. The Selected Remedy is Protective of Human Health and the Environment
The remedy at the site will permat1ently reduce the risks posed to human health and the
environment by eliminm;ng, reducing, or controlling exposures to human and ecological
receptors through treatment and by engineering controls, more specifically:
.
Excavation of cont~minmM soil and transport to an off-site treatment/disposal
facility will reduce the 1e8r.hinepotential of con1mTlinants from soil to
groundWater, which would result in unacceptable levels in groundwater.
.
Treatment of water extracted during construction dewatering will reduce the
toxicity of the water prior to discharge.
.
Backfi11ing with clean materials will allow future unrestricted use of the site.
B. The Selected Remedy Attains ARAR.s
The selected remedy will attain all of the substantive, non-procedural requiremems of federal
and state ARARs. ARARs for Site 34 are set forth in Table 11 of Appendix A to this
document which contains a complete list of ~ including the regulatory citation, and a
brief summary of the r~ent, and the action to be taken to attain the requirement. In
SJ<4ROD.TXT
57
09it7,
-------
addition. policies. criteria. and guidelines (to be considere~ or ''TBCs'') will also be considered
during the implementation of the remedial action.
.
Chemical-Specific ARARs.
None
.
Location-Specific ARARs.
Fish and Wildlife Coordination Act (FWCA).
State of New Hampshire Regulations.
.
Action-Specific ARARs.
Hazardous Materials Transportation Act (HMT A).
CWA.
CAA.
State of New Hampshire Regulations.
.
To Be Considered (TBCs) Criteria.
EPA Health Advisories (HAs).
EPA Risk Reference Doses (RIDs).
EPA Carcinogen Assessment Group Potency Factors.
NH Interim Policy for the Management of. Soils Cont~min~ted From
SpillslReleases of VIrgin Petroleum Products.
The basewide ARARs document (F-530) identifies ARARs for Pease AFB, and Appendix B
identifies those for Site 34, and provides detailed discussions of both ARARs and TBCs. Table
11, in Appendix A of this document, provides a complete list of ARARs and TBC criteria for
Alternative SA, including regulatory citations, requirement synopses, actions to be taken to
attain the requirements, and determinations as to whether the requirements represent ARARs
or TBCs criteria.
S34ROD.1XT
58
O9I22."JJ
-------
Federal and State Drinking Water Regulations. Although not an ARAR, Federal and State
Drinking Water Standards were used in the development of soil cleanup goals based on
leaching. The drinking water standards were entered intO a leaching model to estimate soil
concentrations which would not cause groundwater to exceed the drinking water ARARs.
Drinking water standards, MCLs and other guidance and criteria to be considered (TBCs) were
also used to develop of target cleanup levels for the remediation of groundwater extracted
during constrUction dewatering at the site.
Chemical-specific ARARs and risk-based target cleanup levels will be met by extraCting the
cont~m;na.ted groundwater within the area of excavation, reducing the potential for leaching.
Federal and State Pretreatment Standards. The preferred option is discharge of treated
water to the base POTW. Under this option, discharge' limits would be based on factors
regulated by the POTW's existing NPDES permit, pretreatment regulations, and water pollution
control laws.
Pretreatment standards would be developed with the POTW.
Both the
Pretreatment Standards and CW A NPDES will be attained upon successful establishment of
p~tleatment standards for discharge from the groundwater treatment plant.
Federal and State Air Quality Regulations. The treatment technologies proposed in the
selected remedy will not create any new sources of air emissions. Therefore, many federal anc:i
state regulations governing air quality do not apply to the selected remedy. The only air
quality standards that are applicable are particulate standards promulgated under the Clean Air
Act and New Hampshire Ambient Air Quality Standards. The.particulate standard would apply
to remedial construetion activities. These standards would be attained through monitoring and,
if necessary, use of dust suppression techniques or engineering controls.
S34ROD.TXT
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09117193
~
-.- -.- -... -...~--~--- .
-------
It :oted that, although the requirementS, Standards and regulations of the Occupational Safety
anci Health Act of 1970, 29 U.S.C., ~ sec. 2.!e not ARARs, they will be follewed throughout
the Site 34 remedial activities where necess. See 55 Federal Register 86.9-80, March 8,
1990.
It is also noted that the following New Hampshire requirements and guidanc~, classified as
TBCs, will be followed: NH Administrative Code, Env-Ws 411, Control of Underground
Sto~e Facti,. . ';5: NH Admini~tive Code, Env-Ws 412, Reporting and Remediation of Oil
Discharges; and NH Interim Policy for the Management of Soils Cont~minated from
SpillslReleases of Virgin F -;leum F ~.:lcts.' 'se state requirements and guidance are TBCs
because they re-.~ to the ::: ..1-Up c :roleuL. :.:roducts which are not h.a:.ious substance~
]S defined by C=:?-CLA. However, since the soil to be remedia!ed at Sii: 4 contains such
?etroleum productS, the Air Force wnJ follow the requirements as appropriate.
c. The Selected Remedial Action is Cost Effe~tive
In the judgment of the Air Force, the selected remedy is cost effective (i.e., the remedy affords
overall effectiveness proportional to ~-:... ':sts). Once alternatives that were protective of human
health ax: '.he envi:::unent and tl:. .ller attain or, as app~opriate, waive ARARs were
identified, the overall effectiveness of each alternative was evaluated by assessing the relevant
three criteria: long-term effectiveness and permanence, reduction in TMV of cont~minan~
through treatment, and short-term effectiveness. The relationship of the overall effectiveness
of this remedial alteIrtative was determined to be proportional to its costs.
A snmmary of the costs associated with each of the somce comrol remedies is presented as
follows. All costs are presented in net present-worth costs.
534.
xr
60
09117.-13
.~ .--. - . -
_. - 0. ----.-.--- ..
-------
Present-
Capital 3D-Year Present-Wonh Worth
Remedial Alternative Cost O&M Cost Cost
1. No AcUonlInstitutional Controls $8.300 S358,700 $367,000
2A. In Situ Soil Aerobic Biological
Treatment with SVE, and On-Site
Groundwater Extraction and $ 1 ,669,200 $864,600 $2,534,000
Treatment with On- and Off-Site
Disposal
3A. Excavation and On-Site Ex Situ
Biologica1lVapor Extraction
Treatment of Contaminated Soil and $1,265,600 $469,200 $1,735,000
On-Site Disposal. and On-Site
Groundwater Treatment "and Off-Site
Disposal for Excavation Dewatering
4. Excavation and On-Site Thermal All O&.M costs have been
Desorption of Contaminated Soil and incorporated into the
On-Site Disposal. and On-Site $3,512,000 estimated capital cost $3,512.000
Groundwater Treatment and Off-Site because of the short
Disposal for Excavation Dewatering duration of the remedial
action.
SA. Excavation and Off-Site Treatment All OctM COStS bave been
and/or Disposal of ContaminMM Soil. incorporattd into the
and On-Site Groundwater Treaancnt $1.614.000 estimated capital cost $1.614,000
and Off-Site Disposal for Excavation because of the short
Dewatering duration of the remedial
action.
Of the aforementioned alternatives, four attain ARARs and are protective: Alternatives 2A,
3~ 4, and SA. Alternative SA is the most cost-effective alternative overall, and provides a
degree of protectiveness proportional to its cost. Alternative 3A is 7.S% more costly than SA
and does provide slightly more protection ~o human health and the environment; however, this
additional protection is not necessary since the risk to human health and the environment at the
JETC is acceptable under both alternatives.
Alternative SA provides greater short-term effectiveness at a lower cost than Alternative 3A
or 4. Alternative SA provides equal or greater long-term effectiveness, reduction in TMV
(dependant upon final treatment/disposal chosen at the time of remedial design),
implementability, and compliance with ARARs and TBC criteria as Alternatives 2A, 3A, and
4, but at a lower cost. The costs for Alternatives 3A and SA were very nearly the same;
SJ.4ROD.1XT
61
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however, the time until remediation is completed is very different. Alternative 3A would
require approximately 2 years, while Alternative SA would most likely not require more than
6 months. Continuous pumping of the water-bearing zone at the high rates required for
Alternative 2A could adversely affect wetlands in the area by inhibiting groundwater recharge
of the wetlands. Alternative 1 (no action) does not meet ARARs and would not provide any
additional protection of human health and environment. A summary of costs for key elements
of the selected source control remedy (Alternative SA) is presented as follows. All costs are
net present-worth.
I Component of Remedy I Present-Worth I
Cost
Upgrade of existing groundwater extraction and treatment systems $73,056
One year of O&M of groundwater extraction and treatment systems $111,351
Drainage and erosion controls $12,466
Staging area for stockpiling and treatment of contaminated soil $42,000
Excavation and removal of four USTs and JETC drainpipe $13,300
Soil excavation and stockpiling $203,450
Off-site treatment/disposal of soil $524,300
Backfilling and site restoration $84,625
Miscellaneous $104.750
TOTAL $1,169,298
Miscellaneous includes mobilization/demobilization, access restrictions, health and safety, air
monitoring, and SARA review upon completion. Contingency costs and additions and O&M
costs are not listed as they are in the table on the previous page.
D. The Selected Remedy Uses Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
Once the Air Force identified those alternatives that attain or, as appropriate, waive ARARs
and that are protective of human health and the environment, the Air Force identified which
SJ.4ROD.TXT
62
091'07,")]
-------
altet:n.arive uses permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination was made by determining
which alternative provides the best balance of tradeoffs among alternatives in terms of the
following issues: .c I). long-term effectiveness and permanence; (2) reduction in TMV of
contaminants through-treatment; (3) short-term effectiveness; (4) implementability; and (5) cost.
The balancing test emphasized long-term effectiveness. and permanence and the reduction in .
TMV through treatmen~ and considered the preference for treatment as a principal elemen~
the bias against off-site land disposal of untreated waste, and community and state acceptance.
The selected remedy provides the best balance of tradeoffs among the alternatives.
Alternative SA slightly outranks Alternatives 2A, 3A, and 4 in terms of permanence; however,
all four action alternatives (Alternatives ~ 3A, 4, and SA) have equal rank in long-term
effectiveness. In addition, Alternatives 2A, 3A, and 4 place greater emphasis on treatmen~ but
exceed the cost of Alternative SA by 57%, 7.5%, and 117.5%, respectively, and do not reduce
the TMV of contaminants any more than would Alternative SA, which would most likely
involve resource recovery/reuse technologies. Alternatives 2A, 3A, 4, and SA involve some
upgrades to the Site 34 GWTP that may be incorporated in to the Zone 3 groundwater
remediation and as such possibly serve in both capacities. All four action alternatives would
result in some adverse impact on wetlands, with Al~ve SA creating less impact because
of a shorter time of remediation and less time until restoration occurs. Alternative 1 contains
no provision for reduction in TMV of contaminants or for consideration of EP A's preference
for treatment as a component of remediation.
SJ.4ROD.'TXT
63
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E. The Selected Remedy and the Preference for Treatment that Permanently and
Significantly Reduces the Toxicity, Mobility, or Volume of the Hazardous
Substances as a Principal Element
The selected remedy may not satisfy the statutory preference for treatment which permanently
and significantly reduces the toxicity, mobility or volume of hazardous substances as a
principal element depending on the treatment and/or disposal method chosen at the time of
implementation. The selected remedy is consistent with EP A's preference for containment of
wastes which it is not practicable to treat.
The principal element of the selected source control remedy is off-site treatment/disposal of
source area soil. 1bis element addresses the primary threat at the site (contamination of
groundwater resulting from l~~hing of source area soils), and complies with the NHDES
Policy on Virgin Petroleum Products (F-338). The method of disposal or treatment of the
excavated soils will be determined. during the remedial design phase. The determination will
reflect the requirement ofCERCLA.'120(b)(1) that states "Remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity or mobility hazardous
substances, pollutants or conrnminants is a principal element, are to be preferred over remedial
alternatives not involving such treatment".
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
The Air Force presented a Proposed Plan (Alternative SA) for remediation of the site in
December 1992. The source control portion of the preferred alternative included:
.
Excavation of contmninl'ltP-d, soil and transport to an approved off-site treatment/
disposal facility. It is expected that approximately 5,350 ydJ of contaminated
soils would be excavated. Soil samples would be collected and analyzed as the
operation concluded to ensure all soil above the cleanup goals was removed.
.
Dewatering of the site during soil excavation and treatment of the extracted
groundwater at the existing on-site treatment facility, with subsequent discharge
to the base sanitary sewer.
SJ4ROD.1XT
64
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.
Backfilling of the excavation with excavated soil not requiring treatment or
clean soil.
.
Environmental monitoring during remedial operations.
.
Removal of the re!TI~ining USTs and piping from the manhole to the Test Cell
Ditch. This tank cluster and any retrl~;ning piping at the site will require
removal incidental to excavation of the surrounding cont~m;n~ted soil.
There have been no significant changes in the selected alternative since publication of the Draft
Final Site 34 FS Report and Proposed Plan other than the removal of the JP-4 tank and the
oil/water separator in fall 1992.
It should be noted that several regulations have been updated and some are now enforceable,
where they were not previously. Appendix B presents Subsection 2.2 of the Draft Final Site
34 FS Report. Regulatory updates, as of the signing of this ROD, have been added to the
appendix.
xm. STATE ROLE
NHDES, as a party to the FFA, has reviewed the various alternatives and has indicated its
support for the selected remedy. The state bas also reviewed the Site 34 RI, BRA, and FS to
determine whether the selected remedy is in compliance with ARARs. The State of New
Hampshire concurs with the selected source control remedy for the JETC. A copy of the
, '
Declaration of Concurrence is attached as Appendix C.
SJ4ROD.TXT
6S
09114/93
\
/
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F-44
F-75
F-123
F-142
F-257
F-260
F-299
F-338
F-382
F-450
F-453
F-455
SJ.4ROD.REF
REFERL~CES
ATSDR (Agency for Toxic Substances and Disease Registry). 1991. Toxicological
Profile for Endosulfan. Endosulfan Alpha. Endosulfan Beta, and Endosulfan Sulfate.
Prepared' by Clement Associates, Inc.
CH:M Hill. 1984. Installation Restoration Program Records Search for Pease AFB,
NH.
ENVIROF ATE. 1992.
Protection Agency.
On-line computerized database.
U.S. Environmental
EPA (U.S. Environmental Protection Agency). 1986. Superfund Public Health
Evaluation Manual. Office of Emergency and Remedial Response. EPA 540.1-
86/060.
Howard, P.H. 1989. Handbook of Environmental Fate and Exposure Data for
Orgc ..: - Chemicals, Vol. L Large Production and Priority Pollutants. Lewis
Pub~~;;s, Chelsea, ~n.
HSDB (Hazardous Substances Data Bank). 1992. Computerized Database. On-
Line. National Library of Me 'ine. Toxicology Data Network, Washington, [:.
Little, A.D ~c. E ;;9. The ':allation Restoration Program Toxicology Guide.
Volumes 1 .Jough 4. Oak Ridge National Laboratory.
NHDES (New Ha.":'.'Jshire Department of Environmental Services). 1989. Policy for
Management of '.S Contamin- . from Spillsl-:: ~leases of Virgin Petroleum
Products. Multir:.. .:. Oil Cont~rr .cjon Task Forc;;:.
Schnoor, J.L., C. Sato, D. McKenchie, and D. Sahoo. 1987. "Processes,
Coefficients, and Models for Simulating Toxic Organics and Heavy Metals in Surface
Waters." Prepared for Environmental Research Laboratory. U.S. Environmental
Protection Agency. Athens, GA. EPN600/3-87/015.
WESTON (Roy F. Weston, Inc.). 1987. Installation Restoration Program Stage 2
Quality Assurance Project Plan, Pease AFB, NH.
WESTON fRoy F. Weston, Inc.). 1988. Interim Techni:::!ll Report No.2 for the
Installatio. Zestoration Program, Stage 2. Pease AFB, NI-I. August 1988.
WESTON (Roy F. Weston, Inc.). 1989. Installation Restoration Program. Stage 2
Draft Final Report, Pease AFB. NH.
66
09ta7193
-------
F-456
F-482
F-499
F-504
F-530
F-546
SJ.4ROD.REF
REFERENCES
(Continued)
WESTON (Roy F. Westo~ Inc.). 1989. Installation Restoration Program, Stage 3
Quality Assurance Project Plan, Pease AFB, NH.
WESTON (Roy F. Westo~ Inc.). 1991. Installation Restoration Program, Stage 3C
Site Characterization Summary, IRP Site 34, Pease AFB, NH. July 1991.
WESTON (Roy F. Westo~ Inc.). 1992. Installation Restoration Program Stage 3C.
Jet Engine Test Cell - Site 34 Source Area Remedi~l Investigation. Pease AFB,
NH. November 1992, Draft Final.
WESTON (Roy F. Westo~ Inc.). 1992. Installation Restoration Program Stage 3C,
Site 34 Feasibiliry Study, Pease AFB, NH. May 1992. Draft.
WESTON (Roy F. Westo~ Inc.). 1993. Installation Restoration Program, Stage 4,
Basewide A}URs, Pease AFB, NH. January 1993. .
WESTON (Roy F. Westo~ Inc.). 1993. Installation Restoration Program, Stage 4,
Zone 3 Remedial Investigation Report, Pease AFB, NH. April 1993.
67
-------
AAL
AFB
AFCEE/ESB
ARARs
ATSDR
AWQC
BAT
BCT
BDAT
BGS
BMPs
BRA
BTEX
CAA
CFR
CO
CTVs
CWA
CZMA
DCE
DEQPPM
DNAPL
DOD
DOT
DRE
DRED
EPA
ESA
FFA
FS .
ft MSL
FWCA
FWQC
gpm
GRS
GT
GWTP
HA
HC
HCl
ill
HMTA
HQ AFBDA
HSDB
IRM
S34ROD.ACR.
~_._. -~_._.-.
UST OF ACRONYMS
ambient air limit
"~ase Air Force Base
.ir Force Center for Environmental ExcellenceIBase .vsure Division
Applicable or Relevant and Appropriate Requirements
Agency for Toxic Substances and Disease Registry
Ambient Water Quality Criteria
best available technology
best conventional technology
best demonstrated available technology
below ground surface
Best Manageme::: Practices
Baseline Risk AŁSeSsment
benze""~, tolue: . ethylbenze: and xylene
Cleal- Jr Ac:
Code of Federal Regulations
carbon monoxide
Critical Toxicity Values
Clean Water Act
Coastal Zone Management Act
dichloroethene
Defense Environmental Quality Program Policy Memorandum
dense, nonaqueous-phase liquid
Department of Defense
Department of ':1SpOrtatton
destruction ane. ~ova1 efficiency
Department of K~~Ources and Economic Development
U.S. Environmental Protection Agency
Endangered Spdes Act
Federal Facilities Agreement
Feasibility Study
feet above mean sea level
Fish and Wlldlife Coordination Act
F ederal Water Quality Criteria
gallons per minute
groundwater remediation system
Glacial Till .
groundwater treatment plant
Health Advisory
hydrocarbons
hydrc;en chloride
hazard index
Hazardous Materials Transportatic:. Act
Headquarters Air Foree Base Disposal Agency
Hazardous Substances Data Bank
Interim Remedial Measure
68
----_., -
-------
IRP
ISIP A
ITR
JETC
LDRs
LNAPL
LS
MCL
MCLG
MCS
MTBE
NAAQS
NESHAP
NHCAR
NHDES
NHDPHS
NHPA
N02
NPDES
NPDWS
NPL
NSDWS
NSPS
O&M
03
OSHA
PARs
Pb
PCBs
PCSs
PDA
PELs
POHC
POTW
PPE
RA
RCRA
RID
RI/FS
RME
ROD
RQD
RSA
SCS
S34ROD.ACR.
LIST OF ACRONThIS
(Continued)
Installation Restoration Program
Industrial ShoplParking Apron
. Interim Technical Report
Jet Engine Test Cell
land disposal restrictions
light, nonaqueous-phase liquid
Lower Sand
Maximum Contaminant Level
Maximum Contaminant Level Goal
Marine Clay and Silt
methyl tert-butyl ether
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air Pollutants
New Hampshire Code of Administrative Rules
New Hampshire Department of Environmental Services
. New Hampshire Division of Public Health and Services
National Historic Preservation Act
nitrogen dioxide
National Pollutant Discharge Elimination System
National Primary Drinking Water Standards
National Priority List
National Secondary Drinking Water Standards
New Source Performance Standards
operation and maintenance
Ozone
Occupational Safety and Health Act
polynuclear aromatic hydrocarbons
Lead
polychlorinated biphenyls
potential groundwater contamination sources
Pease Development Authority
Permissible Exposure Limits
principal organic hazardous constituent
publicly owned treatment works
personal protective equipment
Risk Assessment
Resource Conservation and Recovery Act
reference dose
Remedial Investigation/Feasibility Study
reasonable maximally exposed individual
Record of Decision
rock quality determination
Revised Statutes, Annotated
Site Characterization Summary
69
-------
LIST OF ACRONYMS
(Continued)
SDWA
SMCL
S02
SVE
TBC
TCE
TCFM
TI.1V
TPHs
TRC
TSCA
TSD
VIC
US
UST
WHP As
Safe Drinking Water Act
Secondary Maximwn Contaminant Level
. sulfur dioxide
soil vapor extraction
to be considered
trichloroethene
trichlorofluoromethane
toxicity, mobility, or volume
total petroleum hydrocarbons
Technical Review Committee
Toxic Substances Control Act
treatment, storage, and disposal
underground injection control
Upper Sand
underground storage tank
wellhead protection areas
SJ4R.OD.ACR
70
rtMnl'n
-------
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APPENDIX A
..
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- TABLES
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-------
Date
10/87 -12/87
3/88-4/88
9/88-10/88
11/88-12/88
11/88
5/89
5/89
9/89
6/90
6/90
7/90
" '. ...- -
9/90, .
9/90
10/90
S34ROD.Al'A
. Activity
Soil-gas survey
Soil boring 'prognun
I~.
Dedrock well installation
and development
Round I groundwater
sampling
Round I surface,
water/sediment sampling
Round 2 surface water
sampling
Round ~ ~roundwater
sampling
CoUect effluent discharge
sample
Bedrock weU installation
and development.
Wetlands delineation
Hydraulic testing.. , " '..1;
.. ". ,...' .
..
SolVSedimellt Removal..
IRM
Test pit excavation
Rounds I and 3
groundwater sampling
Table 1
Summary of Stag~ 2 nnd 3 Activities
Site 34, pease AFB, NIl
, Scope
Around Duilding 222 based on a 100- by 100-foot grid.
Soil borings 753 through 756, 720, IPld 78t. rlacement
based on previous soil-gas survey. '" ,
Monitor well 617. '
,.
Monitor well () 17.
'.
. .
i ,:.. ~ '
., ,
Staff gage 806 (Ttrst Cell Pitch).
Staff gage 806 (Test Cell Ditch).
"
Monitor well 617.
"
Evaluate discharge to Test Cell Ditch from the JETC.
-
Potential recovef)' wells 634 and 635.
. it . \'. " ,", /
In and adjacent to JETC. .
Wells ~ 17 \ 634, aqd 635.
"
. f ~',.. i .' : I ,,'
.. '...
" ...'
..
.. .
Test Gell Pitch.
.'.,',1
.
Eleven test pits: 987 through 997.
.'
. '
. ,.
. ,
Round I groundwater sampling fOf wells 634 and 635,
and Round 3 for well 617.
.L'''; 'ai, i
A-I
Purpose
Evaluate soil for presence of VOCs.
Evaluate soils in areas of elevated VOCs based on
soil-gas survey.
Evaluate bedrock water-bearing unit beneath the
site.
Evaluate groundwater for VOCs, SVOCs, metals,
and inorganics.
Evaluate surface water/sediment for VOCs,
SVOCs, TPlls, cyanide, and metals..
Evaluate surface water for VOCs, SVOCs, TPlls,
cyanide, and metals..
Evaluate groundwater for VOCs, SVOCs, metals,
and inorganlcs..
Analyze discharge sample.
Installed for possible use as recovery wells for
groundwater treatment plant.
Identify wetlands areas.
Select wells suitable for groundwater recovery
system.
Remoye ~olltaminated soil/sediment from Test Cell
Ditch.
Soil analyzed for VOCs, SVOCs, TPIIs, and
cyanide.b
Evaluate groundwater for VOCs, SVOCs, TI'Hs,
metals, and total cyanide. b
-------
':::.J
j .'
~ I
;1,.
"
.i
I
~/91
Date
5/91-7/91
'.'. t
6/~1
I
. .
6/91-9/91
7/91-9/91
7/91-12/91
9/91
9/91-10/91
9/91 and 1/92
.' :::, ~
10/91." .
. -.-
. . ..... -,'
10/91
I
Installation of pilot GWTP Site 34 ~ro~n~wq.er fecovery system (wells 634 nnd
635). ...' '. . . , .
Seismic refraction. very low-frequency ~Iectromagnetic,
electrical earth r(:sistivity, and terrain conductivity
surveys in JETC' lU'ea. '.. 'i,,'
Southern Ditch: ~043 a~~ 8042. ., ~pper Ne\\ifields
Pitch: 8045 IUld 8044,\ "'1 " .: I.~~.. I I.. d, , ;
Fifty-four boreholes: 7153 through 7179, 7131 through
7 I 85, 7 I 87 througl1 7196, 7200 tl1rougl1 7203, 7216,
7217, and 7240 through 7245.
. Five overb"rdcl1 'wells; 59 Hi, ~Q~ I, S()27, 5028, IU1d
5029.
Twelv~ bedrock well~:' 6009, 6.010, (Jun, 6015 through
6020, and 6038 through 6040. One hybrid well: 6041.
Two bedrock groundwater recovery wells: 634 and 635.
I ;
, .
Activity
Surf~ce geophysical
surveys
" " ~ i I J
Surface waJer/sediment
sampling' "".' '! ,'."
Soli boring/sampling
program ,
., :
Overburden well" .
installation' ,
Dedrock well installation
I,'
Qualitative long-term
pumping test
Surface water/sediment
sampling
Rounds 4 and 5
groundwater sampling
Long-term pumping test
... "" .,"
Sediment sampling
" I
Table 1
1..\' I.
. ... 1\
S~mmary of ~fage ~ pnd 3 Activities
Site 34, reas~ AFD, NH
(Co~Uqucd)
Scope
Test Cell Pitch: 806, 8063, 8()65, I1l1d 8067 thro"gh
8071. Upper Newfields Ditch: 8064 and 8066.
Twelve bedrock wells,S overburden wells, I'fld , hybrid
well." .,. " . ...;,:
One bedrock groundwater recovery well: 634.
." ,
Six sediment samp:I~~:, 8~~3 Ihr~~~h ~~8~,
./
.1."
,.
'Analysis methods per the Stage 2 QAPP (F-4S0).
It Analysis methods per the Stage 3 QAPP (F-456). .
S34ROD' -.
,i,.i;,I'I!;' j
p ..
I
Purpose
~ecovcr and treat contaminated groundwatcr from
water-bearing unit beneath Site 34.
Map bedrock surface and structure.
Evaluate surface water/sediment in Upper
Newfields and Southern Ditchcs.b
Use borings to characterize soil contamination, to
provide stratigraphic information, and to obtain
risk assessment samples.b '
Evaluate overburden groundwater quality.
Evaluate shallow and deep bedrock groundwater
quality.
Initial evaluation of water-bearing unit
characteristics.
Evaluate Upper Newficlds Ditch, and cvaluate
western and eastern ends of Test Cell Ditch.b
Evaluate groundwater for VOCs, SVOCs, TPHs,
metals, and total cyanide. b
Quantitative evaluation of water-bearing unit
characteristics.
Evaluate effect of ditch overflow on wetlands
soils."
-------
... -.... '- .... --.--.... _. - + ._--- .-- ..-.-.. .
Table 2
Chemicals of Concern in Soil (0 to 2 feet).
Site 34, pease AFB, NH
Range of Range of Upper 95%
Sample Averaged Confidence
Quantitation (Detected) Mean Limit of the
Frequency of Limits Concentrations~ Concentration d Mean
Chemical Detectionb (mglkg) (mglkg) (mglkg) (mglkg)
Organics
Benzoic acid 2/5 1.7-1.8 0.051-0.17 0.56' 0.96"
Dibenzofuran 1/5 0.33-0.36 0.040 0.15' 0.20'
Diethyl phthalate: 1/5 0.33-0.36 0.043 0.15' 0.20'
Dimethyl phthalate 1/5 0.33-0.36 0.048 0.15' 0.20'
Ethylbenzene 1/10 0.005-0.006 21 2.1 6.0
n-Nitrosodiphenylamine 1/5 0.33-0.36 0.045 0.15' 0.20'
PARs
. Anthracene 1/5 0.34-0.38 0.20 0.18 0.19
.. Bc:nzo(a)anthracene- - .. 4/5 ..... 0.36 0.060-1.9 0.51 1.3 -
. .., Benzo(a)pyrene -- - - 4/5' -" 0.36 0.051-1.6 0.44 '1.1
".
Benz.o(b )fluoranthene 4/5 - .. 0.36 0.055-1.5 0.44 1.0
Benzo(g,h.i)perylene 3/5 0.36 0.10-0.95 0.30 0.65
BCDZD(k)f1uoranthene 4/5 0.36 0.052-1.8 0.49 1.2
Chrysene '. 4/5 0.36 0.079-2.1 0.56 1.4
- - Fluoranthene 4/5 0.36 0.15-3.4 0.90 " 2.2 "
Indeno( 1 .2.3-cd)pyrene 3/5 0.36 0.092-1.1 0.33 0.74
Phenanthrene 4/5 0.36 0.044-0.85 0.26 0.58
Py1'ene 4/5 0.36 0.083-1.6 0.47 1.1
Pen~orophenol 1/5 1.7-1.9 0.090 0.74' 1.1'
Xylenes (total) .. 1/10 0.005-0.006 36 3.6 10
lnorganics
Barium 7/8 19 P-338 91 161
Lead 7/8 22 7-149 48 78
8'J11e listed chemicals were selected as chemicals for both the human health and ecological risk as~c;ments.
~umber of sampling locations at which the chemical was detected compared with the total number of sampling
locations.
"'The range of averaged concentrations was the same as the range of detected concentrations.
. Arithmetic mean.
-Exceeds the maximum detected/averaged concentration.
SJ.4ROD.AJ'A
A-3
-------
Table 3
Chemicals of Concern in Soil (0 to 15 feet)-
Site 34, Pease AFB, NH
Range of Upper 95%
Sample Range of Avenlged Confidence
Quantitation (Detected) Mean Litnit of the
Frequency of Limits Concentrations" Conccntration4 Mean
Chemical Dctcctionb (mglkg) (mglkg) (mglkg) (mglkg)
Organics
Bem=e 3/36 0.005-5.0 0.035(0.004)-0.36(0.16) 0.14 0.22
Benzoic acid 2120 0.58-19 0.43(0.051)-0.56(0.17) 1.5' 2.18
2-Butanone 3/35 0.005-7.3 0.006-3.0(9.0) 0.33 0.51
Dibcnzofuran 4120 0.32-3.8 0.12(0.040)-0.41 024 0.31
Diethyl ether 5/36 0.005-2.8 0.003(0.001)-12(2.4) 0.48 0.83
Di-n-butyl phthalate 4120 0.32-3.8 0.037-0.092 0298 0.418
Ethylbcnzme 8/36 0.005-0.74 1.5(0.018)-28 2.3 3.9
2-Methylnaphthalene 9120 0.32-0.41 0.14(0.59)-11 1.3 2.4
Naphthalene 6120 0.32-0.41 0.14-7.6 1.1 1.9
PAHs
° 0Ac:cnaphthenc -3120 -- 0.32-3.8 0.17-028 . 023 0.30' .-
- AntbnK:cne .' .' _. '. 0'- 9120 . 0.32-0.42 0.038-1.9 0.31 0.47
Bcnzo(a)anthracene 11120 0.32-0.42 0.047-1.9 0.37 0.54
Bcnzo(a)pyreDe 11120 0.32-0.42 0.049(0.047)-1.9 0.31 0.47
Benzo(b )fluoranthene 10120 0.32-1.9 0.062(0.055)-1.9 0.35 0.51
Bcnz.o(g,h.i)pcrylene 7120 0.32-3.8 ° 0.042-0.57(0.95) 023 - 0.31
Bcnzo(k)fluoranthene 11120 0.32-0.42 0.055(0.040)-1.9 0.31 0.48
Cbrysene.. . -" .0. 11120 0.32-0.42 0.062-1.9(2.1} - 0.37 0.54
Dibcnzo(a,h)anthracene 2120 0.32-3.8 0.059-0.14 0268 0.z3S' °
Fluoranthene 12120 0.32-0.41 0.061-2.4(3.4) 0.58 0.85.
Fluorene 4119 0.32-0.42 017-1.9 0.32 0.47
Indeno( 1 ,2.3-cd)pyrene 7120 0.32-3.8 0.037-o.6S(1.l} 023 0.31
Phenanthrene 11120 0.32-0.41 0.11(0.044)-3.1 0.56 0.86
Pyrenc 12120 0.32-0.41 0.060-2.3 0.43 0.62 -
Toluene 4/36 0.005-5.0 0.14(0.002)-4.9 027 0.51 ..
Xylencs (total) 8/33 0.005-0.74 5.0(0.025)-140 10 18
/norganics
Antimony 3/11 13-21 14.4(10.8)-20.7 11 14
Arsenic 14/14 1.0r 4.1 (2.0)-34.0 12 15
Barium 13/14 22 12-202 50 73
Chromium 13/14 4.0r 6.0(4.9)-63.5(72.3) 21 29
S34tt.OD.APA
A-4
ocm7.9)
-------
Table 3
Chemicals of Concern in Soil (0 to 15 feet).
Site 34, Pease AFB, NH
(Continued)
Range of Upper 95%
Sample Range of Averaged Confidence
Quantitation (Detected) Mean Limit of the
Frequency of Limits Concentrations~ Concentrationd Mean
Chemical Detectionb (mg/kg) (mglkg) (mglkg) (mglkg)
Inorganics (continued)
Lead 12/14 20-21 6.9(3.1)-100(149) 24 36
Nickel 14/14 5.0r 7.8(6.1 )-70.7(91.4) 21 29
'The listed chemicals were selected as chemicals of concern for both the human health and ecological risk assessments.
~umber of sampling locations at which the chemical was detected compared with the total number of sampling
locations.
CZf the minimum or maximum detected concentration differed &om the respective minimum or maximum averaged
concentratio~ the detected. concentration is given in parentheses. .
d Arithmetic mean. - ., - .
~ceeds the maximum detected and/or averaged concentrations.
(Sample quantitation limits were unavailable. Method detection limit is indicated.
S34RDD.APA
A-S
.- .
-------
Table 4
Summary of Total Lifetime Cancer Risks and Hazard Indices
Site 34, Pease AFB, NH
Total Lifetime Cancer Risk"" Total Hazard Index~
Upper 95% Upper 95%
Confidence Confidence
Medium RME Mean Limit Maximum Mean Limit Maximum
Soil Current 8E-07 2E-06 3E-06 IE-03 2E'{)3 4E-03
(0 to 2 feet) maintenance
worker
Future 4E-06 IE-05 2E-05 7E-03 IE.{)2 2E-02
maintenance ..
worker
Soil Future 3E-06 5E-06 2E-05 I E-02 2E.{)2 5E-02
(0 to 15 feet) maintenance
worker
"Values.. are rounded to one: significant number. .. -. .
"Maximum cancer risk at hazardous waste sites is usually regulated in the range of lE-06 to lE-04 (10.0 to
10~). Risks ofless than lE-06 (10.0) are generally not considered to be of concern. . .' -.
cA hazard index of 1 (lE+OO) or greater is usually considered the benchmark of potential concern.. "-""...
. ~,'. J ...
".. .
. - "'. .«~
S34ROD.APA
A-6
09107193
-------
Table 5
Summary of Detniled Alternatives Evailiutioll8
Site 34, Pease AFD, Nil
Proteclion of
Jluman Jlcallh Compliauce Cosl Analysisb
Short-Tem\ Long-Teoo aluf wilh (scusiliv ily
Effectiveness ErrCCliveness Reduction In TMV Implemenlabilily Envlronmenl ARARs analysis)"
Remedial Allernatlve Ranking Ranking Runklng Ranking Itunk lug Runklng
I. No Actionllnslitulional Controls. All C C A C DC $367,000
2A. In Silu Soli Aerobic Dioloaicol Treulmenl n,SH,IIUO
with SVH, and On-Silo Groundwuler AD AD AD AD AD A ($2,2S2,319 10
Extraclion and Trealmenl wilh On- and $2,944,792)
Off-Sile Disposal
3A. Exeavallon and On-Slle Ex Situ $I,7]S,OOO
UiologicalNapor Extracllon Trealmenl of ($1,662,196 10
Conlaminaled Soil and On-Sile Disposal, D AD AD AD AD A $1,902,248)
and On-Slle Groundwaler Treatmenl and
Off-Slle Disposal for Excavation
Dewalerlng
4. Excavation and On-Sile Thermal $3,Sl2,OOO
Desorption of Contamlnaled Soli and On- ($3,11 S,673 10
Sile Disposal, and On-Sile Groundwaler n AU AU AU AU A $4,27S,1I82)
Trealmenl and Orr-Sile Disposal for
Excavation Dowalerlng
SA. Excavalion and Off-Sile Trealment and/or $1,614,000
Disposal of Conlaminaled Soli, and On- ($\,499,757 10
Sile Groundwater Treatment and Off-Site AU AU AD AU U A $I,1I6I,JS4)
Disposal for Excavation Dewatering
'The leller ranking I)'slem I, described In Subsection 5.3 of Iho Draft Final Site 34 FS Report. Tho ranking worksheel ma)' be found In Appelllllx I of Ihe Drult Flnul Site 34 FS Report.
'Estlmaled costs representlhe 30-year presenl-worth cost. Delalled cosl esllmales arc presenled In Appendix E of Ihe Dral\ Final Sile 34 FS Report.
"The sensillvily IInalysis coslS represent the upper and lower limits of the 50% confidence inlerval.
,.
..
"
...
..
..
.', . .... I ~;u;
.~ I
S34ROI>.APA
A-7
-------
Table 6
Risk-Based Concentrations for Groundwater
Site 34, Pease AFB, NH
Chemical
Based on Noncancer Hazard
Index Based on Cancer Risk
(mgIL) (mgIL)
- 1.41Ł-03
1.46E+02 -
- 6.08E-03
1.83E+OO -
1.62E-O I -
-
1.46E-O 1 -
3.6SE+OO -
2.92E+O I -
3.6SE+02 -
3.6SE+OO -
2.70E+OO -
1.34E-02 -
-
l.34E-02 - ...
"'">
- 8.69E-03
-
-
.'-,
Benzene.
Benzoic acid
Bis(2-ethylhexyl) phthalate
2-Butanone
Chlorobenzene 8
Dibenzofuran
Diethyl ether8
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Ethylbenzene 8
2-Methylnaphthalene.
Napbthalene8 ..
n-Nitrosodiphenyl~ine 8
PARs -
Acenapbthene .'- .,. ---- -_. ....""-
Anthracene-
- . -- 2.19E+OO
l.35E-02
-'
-
_A
..
. - - ---- ~-
-.
-
Benzo(a)anthracene
Benzo(b}fluoranthene
Benzo(k)fluoranthene
Benzo(g.h.i)perylene
Benzo(a)pyrene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
-
I.l1Ł-OS .'
I.l1Ł-OS .:
I.l1Ł-OS
-
-
-
.-
-_. 1.46E+OO
-
.-.
.. --
-
-
1.11Ł-OS
I.l1Ł-OS
1.11Ł-05
-
-
.-
._..
1.46E+OO
1.46E+OO
-'"
-
-
Indeno{ 1 ,2.3-cd)pyrene
Phenanthrene8
Pyrene
Pentachlorophenol
Toluene-
1,1, I-Trichloroethane-
Trichlorofluoromethane -
Xylenes (totalf
-
I.l7E-OS
-
1.34E-02
I.lOE+OO
-
-
-
-
..
"
-
7.IOE-04
'.
.2.6SE+OO
2.53E+OO
4.38E+OO
3.6SE+Ol
-
-
-
-
.Hc:nry's Law constant for the: chemical was grcarcr than lE..04 aIm-mJ/molc (F-ID; F-142; F-2S7; F-260; F-382). Therefore, both
groundwater ingestion and DOIIingc:stion household uses were considered in dctenniniDg !he risIc-bascd collCCDU3tiol1.
S34ROD.APA
A-8
-------
;
Tftblc 7
Selection of Groundwatcr Cleanup Goals for Application of
Leaching Model - Organics in Groundwater
, Sitc 34, Pease AFD, NIl
I
,
Risk-Dased Concentrations
Groundwatcr
NIIDf'JlS Dused on Cleanup Goul
Advisory Ufelime Noncaneer Dased on Seleetcd fur
MClo MClGb level° IIcahh lIuzard& Cancer Risk' teaching Model
Chemical (mgIL) (lI1g/l) (mgll.) Advisory (mg/I.) (mg/I.) (mgll.)
Denzene O.OOS' 0 O.OOS 0.00147 O.OOS
Benzoic acid 28.0' 146.0 28
Dls(2-ethylhexyl) phthalate 0.006' 0 0.006 0.73 0.00608 0.006
2-Dulanona 0.17' 0.2 1.83 0.17
Chlorobenzena 0.1' 0.1 0.1 0.1 0.146 0.1
Dibenzofuran 0.146 0.146
Dlethyl elher 3.6S' 3.6S
Diethyl phlhalate S.O' 29.2 SO
Dimethyl phthalata 36S 36S
m-n-bulyl phthalate 34' 3.6S 34
Ethylbenzene 0.7' 0.7 0.7 0.7 2.7 0.7
2-Methylnaphthalene 0.0134' 0.0134
.. '"
Naphthalene 0.02. 0.02 0.0 \34 0.02
n-Nltrosodiphenylamlne 0.36S 0.00869' 0.00869
t ," ..' ;. \. " .,..' \
PAils
Acenaphthene '.. 2.19' 2.19
, h'
SJ4ROD.APA
A-9
-------
I Ii
"
Tpble 7
'.
~. i
Selection of GrOltndwater «;;Ieanup Goqls' for Application of
Leaching Model - Organics in' Groundwater
! Site 34, Peas~ AFB, Nil
j (Continued)
. .
,
..
'.' I Risk-Dosed Concentrallons
OroundlVulcr
NHDPIIS Dosed on Cleanup Ooal
.' '; .1;'.. Advisory Lifetime Noncnnccr Dosed on Selcclcd for
MCL' MCLQ' Level' IIcallh lIaznuJ4 Cancer Risk' LCI,,;hin8 Model
I , ., Chemical (mgIL) (m8/L) (mgIL) Advisory (mall.) (mg/I.) (mg/I.)
Anthracene 0.0134. 0.0134
Denzo(a)anlluacene 0.0001 p. OP 1.17E-05 0.0001
Benzo(b)l1uoranlhene 0.0002 p. OP I. 1.17E-05 0.0002
. . ,
Benzo(k)l1uoranlhene 0.0002 p. OP 1.171:-05 0.0002
Denzo(g,h,i)perylene ",11 ; 1.46.
1.46
Denzo(a)pyrene 0.0002 p. OP 3.0 t E-06 1.17E-05 0.0002
Chrysenc 0.0002 p. OP 1.17E-05 0.0002
Dibenzo(a,h)lII1lhracene 0.0003 p. OP '/ f/ ~'p' I I 1.17E-05 0.0003
; . J I ~ '. ., J ,
Fluorlll1lhene 1.46. 0.166'
Fluorene 1.46' 1.46
" Indcno( 112,3'cd)pyr~n!l .. O.ooOi r' OP .0 1.17E-05 0.0001
Phenlll1lhrene 0.0134' 0.0134
. ' ~'.
Pyrene I 1.10. 0.135'
.. . .
Penlachlorophenol ; 0.001 p' Of ".0.001 1.10 7.1E-04 0.001
Toluene 1.0. 1.0 1.0 1.0 2.65 1.0
1,1,1- Trichloroethlll1c . 0.2. 0.2 1':0.2 '. 0.2 2.53 0.2
SJ4''''D.4PA
A-10
-------
. .
. ...--....-.--
~ t . .-..
;Ta~le .'
Selection of Groundwater Clean~p ~oals for Application of
Leaching Model - Organics in Groundwater
Site 34, Pease AFD, Nil
(Continued)
i I ,
Rlsk-Dased Concentrallons
: I
i Groundwlicr
i .
: NIIDPIIS Uased on Clcanup Gual
, Advisory Ufellme Noncancer Based on Selecled for
MCL' MCLO~ level. Ueahh UlIZllrd' Clncer Rbk' I.cu~hlnll Model
Chemical (mail) (mail) (mail) Advisory (mail) (mgIL) (mall.)
Trichloronuoromelhane 2.0. 4.38 2.0
Xylene. (Iolal) 10.0. 10.0 . 10.0 10.0 36.5 10.0
'Maximum Conlamlnant Level, March 1991.
~Maxlmum Conlarnlnanl Level Ooal, March 1991. .
'New Hampshire Department of Public lIealth Service., lune 1992. I
'Developed based on noncancer hazard Index of I and \he exposure scenarios discussed In Subsecllon 2.3 of \he Draft Final She 34 FS Report.
'Ucveloped based on 10" cancer risk and tho exposure scenarios discussed In Subsecllon :U of \he DraR final Silo 34 FS Report.
'Thl. value would have been used exceplthe concentration wu above the solubility of \he compound; therefore. the solublilly value was used In \he model.
NlV - No lvallable applicable toxicity value. .
P - Proposed ltandanl.
.Valuo used for modellnpul.
I .
. '.
,
, .
.. .
.-.. ..... ..
..
S34ROD.APA
A-l1
-------
-- ~ ...-..-.---..---_."...n-_. ~~_..__.
Table 8
Selection of Cleanup Goals for Organics in Soil
Site 34, Pease AFB, NH
ARARs
Target Level
Based on Mlximmn
Leaching" Concenlnlion Preliminary
RCRA. New Hampsh~' (Unsazurated) D=ctcd" Oeanup Goal
Organic Chemical (mgllcg) (mglkg) (mgllcg) (mgtkg) (mglkg)
Benzene I.~ 4.1 0.16 J.~
Benzoic acid 55.259 0.17 NA
Bis(2
-------
Table 8
Selection of Cleanup Goals for Organics in Soil
Site 34, Pease AFB, NH
(Continued)
ARARs
Target Level
Based on Maximum
Leaching" Concentralion Preliminary
RCRA. N~ HampshiR:~ (UnsaI1U1ItCd) Detected" Oeanup Goal
Organic Chemical (mglkg) (mglkg) (mglkg) (mglkg) (mglkg)
Phenanthrene: 2.446 3.1 NA
PyTene 111,899 2.3 -- - -. NA
Pentachlorophenol 2.000 118 0.09 NA
Toluene 20,000 1.0"" 2.467 4.9 1.0"
1,1,1- TridlIorodhane 7,000 300 0.6 NA
TrichloroftoW'Omc:IhaDc 3,138 0.002 NA
Xylcncs (tolal) 200,000 1.0"" 26,445 140.0 1.0"
"Soil values 1iom RCRA Corrective Action Levels. 1990.
"State of New Hampshire Interim Policy for the Management of Soils Contamina1cd from SpillslReleases ofVtrgin Petroleum Poi.I:2s. 199L
"Soil con<:cDlr3tion developed from leaching model as discussed ill Subsection 2.4 and Appendix B of tile Draft Final Site 34 FS Report.
~prcsems 1.0 mgllcg tDCa1 B1CX (benzene, toluene, ethylbenzcne. and xylene).
"Maximum as pn:sc:nted ill the Draft FInal Site 34 RI Report.
'Maximum detected conccntralion was not considered to be representative of conditions at the site. All other samples were nondetcct fr ti;
compound.; dlen:forc, no c:lcanup goal was selected.
"Value used to select cleanup goal. if applicable.
NA = Not applicable:. ARARs and risk-based concentrations exo:.ed maximum detected concentrations.
~ROD.APA
A-13
09107/93
-------
Table 9
Cancer Risks and Hazard Indices Calculated
Based on ARARs - Soil
Site 34, Pease AFB, NH
ARAR Hazard Cancer
Chemical (mglkg) Index Risk
Benzene 1.00E+OO - 2.66E-08
Ethylbenzene 1.00E+OO 2.57E-05 -
Toluene 1.00E+OO 1.28E-05 -
Xylene 1.00E+OO 1.28E-06 - -
- -- - .
.# . .._.~.-
. -- .-..
- "---. -
..- ------
--.,-. _. _..
. - - -- - --
"'----'~ ._.
- -....-. ou .'
- - '. ._- - - - "..
- . __no -.' -.- .
- .".---.. ---
- ..
"..- - _.. _...... - .-.-..' ----
A - ... -~. - ... -. ._... .
- -.
0':,
" ,r.... - .." r
. ".- -~-' '"".":,:".
.- 0" ._-
. .. ".. .
. -.
. .
-.: ",",'::. '<
-.'.. .
..
~ . :....
- -
.. ".
....'.
,-
. .. '. .
.."" .
-..
" ,
. -.-.' ..
". ".
. '.. . ~ . .."
J' ,
'-'..
., --,
. ...~. .
SJ4ROD.APA
A-14
-------
"
.,. .
Tpble 10
I
.., . .. . .. '" . .. i. '.
J .
Groundwatn TrfPfl11ent QODhlFQr ~xcqvfttio" Dewatering
. Site 34, Pease AFD, NIl
. , !.
:!
" .
..,. potential ARARs .,
.'
-------
',f" , "
-.j' j'..:
Ii
,. - ~ - .' -
" ...,' '. ".'
I Tnble:l0 - n i
, I I I
Groundwnter Treatment Goats For Excnvntion Dewatering
Site 34, Pease AFB, Nil
(Col!tin~~d)
\
~ ~... j,' ~:' ,
.: '
Potential ARARs '
(ul!/L) Maximum
NIIDPHS . Lifetime Concentration Treatment
Parameter MCL MCLG Advisory, RCRA Healtb Detected Goal
Level : Advisory
2-Melhylnaphlhalene 37 12.4~
Naphthalene 20' 20 110 20
PAils I
Fluorene I J NA
PhenanUuene 2J NA
pentachlorophenol l' 0 I 1,000 6J NA
Phenol 4,000 20,000 4,000 5 J NA
.' ..
N-Propylbenzene 100 NA
Tetrachloroethene S 0 S 0.7 0.4 J NA
Toluene 1,000 1,000 . ,I 1,000 10,000 ,.; 1,000 20 NA
1,2,3- Trlchlorobc'nzcno . !., ' '.' , , I'.. .,". '" .. . , ..
700 1 NA
1,2,4-Trichlorobcnzene 70 70 .. , 9' 700 70 0.5 J NA
I,I,I-Trlchloroethane 200 200 200 3000 200 0.5 J NA
. '
Trlchloroethcne S' 0 S S 32 5
Trlchlorofluoromethane ,r, ,. ., 10,000 2,000 0.2 J NA
,.'
1.2,4-Trlmethylbenzene 590 19.8~
1,3,5- Trimethylbenzene 140 NA
S3411f'f\..trA
A_1 "
-------
Table 10
Groundwater Treatment Goals For Excavation
Site 34, IJease AFD, Nil
(Continued)
Dewatering
Potential ARARs
(1&11/1.) Mu xlIII II III
N 1II>rIlS Urctlmc COllcent ra tion Trcatment
"urumeter MCL MCLG Advisory nCRA HeuUh Uclccicli (;oul
Level Advisory
..
Xylenes (total) 10,000 10,000 10,000 70,000 10,000 1,940 NA
INORGANICS
Alul11ll1um 50 - 200.' 27,000 200
Arsenic 50' 50. 50 50 109 50
Barium 2,000 2,000 2,000 1,000 2,000 349 NA
noron 620 600 283 NA
Cadmium S' 5 5 10 5 8.6 5
Calcium 11 0,000 NA
Chromium 100' 100 100 50 100 56.4 NA
Cobol! 56.7 NA
Iron 300' 47,900 300
Lead 15' 0 15 50 23.1' 15
Magnesium 39,500 NA
Monganese 200 SO" 8,480 50
Mercury 2 2 , ' 2 2 2 0.465 NA
Nickel 100 100 . \ 100 700 100 54.2 NA
Potassium . .1\ , 92,600 NA
S34ROD.APA
A-17
09/07193
-------
f.. " I' .
V. I ~.
Tpbl~ 10
:
I "
Groundwater Treatment (foal$ For Excavation Dewatering
Site 34, Peas~ AFB, Nfl
(Conti~ued)
1
," Potential ~RARs
(lle/L) Maximum
NIIDPIIS Lifetime Concentration Treatment
Parameter MCL MCL(f Advisory ' RCRA Health Detected Gonl
Level Advisory
Silicon 32,600 NA
Sodium 100,000. 110,000 NA
250,000"
'(
Zinc 5,000 2,000 107 NA
NOTES
All values arc In pg/L.
, Only detected parameters arc shown In the table.
'Proposed standlU'd.
~Value reported Is concentration derived from baseline risk jlSsessment for Site 34.
'SDW A or NU SMCL. !
'An estimated concentration (58.4J) for lead was reported for well 6009 from the October 1991 sanlpling round. This concentration Is considered invalid; nondctects for lead were reported In
: a duplicate sample and a subsequent (Janulll')' 1992) sample from well 6009. '." ;
! NA .. Not applicable. Concentrations detected arc beloY{ ARARs and risk-based cpncentratlons, or no toxicity value or ARAR availuble.
I 'Value chosen as treatment 80al. ,'II' ; ; j ,I", ; i
; Maximum concentrations of both total and soluble concentrations. :
1" ii.,j :
"
: '. I. j \ ; . I .. ~ ) . ""
" i,'
" I,
t ~
i I.
, ,"
,I." '" . i,
SH'
,\PA
A- 'Q
-------
Table 11
ARARs for Alternative SA - Excavation and Off-Site Treatment And/Or Disposal of Contaminated
On-Site Groundwater Treatment and Off-Site pisposal for Excavation Ucwatering
Site 34, P~ase AFJI, NIl
Soil, and
Medii Requlremenl Requlremenl Synopsb Ac:llon To De Taken To SI.:]
. .'. Ailliin Rc:qulremenla
Chemlul-Spec:lfic:
;
Soli fEDERAI.-EP A lIeallh Advisories (liAs) IIAa are nonenforceable heahh-based Iiland~lds liAs hllve been considered when "1'11(;
establbhed for various exposuro durilions (I.e., sclecllna BrOulldwllter lIelitmelil
, I-day. IO-day, and lirellmc). levels as presented in Tables 2.S-4
wid 2.5-S of the She 34 FS HeJlort.
Soil fEDERAL.EPA Risk Reference Doses (RIDs) RIDa aro dose levell developed based on the EP A IUDs have been used 10 TUC
nonc:arclnoBenlc: ~ffecls and are used 10 develop characlerlze risks resulting from
hazard Indices. A hl\Zard Index of
-------
Il:
'fpble 11
ARARs for Alternative SA - Excavation and O~f-Site Treatment And/Or Disposal of Contaminated
On-Site Groundwater Treatment and Orf-Site Dlsposul for Excuvutlon I>ewutcring
Site 34, Pease AFD, Nil
(Contin'ued)
Melli.
Wellands
Wellands
,I
Wellands, Rivers
. to) .
SJ4r - ~ APA
Requirement
Wellands Execullve Order (EO 11990)
FEDERAL-CW A 404, Section 404(b)(I)
Ouldellnes for Specification of Disposal Siles for
Dredged or l;iII Malerial 40 CI;R I'urt 230
01 I ,.
"
., J
, ,
'..
FEDERAL.16 USC 661 ct. seq., Fish and
Wildlife Coordlnallon Acl
"
" I
I.
, .
" '
Requlremenl Synop,l,
Under this order, federal agencies ure required
10 minimize the destruclion, 10!iS or degradalion
of wellands, and beneficial values of wetlands.
Conlalns requirements for dischurge of dredge
or fill material, Including thai no discharge Is
pennilled If IIlere Is a practicable allcmativc to
the proposed discharge which would have a less
I adverse impact on Ihe aquatic ecosystem, and
that no discharge permilte4 unless appropriate
and practicable' SICpS arc taJ;en 10 minimize
pO\l:nllal adverse: Impacts I!n the aquatic
, ecosystem. ,...., , .', \... .
""'., ...
..
'.6J'il.
! ", ."". ;',,1;1'"'
"",1 '; t'" ",,-,,", , i.".
. ,..
I.',. I. ;
Reqalres federal agencies 10 take Inlo
conslderlltlon the effecl thaI wlI\l:r-rcialed
projects will have upon fi~h lOll wildlife.
Requires consullation with 1:lsh and Wildlife
Service and !he State to d:velop measures to
prev~~1, 1]I11I$l\le, or colllpensa1C for projecl-
related losse, 10 fish and wildlife.
'. '
I ., 1 ~.~.;
.,'.".:..,-; 1,_,.,
", , 'c,,~ " .:',
I : I . i I' ,,~
A-?O
Action '1'0 Ue '''lIken 1'0
AUain RequlremenlS
The Remediul Action will address
impacts 10 idenlified wetlunds.
Remediul activitics will minlmilc
hann to Ule wetlands to UIC ex lent
possible.
'1111: range of alternatives cvalualed
were those which best mcet IIIC
project purpose of minimlling
Icaching of contaminants from
source area soils into groundwater
and surface waler. All of the
alternatives have similar adverse
Impacts on the Site ]4 wellands.
lIowever, the selected alternative
had the leas! adverse hnpac\.
Remedial activities will be dcsigned
10 minimize potential adverse
affects on IIle aquatic ecosystem.
Any wetlands adversely affccted
will be restored or replaced.
Relevanl federal agencies will be
cuutactc:d to help OIlalyze ellcets of
remediul action on wildlili: In tbe
wetlOllds In and around Sile 34 WId
10 devclup measures 10 prevent,
millgale, and compensale for
adverse Impacts.
Soil, nnd
SIIII:::J
APIJli,;uble
Applkable
Applicable
-------
Table 11
ARARs for Alternative SA - ElCavation and Off-Site Treatment And/Or Disposal of Contaminated
On-Site Groundwater Treatment and Orr-Site Disposal for Excavation Uewatering
Site 34, Pease AFU, Nil
(Continued)
Suil, and
Media Requirement Requirement Synops" ACIIon To De Taken To Sialus
Allilin Requiremenll
Wetlands, Rivers STATE.RSA 48S:A.17 Nfl Admin. Code Env- Establish criteria for conducllng any activlly In Soil excavalion and groundwater Appli~able
Ws 41 S, Ilules Relalive to I'rcvenliun uf or ncar slale surface Wllters which si~nificanlly Ueallutnt will lUeet subSlaulive
I'ollution frolll Dredging. Hlling. Mining. IIltcrs terrain or may otherwise: adversely ulIeet requirements of these NUDES rilles
Transponing, Construcllon waler quality. Impede niliural runolI or create prior 10 initiation of aClivities in !he
unnatural runoff. ACllvitles wi!hin the scope: of wetlands or vicinity of !he Test Cell
!tIese provisions Include exellvlI!lon. drellging, Ditch.
filling, mining and grading of topsoil In or near
wetlwld arellS.
Wetlands, Rivers STATE.RSA 482.A, Nil Admin. Code fnv-Wt Regulate OIlInl and other activltlel In or Proposed work adjacent to !he Applicable
]00, 400, 600, New IIwnpshlre Criteria and adjacent to wetlands, and establish crl1eria for wellands anll Test CellUiteh will
Conditions for Fill and Dredging In Wetlwlds the protection of wetlands from adverse Impacts comply witIJ State wetland
on fish, wildlife, commercl) and public protection requlrelUents:
recreation.
Actlon.SpcdRe
Wllter FEOERAI..CWA 40 CFR PIIrt 403 ErA General luidelines to be followed in Discharge to wastewater treatment Applicable
Prclfeatment Slwldurd establishing prelleahnent efflnent dlschwges plWlt will meet prelreatment
limits for pollulunts that will be dischwged 10 a requirelUents of CW A.
POTW. '
Soils CERCLA OIT.Site Disposal Polley - OSWER This policy requires off.site receiving facility to The olT.site receiving facility will 'ruc
Plrectlve 9834.11, 1111]/87 be In compliance with all permll wid witIJ have to be licensed and In
applicable Uale and federul requirements. compliance wi!h permits and
applicable stale and federal
requirements before /lilY malerial
lium Sile 34 is laken 10 Ihe facilily.
STATE-Nil Admin. Code t:nv-Wm 702.06, General requlremenl for owner or operalor 10 Community relalions plan is being Applicable
Public Notification Plan develop a community relalions plan at the devc:loped.
requesl of NIIDES.
SHROD.APA
A;-21
-------
Table 11
ARARs for AUcrnativc SA - Excavation ~nd Pfr-Site Treatment And/Or Disposal or Contamimttctl
On-Site GrQundwater Treatment ~"4 prf"7Sif~ pisposal for Excavation Dewatering
. Site 34, r~asc AFU, Nil
(Continued)
Suil, nntl
'",
Media RequlremeDI '.' ReIJulrellfenl Synopsl. Action To De TakeD "1'0 Sialu.
Allain Requlremenl'
Solis STATE-Nil Admin. Code Env-Ws 411, Control Establishes requirements for the installalion, The closure of the lJSTs will Applicable
of Underground Siorage Facilities permilllng, tesling, operalion, mainlenance, and comply willi applicabh: scclions of
closure of UST.. Olese regulations.
.-
Soils STATE-Nil Admin. Code fnv-Ws 412, Establishes procedures and requirements for The requirements of Ihis regulalion I\ell:vanl
Reporting and Remediation of Oil Discharges notification, reporting, response actions, and have been used in Ihe development &
Invesligatlons for slles where discharges of oil of Ihe remedial allemalives. Appropriale
have occurred.
Water STATE-Nil Admin. Code Env-WI 904, Establishes pretreatment standards for These regulalions, along with all Applicable
Standards For Pretreatment of Wasles Prior to wastewaterl discharged 10 POTW. Specific pretreatrnent requirements Imposed
Discharge 10 rOTW prohibited wastel arc Iliso Identified. by Ole wastewater \realment planl,
will be met for dlschUlges to Ole
sewer system. Trealment goals for
groundwaler are presented in
Tables 2.5-4 wId 2.5-5 of Ihe Sile
34 FS RepOiI.
Water STATE-Nil Admin. Code Env-Wr 700, Waler Establishes requirements for users of 20,000 1111: groundwaler trealment syslem Applicable
Resources gallons of water or morc over 7-day period or will comply willi Ihc waler use
600,000 gallons In any ]O.day period. 111e requirements.
requirements Include registralion, measuremenl,
and rCllorting.
Air STATE.NII Admin. Code Env-A BOO Testing Identifies procedures that must be followed for During groundwater treahnenl, and Applicable
and Monitoring Procedures lestina of air emissions from slatlonary sourccs. soil excavalions, air emissions will
, be lIIonilored and Ie sled 10 cnsure
O,al Ihese sources do nOI cxceed
applicable s.andwds.
Air STATE.NiI Admin. Code Env-A 1300 Toxic Air Standards established 10 protect the public from Release of conlanlinants 10 IIIC air Applicable
Pollutants concentrations of pollulants in ambient air that from any on-sile remedial aclion
may cause adverse health effects. will nut resnll in cxceedcncc of Ihe
respective Ambient Air L.imit, if
, , (lile exists.
... ."()D.APA
A-22
-------
Table 11
ARARs for Alternative SA - Excavation and Off-Site Treatment And/Or Disposal of Contaminated
On-Site Groundwater Treatment and Off-Site Disposal for Excavation Dewatering
Site 34, Pease AFB, Nil
. (Continued)
Soil, and
Media RequlremeDt Requirement SYDOPIIs AclioD To Be Taken To SllluI
Alliin RtquircmcDII
Air STATE.NII Admin. Code Env-A 300 Amblenl ESlablishes primary and secondary levels for TIlese anlbienl lIir levels will be Applicllble
Air SllIl\IJards eillhl air COliluOIlllllnlS (jlur1lculule lIIuller, sulfur incOIporuled willi fedcrul NAAQ~
dioxide, carbon monoxide, nitrogen dioxide, 10 establish largel levels, lIIat mllY
ozone, hydrocarbons, fluorides, and lead). nol be exceeded In air emissions
from on-slle IIclivilies, Including
soil excuvation IIlId groundwater
trealment Air monilorlng will be
conducled during remcdial
aCllvilies.
Air STATE-Nil Admin. Code Env-1002 fugillve Requires preeaullons 10 prevent, abale, and Precaulions Iu control fugilive dust Applicllble
Dusl Control control fugilivo dusl during speclned IIcllvllles, emissions will be required during
Including excaullon, construclion, wid bulk remedial aClivities. TIlese
hllullng. precaulions will be includcd in
remedial design.
Solis STATE-Nil Guidance Document, lnlerim Policy This policy Idenlilies opllons for trelltment IInd Reljuiremenls will be alillinied via TIIC
for lIIe Manllgement of Soils Conlwnlnaled from disposal, cunenl onalyllclIl melllOds, and excuvalion, olr-sile trealmenl und
SpillsIRelellSes of Virgin Petroleum ProduclS. rc:medilliion gOllls for virgin petroleum- disposlli. Soil cleanup gOllls arc
conramlnlltcd solis. presenled In Table 2.5-1 of Ihe Sile
34 FS Report.
S34ROD.APA
A-23
-------
APPENDIX B
ARARS FOR
PEASE AFB
S34ROD_o\PB
-------
APPENDIX B
ARARs FOR SITE 34
2.2 E:vvIRONMENTAL AND PUBLIC HEALTH APPLICABLE OR RELEV At',TT A.l'VD
APPROPRL~TE REOUIREMEXfS
SARA. and the NCP, revised 8 March 1990 [40 Code of Federal Regulations (CFR) 300],
provide that the development and evaluation of remedial actions under CERCLA must include
a comparison of alternative site responses to federal and state environmental and public health
ARARs. The following subsections present and discuss ARARs and other (0 be considered
(TBC) criteria that may affect remediation at Site 34. A list of A.RARs appropriate to the
preferred alternative selected for detailed evaluation at Site 34 is presented in Table 11, in
Appendix ~.
B
2.2.1 Identification of ARARs
Identification of ARARs must be performed on a site-specific basis. NCP and SARA do not
provide universal standards for determining whether a particular remedial action will produce
an adequate remedy at a particular site. Rather, the process recognizes that each site has
unique characteristics that must be evaluated and compared to those requirements that apply
under the given circumstances. ARARs are defIned as follows:
.
Applicable requirements are those cleanup standards, standards of control, and
other substantive environmental protection requirements, criteri~ or limitations
promulgated under federal, state, or local laws that specifIcally address a
hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance found at a CERCLA site.
.
Relevant and appropriate requirements are those cleanup standards. standards of
control, and other substantive environmental protection requirements, criteria, or
limitations promulgated under federal, state, or local laws that, while not
"applicable" to a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a CERCLA site, address problems or
situations sufficiently similar to those encountered at a CERCLA site.
S34ROD.AP9
B-1
-------
TBC information refers to other federal and state criteria. ad\isories. guidance.
and proposed standards and local ordinances that are not legally binding, bUt that
may provide useful information or recomrne:lded procedures.
A.RAR5 may be divided into the follov.ring categories:
Chemical-soecific reauirementS are health- or risk-based concentration limits or
ranges in various environmental media for specific hazardous substances.
pollutants. or contaminants. These limits may take the form of action levels or
discharge levels.
.
Location-soecific reauirementS are restrictions on activities based on the
characteristics of a site or itS immediate envirorunent. An example is restrictions
on wetlands development.
.
.-\ction-soecific reauirementS are controls or restrictions on particular types of
activities in related areas such as hazardous waste management or wastewater
creatment. .-\11 example is Resource Conservation and Recovery Act (RCRA)
incineration srandards. Because such requirementS are triggered by the panicular
remedial alternative acrion considered, and the FS evaluates a wide range of
alternative acuons. many different action-specific requirements may be
applicable.
The chemical-. location-, and acrion-specific ARARs for Site 34 are summarized in Table
2.2-1.
2.2.2 Chemical-Specific ARARs
Chemical-specific requirementS "set health- or risk-based concentration limits or discharge
limitations in various envirorunental media for specific hazardous substances, pollutantS, or
contaminants" (52 FR 32496). These requirements generally set protective cleanup levels for
the chemicals of concern in the designated media, or indicate a safe level of release that may
be incorporated into a remedial activity.
SJ4ROD.APB
B-2
-------
Table 2.2-1
ARARs for Site 34
Pe2Se AFB, NH
.
Chemical-Specific ARARs
Clean Water Act (C\VA)
Clean Air Act (CAA)
State of New Hampshire Regulations
Location-Specific ARARs
.
Fish and Wildlife Coordination Act (FWCA)
State of New Hampshire Regulations
Action-Specific AR.ARs
.
Hazardous Materials Transportation Act (HMTA)
Occupational Safety and Health Act (OSHA)
CWA
CAA
State of New Hampshire Regulations
.
To Be Considered (TBCs) Criteria
EPA Health Advisories (HAs)
EP A Risk Reference Doses (RIDs)
EPA Carcinogen Assessment Group Potency Factors
NH Interim Policy for the Management of Soils Cont~m;nated From
SpillS/Releases of Virgin Petroleum Products
S34ROD.APB
B-3
-------
Clean \Vater Act
The provisions of CERCL-\. Section 121 state that remedial actions shall attain federal water
quality criteria where they are relevant and appropriate. Federal water quality criteria
documents have been published for 65 pollutantS or groups of pollutantS liSted as toxic under
the C\V A. These criteria are unenforceable TEC guidelines that may be used by states to set
surface water quality standards. Although these criteria were intended to represent a reasonable
eStimate of pollutant concentrations consiStent with the maintenance of designated water uses,
states may appropriately modify these values to reflect local conditions.
The water quality criteria are generally represented in categories that are aligned with different
surface water use designations.
Most aquatic life that exhibitS levels below specified
concentrations is protected against acute or chronic effectS (24-hour average). Specific criteria
have not been eStablished for many chemical compounds because of insufficient data. Table
2.2-2 provides the most recent water quality criteria for the protection of aquatic life and
human health.
Clean A.ir Act
The CAA was enacted to protect and enhance the quality of air resources to protect public
health and welfare. The CAA is intended to initiate and accelerate national research and
development programs to achieve the prevention and control of air pollution. Under the CAA.
federal agencies are to provide technical and fmancial assistance to state and local governmentS
for the development and execution of their air pollution programs. EPA is the administrator
of the CA..A and has the responsibility to meet CAA objectives. CAA requirementS are
potentially applicable to remedial actions that result in air emissions, such as excavation,
landfilling, and treatment activities. National Ambient Air Quality Standards are listed in Table
2.2-3.
S34ROD......P9
B-4
-------
State of New Hampshire Re1!ulations
Groundwater
Draft New Hampshire Code of Administrative Rules (NHC.~) and Env-Ws 410 Protection
of Groundwater. have been developed and the NHCAR is under the public comment period.
The NHCAR. rules are not yet enforceable. and Env-Ws 410 has been officially adopted and
is enforceable. the State of New Hampshire Department of Environmental Services (NHDES)
has consistently applied the requirementS ,set forth in these proposed rules and. as such,. they
are TBCs and ARARs, respectively. The chemical-specific requirementS of these rules are
discussed in Env-Ws 410.03, Groundwater Quality Criteria. and are presented as follows:
.
~o person shall cause groundwater quality to be altered in any way that would
make groundwater unsuitable for use as a source of drinking water.
.
No person shall cause groundwater to contain any regulated contaminant at
concentrations above the groundwater quality standards adopted under the New
Hampshire Revised Statutes, Annotated (RSA) 485-C:6.
.
Prior to the adoption of specific groundwater quality standards. no person shall
cause groundwater to contain any regulated contaminant in a concentration
above the maximum contam1nant level established in Env-Ws 310 through 319,
or above health advisory levels issued by EPA or the New Hampshire Division
of Public Health Services.
.
No person shall cause groundwater to exceed surface water quality standards,
as eStablished in RSA 485-A and Env-Ws 430 through Env-Ws 439, at a point
of discharge of groundwater to the surface water body.
.
No person shall cause degradation of groundwater that results in a violation of
surface water quality standards, as established in RSA 485-A and Env- \Vs 430
through Env- \VS 439, in any surface water body.
Table 2.2-4 presentS State of New Hampshire MCLs and MCLGs eStablished in Env-Ws 310
to 319, Drinking \Vater Quality Standards as well as the advisory levels established by the New
Hampshire Division of Public Health and Services (NHDPHS). Regulated SMCLs (established
primarily for aeSthetic purposes) in Env- W s 319 are also presented in Table 2.2-4 and will be
considered in selecting site-specific groundwater cleanup goals.
S34ROD.APB
B-5
-------
Tablc 2.2-2
Fcdcna' Watcr QUialHy Critcria for a»rutcdioll of lI"nmn lIe"Uh .11,,1 ACI""tic Life
SHe 34, Itcasc AII'II, Nil
-
CW A Water Quality Criteria CW A Ambient Water Qnillily Criteria fur
li.r I'ruleeliun or I hllnilll Ilealih Proleclion uf A11llalic I.ilc.
Waler and Fish Fish Consumption Frcshwater Marinc
Ingeslion Only Acnte/Chronic AClite/Chronic
Parameter (mg/L) (mg/L) (mg/I.) (mg/I.)
Acenaplhene -- -- 1.7+/0Y O,9'/(),7'
Accnaphlhylcne .. -- -- 3 ,Ox 10-0 I .
Aldrin 1.3x 10-07 1.4x 10-07 3,Ox 10-03 1.3 x II}-O 1
Anlimony nnd COll1pl}unds 1.4x10-02 4.3
Arscnic aod compollods 1,8x 10-0$ lAx I Q-Q4 Q.36/().I9. 6.9x I 0-02/3.6x I ()-02
Arsenic (V) aod compounds .. -- 0.85' '2.1'
Barium and compounds --I -- -- --
Benzene 1.2x 1 0-03 7.lxI0-02 -- --
Bcryllium and compounds -- -- -- --
Cadmium and compounds -- -- 3.9x 10-03"/1.1 x 10-03" 4.3x 1 0-02/9.3x 10-03
Carbon tetrachloride 2.5x!0-04 4.4x I Q-()3. --
'. ..
Chlorclane . . ... 5.7xI0-07 5.9x I 0-07 2.4x 1 0-03/4.3x 1 0-06 9.0" 10-05/1.0x 10-06
Chlorinaled bcnzcnes -- -- 2.5x 10-0 1'/5.0x 1 0-02' 1.6x 10-01'/
1.3x IO.Olt
Chlorinaled llilp!!llmlenes' -- -- 1.6' 7.5x j()..()J'
Chloroalkyl elhers -- u 2.3xI0102' --
S34IWU.AI'U
13-6
-------
Tahle 2.2-2
Federall Walter Quality Criteria ror .»rutection or lIullum
Site 34, Pease AIm, Nil
(Continued)
IIc~,Uh aUlI A(llwtic Lire
CW A Water Quality Criteria CW A Ambient Wuter Quality Criteriu fur
fur Protection of Human Health Protection of Aquatic Lilc'
Water and Fish Fish Consumption Freshwater Murine
Ingestion Only Al:llie/Chronic Al:llte/Chrunic
Parameter (mg/L) (mg/L) (mg/L) (mg/L)
Chloroform ' ."-:: '. ., .,.: ":':. .,:0::' '::'0:47"
""".,. . : ,::,.;".:::.,,,:. '5.7xI0-03 " -- --
2-Chlorophe!1ol . .. -. 4.4 .-
chromhlln Oil) an~ cOlnpoUn~S. . -- -- 1.7~./0.2.* --
Chromium (VI) and f,;ompou/1cls. . ,. .- .. 1.6x ~ 0-02/1. t x 1 0-02 1.I/5.0x 1 (J.02
.
Copper and compounds -- -- 1.8x 10-02"/1.2x 10-02" 2.9x J 0.03/2.9:< J 0.03
Cyanides 0.70 220 2.2x I 0-02/5.2x 10-03 1.0x I O-OJ/I.Ox 10-03
PDT 5.9x 10-07 5.9x 10-07 1.1 x! 0.03/I.Ox I ().(16 Ux 1().(WI.()x I ().(16
Dibulyl ph~hala~e' 4 154 -- --
.
Dich lorobenlcncs 4x10-91 2.6 J. J .17.6x 10-0 J. 1.9*
,
1.2-Dichloroelhane " '3.8x 10-94 . 9 .9x I 0-0.2 -- --
Dich loroclhenes -- -- 11.6 224
I. t -Dichloroethene 5.7x 10.05 3.2xIO-03 .. -.
2.4 - Pich lorophcnol 9.3x 10-02 0.79 2.0*/0.37* u
Dieldrin 1.4x 10.07 1.4x 10-07 2.5x I 0.03/1.9x 10-06 7.1 x 1(1-04/1 ,I) x 10.06
Diclhyl phthalate 23 120 ., n
S'
').AI'II
" 7
-------
Paramcler
Dimethyl phthalate
I :lUlosu I Ii III
Endrin
Ethylhcnzene
Filloranthcne
Fhwrides
IIcPlachlor
Ilcxachlorobenzene
IlcxachlorohlltUlliene
Tahle 2.2-2
Federal Water Quality Criteria for I)rotection of Human HcaUh and Aquatic Lifc
Site 34, Pease AFn, Nil
( Continuc")
CW A Water Qualily Criteria
for Protection of I hll\1i1l1 Ilcalth
CW A Ambient Water Quality Crileria for
Protectiun of Aqllath: Life'
.'
WaleI' and Fish Fish Consumplion
Ingest ion Ouly
(mg/L) (mg/l.)
313 2.900
7Ax 1 {)-()2 1.6>< I (I-O!
. "'" ..,..
d. 7 .6x IO.Q4 a.lxtQ-04.'
3.1 29
0.30 0.37
-- 4.0
2.lxI0-Q7 2.1 x t 0-07
7.2x 10-07 7.7xI0-07
4.4xI0-04 I 5x 10-02
-- --
1.4 x 10-04 1.5x 1 0-04
1.4 x W-04 l.5x 10-04
n.lIl 4.6
10 --
7 .4x 10-02 8.5x 10-02
B-H
--
Freshwater
ACllle/Chronic
(Illg/i.)
--
2.2x 1 (HH!HIK I (I..()5
.. .
. . .. . .
1.8x I ~04/2.3x IO-Q6
J2
--
--
5.2x 10-04/3.8x 1 0-06
..
--
Lead and compounds (inorganic)
Il.2x 10.0213 .2x 10-03"
Mercury und compounds ([Ilkyl)
Mercury illlIl compounds (inorgunic)
2.4x I 0.03/1.2x 1 O-O~
2.elll[ICh lorobenzcne
SHIIOJ).AI'II
1.'\. +/I.lIx 10.111 + +
d
--
f\.1i1rille
ACllte/Chwllil:
(mg/I. )
--
J..1x IU.OS/II.7x III..O/!
3.7x 1 0-05/2.3x 10-06
.1.] x 111-0 1+
--
--
5.3x 10.05/3.6x 10-06
--
-
--
0.22/1I.5x lO-t13
2.1 xl O-()3/1.5x 10.05
2.1 x 10-03/2 .5x 10.05
7.5» I II. (l2I1U.\ 11I.(lJ
--
--
-------
Tahlc 2.2-2
Fcdcral Water Quality Critcria for l)rotccliol1 of Human Hcalth and A(lualic Life
Site 34, Pcase A 11'11, Nil
(Continued)
CW A Water Quality Criteria CW A Ambicnt Watcr Quality Critcria fur
li)r Protection of Iluman Ilcalth Protection of Aquatic I.ife"
Watcr amI Fish Fish Consumption Frcshwater Marinc
Ingest ion Gnly Acute/Chronic Acute/Chronic
Parameter (mg/I.) (mg/I.) (lUg/I.) (mg/I.)
Pcntacillorophcnol 2.8x 10-04 8.2xI0-03 2.0x 1O-02/\.3x 10-02 1.3x 10-02/7 .9x 1(1-03
Phenol 21 4.600 \.Ox 101 01/2.5 5.8
Polychlorinated biphenyls (PCps) 7.9,,10-08 7.9" 1 O-O~ 2.0" 1 0.03/ 1.4" 10-05 1.0" 10-02/3.0" 10-05
Selenium and compounds -- "- 0.02/5.0" I 0-03 0.30/0.07
Silver and, cornpounds .'... 4.lx 10-03" 2.3x 10-03
1,I,2,2-Tctrachlorocthane . . 1.7X10.04 I.I~ 10-02 .. --
Tctmchlorocthancs .. -- 9.3* --
'I'ctracl) IOI'Pctllcilc Hx I 0-04 8.9xI0-03 .- n
. .
Thallium ilnd compounds pxIO-()3 ().3x 1 p.Q~ -- --
Tolucne 6.8 200 -- --
1,1, I- Trichlorethane -- -- -- 3. I x 1(1 1111 *
1,I,2-Tricltlorctltanc 6x.l 0-04 4.2xIQ-02 -. .-
Trich Imcthcnc 2.7xI0.()3 8.lxI0-02 --
2,4,5-Tricltlorophenol . 26 -- O.I"/6.3x I 0.()2 O.24f/ 1.1 x 111-021'
. .
2,4,6-Tricllloropheno!' .. ' 2.lxI0-03 " ~.~xJ().03 9.7xI0-01. --
S'
').AI'U
I> 9
-------
Table 2.2-2
Federal Water Quality Criteria for P.'otection of Human
Sitc 34, Itcasc Aii'D, Nil
(Cnntinnetl)
IleaUh and ACllliitic ..ifc
.-
CW A Water Quality Criteria CW A Ambicnt Watcr Qnality Critcria Ii II'
fur Protection of lIuman lIealth Protection of Aquatic Lifc'
Watcr and Fish Fish Consumption Freshwater Marine
I n!;Csl ion Only AUlte/(:hnlllil: AUlh.:/l'hwnk
Parameter (illg/i.) (mg/I.) (illg/i.) (illg/i.)
.- - --"-
Vinyl chloride 2x10.03 S.3x 10.()I -- --
Zinc amI compounds -- -- 0.12/0.11 9.5x I 0-U2/8,6x 10-02
n.
'Federal Water Quality Crilcria (rwQC) arc lIot legally ellforceable standards, but arc potentially relevant and ilppropriate 10 CERCLA
actions. CERCLA 121 (d)(2)(D)(i) requires consideration of four factors when detennining whether rWQc arc relevant and appropriate:
(1) the designated or potential use of the surface water or groundwater; (2) the environmental media affected; (3) the purposes for
whidl such criteria were developed; ami (4) the latest information available.
.Lowest observed effect level.
"Jlardness-dependent criteria (100 mg/L used); refer to specific criteria documents for equations to calculate criteria hased on other wilter hardness values.
Source: CERCLA Compliance with Olher Laws Manual. Interim Pinal. 8 August 1988.
P = Proposed value.
SHlUlI>.AI'IJ
13-10
-------
T..hlc 2.2-3
Fcdcral "ml S',,'e Amhicn' Air Qu"IHy Shuulanls ,lIul
Stolte Tuxic Air Pollutant Amhient Air LimHs
Sitc 34t "case AFIJ, Nil
I'ullillani
Nalional Ambient Air Quality Standards
(40 CFR 50)
('lwm')/(pPIII)
Ambient Air Standillds
(Nil Adillin. Cude, Chapl. 300, Pari 3m)
(,(wm')
Curbon monoxide (CO) .
',40,000 (I-hol.lr uvcrol\c)/3S (I-hollr ~vcruGc)
10,OOO(8.'hQ~tr !!VCragc)l') (8-hl)lIr. ~vcruge)
I.S (3 months)
. ~O,OOO (I-hollr I\VCriIGe)
10,000 (8,-IIOl!r average)'
'.5 (01/11111<11)
~.ea~ (I)~)
Nilro~CII ~10X,illc (NO,)
Olone' (0.) . . : " : :.'
100 (1IIInuul)/O.053 (ullllllul)
100 (Ulllllla\)
23 S (!-hour)
. . ,. . .
.. 23~' (l-Ilollr)/0.'12 (I ~ho;lr)
150 (24-hour)/NA
150 (24-holllt
1,300 (3-11(1111)
)65 (2'Hour)
~O ~arinual)
particulate mailer (rM-1 0)
Snlfur dioxide (SO,)
1,3QP ().hour)/0.5 (3-hullr)
. 36S(~4-1")lIr)/q.!4 (24-ho~r)
. '.0 (~nual~/o,.036 (Willual) .
'l„drOCilr~on.~ q ,q
I ~o ().hOIll)
ACetone
. ..
M~c"h:
D,~lum:: .
lIeOlcnc
IIc~lljuJn
ChromIum
Cob~11 .
. .
..
',. ",
, ..
.... .
.., "
..
Copper
ElhylhclIlcne
Gusuline
Man&anc~c.'
S""')D.AI'A
B-lI
Selected Tuxic Amhieut Air !.iIlIlIS (AflLs)
(Nil Admin. eude En\'-,\-IJ(I()
1 I'I;/m')
11 ,8UO
0.48
P
71
O.IIlJo\~
0.12
0.167
031
1,450
tooU
16.7
-------
Tahle 2.2-3
Fcderal 6Intl State Amhicnt Air Quality ShllHlanls ,lIul
Statc Toxic Air I)ollutant Amhicnt Air Limits
Sitc 34, ..case Ali'n, Nil
( Continucd)
Nalional Ambient Air Qllalily Standaril$ Ambient Air SlilluJuuh Seleeled Tllxie Amhient Air 1 imils (A'\l.s)
(40 CFIl SO) (Nil Admin. Cllde, Chapl. ]UU, I'alt ]0) (Nil AdUlill. Cllde 1:11\..'\-1311111
1'lIlIlIlanl (,.g/m')/(PJlm) (,.g/m'l (,.g/Ill')
Melhyl elhyl ketone (2-nulanone) 1.%7
Nick!:! 0.12
Xylenes t"tSO
Zinc 50
"This maximum 8-hour level may not bc excceded morc than once per year.
bThis maximum 24-hour level may not be exceeded more than once pcr ycar.
NA = Not applicable.
SHIUJI).AI'A
1\-12
-------
Table 2.2-4
State Groundwater negnlatury Criteria
Site 34, Pease AFU, Nil
Ncll' Ilampshirctli
Ncll' Ililiupshhc l)ivbiull uf I'liblic l!callh Scrviccs") J)linkilll! Wilicr Qualily Slillhiahis
Paramclcr Advisory Level I Source MCI. I MCI.O I SMCI.
Inorganlu
I\Ichlb (lIIg/l.)
AluminulII - - u _. 0.2
Arsenic 0.05 MC!. 0.05 u u
lIarium 2 MC!. 2 2 -.
lIoron 0.62 LIlA u u --
Cudmlulil O.OIlS r.ICI. IIIIIIS II.IIII~ --
Chromium (Iolal) 0.1 MCL 0.1 0.1 u
Iron - . _. _. 0.3
Lcad 0.01 S' r.ICI. IIIIIS II --
Mangancse . - -- -- 0.05
Mercury 0.002 MC!. 0.002 0002 ..
Nickel 0.1 Met. eo 0.1 ..
l'OIB:isium 35,000 UintA .. 00 ..
SodiulII - 0 u u 11111 III 2511
Zinc - - eo _. 5
Orgllnlcs:
l'csllcldcsll'CU, (IICIl.)
I'clllachiurophenol I MCL I 0 30
VOCs (/lC/I.)
Ucnlcllc S MCL 5 0 --
ChlorobclllclIC (IIIUIIO) 100 MCL 100 1011 --
1,2.UichlurubclIlenc 600 MCI. 61111 (,1111 III
1,4.l)ichlurubclIlclic 75 MCL 7S 75 5
1,l.Ukhluroclhanc III IIlIIlA IIllM u --
SHItOI>.AI'U
P '1
-------
T..hlc 2.2-4
S.OI.e GI-ollndw~lter Hcglll..tory Criteria
Sitc 34, l)c~lsc AFR, Nil
(Continuc(1)
=
"'" """'1""'''''' ~
NelV lIulllpshire Divisiull IIfl'uhlk lIeuhh Scr\'kes'" Iii ill~in!; Willer Quulil)' Slillhl"lIb
l'aroll1etcr Advisory !.evc:1 I Source MC!. I /lU:1.G r SMCI.
I.I-Ukhloroclhcne 7 MCt. 7 7 --
cis-I,2-Uichlufllelhclle 70 /IIl'l. 70 '/11 --
IIWIS-I.2-Uichloroclhclle IUO MCI. 100 IUO n
EtJlylbclllcnc: 7UO /IICt. 700 700 ]U
Tc:lIachluroclhcllc S /IICI. S 0 ..
Tolllcnc I,UOO /IICI. 1,000 1,0110 ,1\1
1,2.4-TrichlurobclIlcIlC 70 MCt. II 11M !II ..
1.I,I-lrichlnructJlal1c 201J /ltel. 201J 201J n
Trichloroclhelle S /IIl'1. S 0 --
Tr khlorolluoromclhune 2,000 LIlA .- -- n
Xylelles (Iutal) 10,000 MCt. 10,000 10.11011 20
-..-
S\'Ul:. (JAG/I.)
bb(2.l:Ihylhcxyl) phthalate -- n -- 0 --
Naphthakne 20 LIlA II J) /II .. n
I'hcnol 4.UOn LIlA n -- ..
Source:
."New lIall1l'shlre I>ivisioll of Pllblic lIeallh Scrviecs Advisory I.cvcls dalcd S Jllnc I !In.
Notes:
UIIIlA .. lIureau of lIealth Itlsk Assessment I>rll1ldnl: Waler Criterinn.
CAG " EPA Risk Vulue: lor 10' risk.
f'" Concenilation diners from Fedcral criteria.
n. ~ fedefillly lisled IIlIly.
\.IIA .. I.ili:tilllc Ikullh Allvisur'y,
NU'l>Wlt '" National Interim Primary I>rilikilll: Water Itegillatiulls.
MC!. ~ /IIaximum CUlitalllillllll1 \.evel (cillurccuble; as close 10 MCJ.{j us ledlllically feasible).
MCI.G '" Maxilllum Conlalllinallt l.eve! Goal (prolective of hUlllan health; no known or expecled adverse health effeelS).
Sl:MI. -= Secondary Maximum Conlaminalll I.evel (proleclivc: of hmnan IVelfarc; plimUlily uestllcllc).
SHltOl> AI'II
1.1-14
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Table 2.2-4
StOlte (;ruundw~,ter Itegulatury CrHeriOl
Site 34, »>ease Alt'U, Nil
(Continucd)
II .. Treatment Techniqlle.
UItM. Unreguluted orgwlic cOlllumlliullt reljuirillgllloilitorilill UlIce, wilh u ~umple Ulld u ,oIlHuIUti,," ~ulllple.
URM2 .. Unregulated orgallic conlllminant requirillg monitoring for II millimum of 1 year (four cOII~ecutive quarters).
lIDM = Unregulaled organic conlaminant requiring discrclionary monitoring.
WQC = Waler Quality Criteria.
'Illesc critcria assuillc ~ml ouly ulle cOlllamillallt is prc~ellt. Additive or s)'ucrgislie elfcels of two ur mure cumpounds may relluire luwcr crileria.
. Environmclltal condilions can alTecl the: acsthelic value of wilier ouly; aclual regulaled value le/\ 10 ~'e stale.
u .. Unregululed ioorgllllic cOlilamllluuls. Treutmelll, ~ubSlilulioll, or closure of Ihe: source of the~e cOlltamillllnt~ will be sought hy Ihe NlmES hased ou thc rc.ommclIlhltiulI uf Ihe
Nllllcal~1 Risk Assessment Ullil, EI'A SNAIlI.S, or o~ler health refcrcllces.
.. '" Criteria nOI aVlliiable.
SHIWD.AI'U
0-15
-------
The aforementioned requirementS would apply to new discharges to groundwater outSide a
Groundwater Management Zone (Env-Ws 410.26), but would not apply to discharges to the
groundwater \vithin the captUre zone of a groundwater extraction and treatment system
associated with remediation of contaminated groundwater under a groundwater monitoring
permit. Further discussion of Env-Ws 410, including the state's poiicy for dealing with sites
where groundwater has been conT.aminated by past discharges (Groundwater Management Zone
Policy), is presented in Subsection 2.2.4.
Wastewater to POTW
NHCAR Env- W s 900, Part 904, has eStablished pretreatment standards and guidelines for
wastes iliat are discharged to a publicly owned treatment works (POTW).
Air Emissions
NHCAR Env-A 300, PartS 303 and 304, have established primary and secondary ambient air
quality Standards (equivalent to federal standards). Tbese requirementS are listed in Table 2.2-3
and are summarized as follows:
(a)
Particulate Matter
.
Tbe annual arithmetic mean for particulate matter shall not exceed 50
p.glm3.
The maximum 24-hour average concentration for particulate matter shall
not exceed 150 p.glm3.
(b)
Sulfur Dioxide
.
The annual arithmetic mean for sulfur dioxide shall not exceed 0.030
ppm or 80 p.g/m3.
.
The maximum 24-hour concentration shall not exceed 0.14 ppm or 365
p.glm3 more than once per year.
.
For secondary standards, the maximuIn 3-hour concentration shall not
exceed 0.5 ppm or 1,300 p.gim3 more than once per year.
S34ROD.AP9
B-16
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(c)
Carbon Monoxide
.
The maximum 8-hour concentration shall nOt exceed 9 ppm or 10 mgim3
more than once per year.
.
The ma.ximum I-hour concentration shall not exceed 35 ppm or 40
mgim3 more than once per year.
(d)
Nitrogen Dioxide
.
F or primary and secondary standards. the annual arithmetic mean for
nitrogen dioxide shall not exceed 0.05 ppm or 100 j.LgimJ.
(e)
Ozone
.
F or primary and secondary standards, the maximum I-hour average
concentration of ozone shall not exceed 0.12 ppm or 235 j.Lg/mJ.
(t)
Hydrocarbons
.
In order ro achieve primary and secondary Standards, the maximum 3
consecutive hour concentration, from 6:00 a.m. through 9:00 a.m., of
nonmethane hydrocarbons shall not exceed 0.24 ppm or 160 j.Lg/m3 more
than once per year.
(g)
Lead
In order to achieve primary and secondary standards, the maximum
arithmetic mean averaged over a calendar quaneI' shall not exceed 1.5
j.Lgim3. .
NHCAR Env-A, Part 1303, identifies toxic air pollutants to be regulated. These pollutants are
also listed by EPA in 40 CFR 61. Toxic ambient air limits (AALs) established for some of
the chemicals detected at Site 34 are listed in Table 2.2-3.
NHCAR Env-A, Chapters 600, 1000, and 1200, have established standards for the release of
air emissions, including VOCs and hazardous air pollutants. Applicable standards include the
most stringent of the following requirements:
.
New Source Performance Standards (40 CFR 60).
.
National Emission Standards for Hazardous Air Pollutants (40 CFR 61).
S34ROD.APB
B-17
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.
~ew Hampshire State Implementation Plan Limits.
See RSA 125-C:6, NHCAR Env-A 101.09. md =:nv-A 606.01. Remedial action
may be necessary to prevent unpermitted air emissions from the site. including
volatilization of soil contaminants. during remedial activities.
2.2.3 Location-Specific ARARs
Location-specific requirements "set restrictions on activities depending on the characteristics
of a site or itS immediate environs" (52 FR 32496). In derermining the use of these location-
specific ARARS to select remedial actions for CERCLA sites. one must investigate the
jurisdictional prerequisites of each of the regulations. Basic definitions. exemptions, etc..
should be analyzed on a site-specific basis to confirm the correct appiication or the
requirements. A description of Site 34 and its immediate environs is contained in Section
1.
Fish and Wildlife Coordination Act
The purposes of the FWCA are to conserve and promote conservation of fish and wildlife and
their habitats. The FWCA pertains to activities that modify a stream or river and affect fish
or wildlife. Actions mUSt be taken to protect those fish and wildlife resources affected by sire
activities.
State of New Hamushire Reauirements
Wetlands Impact
RSA 485-A:17 and Env-Ws 415 establish criteria for conducting any activity in or near state
surface waters that significantly alters terrain or may othernise adversely affect water quality,
impede natural runoff, or create unnatural runoff. Activities within the scope of these
provisions include excavation. dredging, filling, mining, and grading of topsoil in or near
wetlands areas. Remedial activities near or adjacent to wetlands or surface water must comply
with these criteria for the protection of state surface waters.
S34ROD.APB
B-18
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RSA 482-A and (Env- Wt) 300 to -+00, 600. and 700 regulate filling and other activities in or
adjacent ro wetlands. and establish criteria for the protection of wetlands from adverse effects
on fish. wildlife. commerce, and public recreation. Remedial acrivities in wetlands located in
or adjac~nt to the site must comply with these wetlands protection requirements.
Wellhead Protection Program
The New Hampshire Wellhead Protection Program, instituted under RSA 485:48 of me New
Hampshire AdminiStrative Code. has been approved by the Council on Resourc~s and
Development and EP A.
Under the program. wellhead protection areas (WHP As) for public wells (private homeowner
wells are not included in this program) will be delineated and potential groundwater
contamination sources (PCSs) within those areas will be identified and managed. The state's
program for managing PCSs wiiI include educating industry personnel on management and
handling practices that reduce the risk of groundwater cODt:!mination. These practices are
called Best Management Practices (BMPs). Management inspections will be performed
periodically at each identified operation in a WHP A to ensure that BMPs are being used.
Rules for these BMPs and the authority to enforce them at the state and local levels are
proposed under a draft groundwater classification system for the state. Additional regulatory
and nonregulatory tools are available to local governments for the management of PCSs in
WHP As; guidance on these will be made available through the Office of State Planning.
2.2.4 Action-Specific ARARs
Action-specific ARARs are technology- or activity-based requirements or limitations on actions
taken with respect to hazardous wastes. These requirements are triggered by the particular
remedial activities that are selected to accomplish an alternative. Since there are usually
several alternative actions for any remedial site, different requirements can come intO play.
These action-specific requirements do not in themselves determine the remedial alternative;
rather, they affect how a selected alternative must be achieved.
S34ROD.AP8
B-19
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The diStinction betWeen substantive requirementS and adminiStrative reqUlrementS at a
CERCLA site is important when reviewing different action alternatives.
SubStantive
requirementS pertain directly to actions or conditions in the environment while adminiStrative
requirementS pertain to permitS that facilitate implementation of a requirement. At CERCLA
sites. actions taken on-site are exempt from the adminiStrative requirementS. F or example,
discharge to an on-site Stream would be exempt from permit requirementS, bUt discharge to a
POTW would not be exempt.
Wetlands Protection
Through Executive Order No. 11990, regulations regarding protection of wetlands were
promulgated by EP A under 40 CFR 6.302. As wetlands areas exiSt at Site 34, the foHowing
action-specific regulatory requirementS represent potential ARARs:
.
Avoid adverse impacts associated with the destruction or 1055 of wetlands.
.
Avoid new construction on wetlands unless no other practicable alternative
exists.
.
Prepare a wetlands assessment if wetlands will be affected.
.
Minim;7e adverse impactS on wetlands if no practicable alternative to the action
exists.
Hazardous Materials Transportation Act
Through the Hazardous Materials Transportation Act (49 USC 1801 to 1813), regulations
regarding the transportation of hazardous materials were promulgated by the Deparc:nent of
Transportation (DOT) under 49 CFR 107 and 171 to 177. If transportation of DOT -defined.
hazardous materials off-site is a potential remedial action at Site 34, the following action-
specific regulatory requirementS represent potential ARARs:
.
Hazardous materials table (49 CFR 172.101).
Required manifeSt information (49 CFR 172.101. 172.203, and 173).
Transportation mode requirementS (49 CFR 172.101 and 174 to 177).
S34ROD.AP9
B-20
-------
.
Packaging, labeling, and marking requirementS (49 CFR 172. 178. and 179).
Transportation placarding requirementS (49 CFR 172, Subpart F).
.
Occupational Safety and Health Act
The Occupational Safety and Health .-\ct (OSHA) (29 USCA 651) resulted in creation of the
Occupational Safety and Health AdminiStration to protect worker safety and to administer
regulatory control for worker safety.
Under OSHA. general indUStry standards have been promulgated under 29 CFR 1910. The
action-specific requirementS given under 29 CFR 1910.120, Hazardous Waste Operations and
Emergency Response. may apply to remedial activities at Site 34.
Clean \Vater Act
CW A regulations establish effluent standards for point source discharges as follows:
S34ROD.APB
.
Direct discharge to a surface water is governed by the National Pollutant
Discharge Elimination System (NPDES) permitting requirementS (Section 402
of the CW A). Specific permitting requirements are contained under 40 CFR
125, while specific effluent guidelines and standards are given in 40 CFR 401.
It should be noted that no categorical effluent guidelines or standards have been
established for hazardous waste sites. It should be noted, however, that
standards established in 40 CFR 403.6 for various industrial uses may be
indirectly applicable to hazardous waste site operations if the types of
technologies employed during remediation are similar to the processes used in
the regulated industry.
.
Indirect discharge to a POTW is governed by pretreatment regulations [Section
307(b) of the CWA]. National pretreatment standards are addressed under 40
CFR 403. The standards specifically prohibit discharge of the following items
(40 CFR 403.5):
Ignitable or explosive wastewater.
Reactive or toxic fume-generating wastewater.
Used oil.
B-21
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Solvem waste.
PollutantS that pass through the POT\V 'Without treatment. interfere with
POT\V operations. contaminate POT\V sludge, or endanger the health or
safety of POT\V workers.
Transported pollutantS. except at pointS designated by the POTW.
NPDES discharge limitations are based on meeting the following criteria:
.
Location-specific. federally approved state water quality Standards (40 CFR
122.44 and 131.40).
.
Action-specific best available technology (BAT) economically achievable
requirementS LO control toxic and nonconventional pollutantS and best
conventional technology (BCT) requirementS to conn-ol conventional pollutantS
[40 CFR 122A4(a)]. However, technology-based limitations may be determined
on a case-by-case basis.
Compliance with eStablished limitations is based on discharge monitoring of pollutant mass,
effluent volume, and frequency of discharge (40 CFR 122.41). Approved sampling and test
methods must be used for monitoring (40 CFR 136.1 to 136.4). Discharge of CERCLA
wastewaters to a POTW \vould constitute an off-site activity and, thus, is subject to all
permitting requirementS and local pretreatment requirementS. When considering discharge of
CERCLA wastewaters to a POTW, the POTW's record of compliance with its NPDES permit
and pretreatment program requirements mUst be assessed to determine \vhether the POTW is
a suitable disposal site for CERCLA wastewater.
EP A's Groundwater Protection Strate~ for the 1990s
In July 1989, EPA eStablished a Groundwater Task Force to reVlew EPA's groundwater
protection programs and to develop concrete principles and objectives to ensure effective and
consistent decisionmaking in all EP A activities affecting the resource. The outcome of this
effort is a report entitled., Protecnng the Nation's Groundwater: EPA's Strategy for the 1990s.
Since this policy is intended to direct the course of EPA's effortS in the coming years, it has
the potential to significantly affect any action taken to remedy contaminated groundwater at
SJ4ROD.APB
B-22
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Pease AFB. \vhich in rum may impact groundwater and source area remediation at Site 34.
Specific componentS of this policy that may significantly affect groundwater remediation at
Pease AfB are swnmarized as fo11O\...-s:
EP A's Groundwater Protection Princioles
The overall goal of EPA's groundwater policy is to prevent adverse effects on
human health and the environment and to protect the environmental integrity of
the nation's groundwater resources.
.
In detennining appropriate prevention and protection strategies, EP A will also
consider the use, value. and vulnerability of the resource, as well as social and
economic values. Thus. in decisionmaking, EP A must take a realiStic approach
to restoration based on actUal and reasonably expected uses of the resource as
well as social and economic values.
.
The primary responsibility for coordin~ring and' implementing groundwater
protection programs has always been and should continue to be veSted with the
states. An effective groundwater protection program should link federal, state,
and local activities in a coherent and coordinated plan of action.
EP A's Policv on Use of Oualitv Standards in Groundwater Protection and Remediation
Activities
S34ROD.APB
.
MCLs under the SDW A will be used as reference pointS for water resource
protection efforts when the groundwater in question is a potential source of
drinking water.
.
When MCLs are not available, EP A Health Advisory numbers or other approved
health-based levels are recommended as pointS of reference.
.
Water quality standards under the CW A will be used as reference points when
groundwater is closely connected hydrologically to surface water ecological
systems.
.
In certain cases, MCLGs under the SDW A, or background levels, may be used
in order to comply with federal statutory requirementS.
.
In general, remediation will attempt to achieve a total lifetime cancer risk level
in the range of 10-4 to 10~ and exposures to noncarcinogens below appropriate
reference doses. More Stringent measures may be selected based on such factors
as the cumulative effect of multiple confJ'lminJ'lntS, exposure from other
B-23
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pathways. and unusual population sensitivities. Less Stringent measures than the
reference ~oint may be selected where authorized by law based on such factors
as technoiogical practicality, adverse environmemal impactS of remediation
measures.:oSt, and low likelihood of potential use.
Clean Air Act
The Ci\i\ (42 USC 7401 ~t seq.) mandates EPA to establish regulations to protect ambient air
quality. As such. it may be applied as an ARAR to Site 34 for remedial actions that potentially
result in air emissions.
Under the CAA, three ar--.a5 were identified for regulation:
.
Establishment of National Ambient Air Quality Standards (NAAQS).
.
Establishment of maximum emission standards as expressed under the National
Emission Standards for Hazardous Air Pollutants (NESHAP).
.
Establishment of maximum emission standards as expressed under the New
Source Performance Standards (NSPS).
NAAQS and NESHAP represent chemical-specific requirements (see Table 2.2-3). The NSPS
contain action-specific requirements.
~e. CAA was amended in 1990; however, most of the final rules to support this amendment
have not yet been issued. It is expected that the new rules will include expanded permit
requirementS and maximum available control technologies for hazardous waste facilities.
State of New Hampshire Regulations
Hazardous Waste Re1!Ulations
The hazardous waste rules for the State of New Hampshire are presented in the NHCAR,
Subtitle Env- Wm. These rules establish a hazardous waste permit program and a mechanism
for monitoring hazardous wastes subject to other regulatory programs. such as NPDES.
S34ROD.APB .
B-24
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A waste is considered hazardous by NHDES if it is listed in Env-Wm 400 of the Hazardous
Waste Rules or is listed in 40 CFR 261. A waste . also may be considered hazardous if it
exhibits any of the ignitabliity. corrosiveness. reactivity, or TCLP characteriStics set forth in
-+0 CFR 261.
These provisions eStablish standards applicable to the identification. liSting, and deliSting of
hazardous waste; permitting; inspection; enforcement; and recycling requirements. These rules
also set requirements for owners and operators of hazardous waste facilities, and transponers
and generators of hazardous \vaste.
These regulations may be applicable or relevant and appropriate for remedial activities at Site
34. Any activity involving handling or moving a waste or soil and debris determined to be
hazardous may involve Env- \Vm Hazardous Waste Rules.
Solid \Vaste Reauirements
State of New Hampshire requirements for solid waste m::tn::teement are contained in the New
Hampshire Solid \Vaste Rules. NHCAR Env-Wm 100 to 320 and 2100 to 2800. These
provisions establish standards applicable to the treatment., storage, and disposal of solid waste
and the closure of solid waste facilities. Nonhazardous solid waste on-site mUSt be managed,
stored. treated, and disposed of in accordance with the Solid Waste Management Act and the
rules thereunder.
Unden!round Stora~e Tank Reauirements
State of New Hampshire requirements for the installation, permitting, testing, operation,
maintenance, and closure of USTs are contained in the NHCAR, Env-\Vs 411, General
Requirements for Tanks at Underground Storage Facilities. These regulations outline
procedures and requirements for management of underground storage facilities, including the-
follo~ing:
S34ROD.APB
B-25
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Facility Registration (Env-Ws 411.04).
()
Permit to Oper:ne (Env-Ws 411.07).
Transfer of Facility Ownership (Env-Ws 411.08).
.
Inventory Monitoring (Env- W s 411.11).
.
Tank Tighmess TeSting (Env-Ws 411.13).
.
S pill/Overt ill Protection (Env- W s 411.25).
Release Detection for Tanks Without Secondary Containment and Leak
Yfonitoring (Env-Ws 411.29).
.
Corrosion Protection for Steel Tanks (Env-Ws 411.32).
.
Permanent Closure (Env-Ws 411.18).
.
Secondary Containment for New Tanks (Env-Ws 411.23).
These regulations apply to tanks with capacities greater than 110 gallons that .store regulated
substances, including motor fuels, heating oils, lubricating oils, other petroleum products, and
petroleum-contaminated liquids and hazardous substances. These regulations would apply to
the JP-4 and oil/water underground tanks at Site 34. If remediation activities at the site involve
testing, retrofitting, or removal of USTs, these activities will be executed in accordance with
the aforementioned requirementS.
The State of New Hampshire has also developed a guidance document entitled, Interim Policy
for the l\1anagement of Soils Contaminated from Spills/Releases of Virgin Petroleum Products
(NHDES Virgin Petroleum Products Policy). This policy identifies options for treatment,
current analytical methods, and remediation goals for virgin petroleum-cont~minated soils.
Remediation of soils at Site 34 that have been cont~minated by virgin petroleum products will
be handled in accordance with this policy.
Remediation goals established for virgin petroleum-contaminated soil are as follows:
S34ROD.APB
B-26
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Gasoline
Benzene. toluene. ethylbenzene, and xylene lBTEX) - 1.0 ppm.
.
Total pen-oleum hydrocarbons (TPHs) - 10.0 ppm.
Diesel fuel or other fuel oils
.
BTEX - 1.0 ppm.
.
TPHs - 100.0 ppm.
According to NHDES. remediation goals for soil contaminated with JP-4 would be the same
as those presented for diesel and other fuel oils. Currendy, NHDES does not have a formal
policy for the handling of soils cont~minated by hazardous wastes or waste oils resulting from
the operation of underground storage syStems. These materials will be dealt with in a future
NHDES policy document.
Groundwater
As previously indicated, the State of New Hampshire has adopted Goundwater Protection Rules
(Env-\Vs 410).
These rules present the state's policies and procedures for dealing with new discharges of
contaminants to groundwater and to groundwater already cont~m1nated by past discharges.
Air Emissions
The air emissions requirements of the State of New Hampshire are summarized as follows:
.
Demonstrating Conformance (Env-A 1 0 1.26).
Testing and Monitoring Procedures (Env-A 800.07 and 800.09).
Malfunctions/Breakdowns of Air Pollution Control Equipment (Env-A 902).
Fugitive DuSt Emission Control (Env-A 1002).
.
.
S34ROD.APEI
8-27
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Incinerator Emission Standards (Env-A 1201).
Comroi of VOC Emissions (Env-A 1204).
Impact Analysis and Permit Requiremem (Env-.-\
Toxic Air PollutantS (Env-A 1300).
1305).
Water Resources
Water resource requirementS of the State of New Hampshire are as follows:
.
Water Use Registration - Env-Wr 700, Part 701. Users of 20,000 gallons of
water or more per day over 7 days or 600,000 gallons over 30 days mUSt
regiSter with the Water Resources Division. Water flow measurementS are
defined in Part 702. Remedial activities involving the use of these quantities of
water mUSt compiy with the requirementS of this section.
Safetv
Relevant safety requirementS promulgated by the State of New Hampshire include the New
. .
Hampshire Department of Safety Rules for Transport of Hazardous Materials (Safety Ch. 600).
These regulations govern the transport of hazardous materials and wastes. They mUSt be
complied with when removal action requires off-site transportation of hazardous waste.
Water Discha~e Reauirements
The water discharge requirementS of the State of New Hampshire are summarized as follows:
.
New Hampshire IndUStrial and Municipal \Vastewater Discharge PermitS (Env-
Ws 403).
.
Pretreatment Standards (Env- Ws 904).
S34ROD.APB
8-28
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APPENDIX C
DECLARATION OF CONCURRENCE
J.4rocUpc:
-------
~ES
State of ~~ Hampsmre
DEP"~-r OF ENVIRO~"MENTAL SERVICES
6 Haze:l Drive. ?O. Box 95. Concord. NH 03302~S
603.271.3503 FAX 603-271-Z86i
TI::O ~,: Rel~ !'or! i.roc).73S.2964
D
September 14, 1993
Mr. Alan P. Babbitt
Deputy for Hazardous Materials and Was1e;
Deputy Assistant Secretar,! of the Air Force
(Environment. Safety and Occupational Health)
Suite SCS66, Pentagon
Washington, D.C. 20330-1660
RE:
Site 34 Source Area Record of Decision
Poa.. Air Forc:8 SaM Superfund Sit.
P- Air Force Base, New Hampshire
SUbJect: .
Dectaratton of Concurrence
Dear Mr. Babbitt:
The New Hampshire Department of EnvironmentaJ Services (NHDES) has reviewed the
September 1993 R8COrd of Decision (ROO) regarding Source Area Remedial ACt10n at Site
34 - the Jet Engine Test Cell at the Pease Air Force Base Superfund Site located in
Newington and Portsmouth. New HampshiT9. The intent 01 the source control action is
to reduce the potemialleaching of soil contaminants to groundwater. Remedial actions
necessary to address groundwater, surface water and sediment comaminatlon will be
addressed in the Zone 3 ROD.
A description of the SOUI"C9 control actions. together with NI-fDES' position follows;:
J.
Excavation of con1aminated soil from the JP4 Tank Area. the Fuel Oil Tank/Waste
FlJ@j Separator Area! the manhole area and hojding tankS area, and transport to
an approved off-site trestmentldispoeal facility. The ttnaJ volume of soil to ~
removed will be determined at the time 01 remediation using field screening
techniques. Removal of USTs and drain piping trom the manhole to the Test Cell
Ditch wi1l also be incorporated into the source control action.
As noted in the NHDES, "Interim Policy for the Management
of Soils contaminated from Spills/Releases of Virgin Petroieum
Products", $Oil excavatfon and tr9atmen1 is one of many
appropriate remedial methods which minimizes tran$fer of
contaminants from one environmental medium to anott1er.
Treatment in a thermal de8!OrptiQn proc9ss system, treatment
~m RESOURCES Dr.'.
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IJ
Letter to Alan P. Babbitt
Re: Site 34 ROC Declaration c1 Concurrence
SepbMnber 14, 1993
Page 2
,
and resource raccvery at a NHDES permitted asphalt batch I: I ant, as
well as, disposal in a specifically authorized RCRASubtitfe D Landfill
or RCRA facility are accepted methods tor processing yjrgin
petroleum contaminated soils. F;.ld screening of the excavation win
be conducted in accordance wTth Section VII .. Sampling and Analysis
Protocols of the NHDES Policy on Virg1n Petroleum Contaminated
Soils. Any wet1ands adversely imcacted by the source controi action
will b9 restored. subiect to the crovisions of RSA 482.A and Efw-Wt
, .
100 through Wt 800.
II.
Dewatering of ~he site during soil excavation and treatment of the extracted
groundwater a1 the existing on-site treatment facility, with subsequent discharge to
the base sanrtary sewer.
The discharge at treated groundwater from the Pilot Groundwater
Treatment Plant to the base sewer win require the devetopment of
discharge limits in coordination with the City ot Portsmouth (operator
of the base wastewa1er trea~t plant) in order to ensure
compliance with the existing National Pollution Discharge Elimination
System p9nT1it. pretreatment regulations and water poUutiOM control
laws.
III.
Environmental monitortng:
Long-term monitoring will be necessary in order to determine the
effectiveness of the source controf adton. Waier quafity monitoring
is determined on a site specific basis and will be addressed in the
Zone 3 ROO. Frequency and location of water quality monttoring is
typically required on a tri-annuai buis until a bs8eflne condition ~
estabtish9d. A comprehensive. detailed nMew will be conducted by
the' Air Force, the USEPA and the NHDES within five years after
remediation to ensure th9 remedy provided adequate protection of
human heatth and the environm81'lt.
Based upon its review. NHOES has de'termined the source area remedial action to be
consistem with app4icab1e or refevant and appropriate state requirements and policies.
NHDES. as a party to the Pease Air Force Base F8deraJ Facility Agreement. and acting
-------
Letter to Alan P. Babbitt
Re: SIte 34 ROD Declaration of Concurrence
September 14, 1993
Page 3
D
~
Sincerety,
~v~~J~ ~
Commissioner
Philip J. O'Brien, Ph.D., Director, NHCES-WMD
Cart W. Baxter) P.E., NHDE5-WMEB
Richard H. Pesse, P.E., NHDES-WMEB
Martha A. Moore, Esq., NHDOJ-PDA
Michael J. Daly, EPA
Arthur L. Oitto, P.E., AFBDA
James Snyder, AFCEE
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