PB97-963806
                                 EPA/541/R-97/079
                                 January 1998
EPA  Superfund
       Record of Decision:
       Naval Air Engineering Center OU 20
       (Site 28 Soil & Groundwater)
       Lakehurst, NJ
       7/7/1997

-------
NAVAL AIR ENGINEERING STATION, Lakehurst, NJ
                  Final
           Record of Decision for
        Site 28 Soil and Groundwater
               7 May 1997


-------
 7 May 1997
                               RECORD OF DECISION
                            DECLARATION STATEMENT
                        SITE 28 SOIL AND GROUNDWATER
                        NAVAL AIR ENGINEERING STATION
 FACILITY NAME AND LOCATION

 Naval Air Engineering Station
 Lakehurst, New Jersey 08733
 STATEMENT OF BASIS AND PURPOSE

 This decision document presents the final remedy to address Site 28 soil and groundwater at the
 Naval Air Engineering Station in Lakehurst, New Jersey. The selected alternative was chosen in
 accordance with the Comprehensive Environmental Response, Compensation and Liability Act
 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) and, to
 the extent practicable, the National Oil and Hazardous Substance Pollution Contingency Plan.

 This decision is based on information contained in the Remedial Investigation (RI) Report (October
 1992), the Endangerment Assessment (EA) Report (October 1992), the Focused Feasibility Study
 for Site 28 (July 1996), the Proposed Plan for Site 28 (February 1997), and sampling data obtained
 from the  Site 28 interim pump and treat facility (March 1993 - October 1996).  These reports and
 other information used in the remedy selection process are part of the Administrative Record file
 for Site 28, which is available  for public review at the Ocean County Library in Toms River. New
 Jersey.

 This document provides background information on the Site, presents the selected alternative and
 reviews the public's response to the Proposed Plan.

 Both  the United  States  Environmental  Protection  Agency  (USEPA),  Region  II Regional
 Administrator and the Commissioner of the New Jersey Department of Environmental Protection
 (NJDEP) concur with the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY

The selected alternative to address groundwater at Site 28 is continued operation of the existing
groundwater treatment facility with a sparge/vapor extraction system installed to accelerate the
remediation of the higher areas of soil and groundwater contamination.  The objectives of the
selected actions are to:

1) protect human health  and  the environment by reducing the  dovvngradient  migration of
contaminated  groundwater;  2)  remediate the source  areas  with the highest  concentration of

-------
contamination;  and 3) reduce site contamination to applicable  or relevant and  appropriate
requirements (ARARs).
STATUTORY DETERMINATIONS

This final action for Site 28 is protective of human health and the environment.  The results of this
action will attain Federal and State applicable or relevant and appropriate requirements (ARARs).
Captain Leroy Fan             (Date)
Commanding Officer
Naval Air Engineering Station
LakehursL New Jersey
With the concurrence of:
                       '7-    -»->
                       U   rDate^
£/eanneFox (/I/
  Regional Administrator
  U.S. Environmental Protection Agency. Region

-------
                                DECISION SUMMARY
                                RECORD OF DECISION
                         SITE 28 SOIL AND GROUNDWATER
                         NAVAL AIR ENGINEERING STATION
SITE DESCRIPTION

The Naval Air Engineering  Station (NAES)  is located in Jackson and Manchester Townships,
Ocean County, New Jersey,  approximately 14 miles inland from the Atlantic Ocean (Figure 1).
NAES is approximately 7,400 acres and is bordered by Route 547 to the east, the Fort Dix Military
Reservation to the west, woodland to the north (portions of which are within Colliers Mill Wildlife
Management  Area), Lakehurst Borough and  woodland, including the Manchester Wildlife
Management Area, to the south. NAES and the surrounding area are  located within the Pinelands
National Reserve, the most extensive undeveloped land tract of the Middle Atlantic Seaboard.  The
groundwater at NAES is currently classified by NJDEP as Class I-PL (Pinelands).

NAES lies within the Outer Coastal Plain physiographic province, which is characterized by gently
rolling terrain with  minimal relief.   Surface elevations within NAES range from  a  low of
approximately 60 feet above mean sea  level  in the east  central part of the base, to  a  high of
approximately 190 feet above mean sea level in the southwestern part of the base.  Maximum relief
occurs in the southwestern part of the base because of its proximity to the more rolling terrain of the
Inner Coastal Plain. Surface slopes are generally less than five percent.

NAES lies within the Toms River Drainage Basin. The basin is relatively small (191 square miles)
and the residence time for surface drainage waters is short.  Drainage from NAES discharges to the
Ridgeway Branch to the north and to the Black and Union Branches to the south. All three  streams
discharge into the Toms River.  Several headwater tributaries to these branches originate at NAES.
Northern tributaries to the Ridgeway  Branch include the Elisha,  Success. Harris and Obhanan
Ridgeway Branches.  The southern tributaries to the Black and Union Branches include the North
Ruckles and Middle Ruckles Branches and Manapaqua Brook. The Ridgeway and Union Branches
then feed Pine Lake; located approximately 2.5 miles east of NV-ES before joining Toms River.
Storm drainage from NAES is divided between the north and south, discharging into the Ridgeway
Branch and Union Branch, respectively.  The Paint Branch, located in the east-central part of the
base, is a relatively small stream which feeds the Manapaqua Brook.

Three small water bodies are located in the western portion of NAES: Bass Lake, Clubhouse Lake.
and Pickerel Pond.  NAES also  contains over 1,300 acres of flood-prone areas, occurring primarily
in the south-central part of the base, and approximately 1,300 acres of prime agricultural land in the
western portion of the base.

There are 913 acres on the eastern portion of NAES that lie within Manchester Township  and the
remaining acreage is in  Jackson Township.   The combined population of Lakehurst Borough.

-------
 Manchester and Jackson Townships, is approximately 65,400, for an area of approximately 185
 square miles.   The average population density  of Manchester  and Jackson Townships is  169
 persons per square mile.

 The areas surrounding NAES are, in general, not heavily developed. The closest commercial area is
 located near the southeastern section of the facility in the borough  of Lakehursl This is primarily a
 residential area with some commercial establishments but no industry.  To the north and south are
 State  wildlife  management  areas which are  essentially undeveloped.  Adjacent to and south of
 NAES are  commercial cranberry bogs, the drainage from which crosses the southeast section of
 NAES property.

 For the combined area of Manchester and Jackson  Townships, approximately 41 percent of the land
 is vacant (undeveloped), 57 percent is residential, one percent is commercial and the remaining one
 percent is industrial or farmed.  For Lakehurst Borough,  83 percent of the land  is residential.  11
 percent is vacant, and the remaining 6 percent commercially developed.

 In the vicinity of NAES, water is generally supplied to the populace by municipal supply wells.
 Some private wells exist that provide drinking water, however, the majority are for irrigation only.
 In  Lakehurst Borough there  is a well field consisting of seven 50-foot  deep  wells, located
 approximately two-thirds of a mile south of the eastern portion of NAES. Three of the seven wells
 (four of the wells are rarely operated) are pumped  at an average rate of 70 to 90 gallons per minute
 and supply  drinking water for a population of approximately 3,000. Jackson Township operates
 one supply  well in the Legler area, approximately one-quarter mile north of NAES, which supplies
 water to a very small population (probably less than 1,000) in the immediate vicinity of NAES.

 The history of the site dates back to 1916, when the Eddystone Chemical Company leased property
 from the Manchester Land Development Company to develop an experimental firing range for the
 testing of chemical artillery shells. In 1919, the U.S. Army assumed control of the site and named
 it Camp Kendrick. Camp Kendrick was turned over to the Navy and formally commissioned Naval
 Air Station  (NAS) Lakehurst, New Jersey on June 28,  1921.  The Naval Air Engineering Center
 (NAEC) was moved from the Naval Base, Philadelphia to Lakehurst in December 1974.  At that
 time, NAEC became the host activity, thus, the new name NAEC.  In January 1992, NAEC was
 renamed  the Naval Air Warfare Center Aircraft Division Lakehurst (NAWCADLKE), due to a
 reorganization within the Department of the Navy.  In January  1994, the NAWCADLKE was
 renamed the Naval Air Engineering Station (NAES), due to continued reorganization within the
 Department of the Navy.

 Currently, NAES's mission is to support programs of  technology  development, engineering.
developmental  evaluation  and verification,  systems   integration,  limited   manufacturing.
procurement, integrated logistic support management, and fleet engineering  support for Aircraft-
 Platform Interface (API) systems. This includes terminal guidance, recovery,  handling, propulsion
support, avionics  support, servicing  and maintenance, aircraft'weapons/ship compatibility, and
takeoff. The Station provides, operates, and maintains product evaluation and verification  sites.

-------
 aviation and other  facilities, and support services (including  development of equipment and
 instrumentation) for API systems and other Department of Defense programs.   The Station also
 provides facilities and support services for tenant activities and units as designed by appropriate
 authority.

 NAES and its tenant activities now occupy more than 300 buildings, built between 1919 and 1996,
 totaling over 2,845,000 square feet.  The command also operates and maintains:  two 5.000-foot
 long runways, a 12,000-foot long test runway, one-mile long jet car test .track, four one and one-
 quarter mile long jet car test tracks, a parachute jump circle, a 79-acre golf course, and a 3,500-acre
 conservation area.

 In the past, the various operations and activities at the Station required the use, handling, storage
 and occasionally the on-site disposal of hazardous substances. During the operational period of the
 facility, there have been documented, reported or suspected releases of these substances into the
 environment.

 SITE HISTORY

 Site 28 is located approximately 2,800 feet from the southern boundary of the NAES in the central
 portion of the Base (Figure 2). Site 28 is located in NAES Superfund Area  E. The Site is partially
 developed and includes various facility buildings, including Building 307, known as the Westfield
 Hangar (Figure 3). There is a shallow groundwater table at Site 28 at a depth of approximately 7  to
 9 feet. Groundwater at the site flows in an easterly direction toward the Paint Branch which flows
 approximately 300 feet to the northeast of the site.

 INITIAL INVESTIGATIONS

 As part of the DOD Installation Restoration Program  and the Navy Assessment and Control  of
 Installation Pollutants (NACIP) program, an initial Assessment Study was conducted in 1983  to
 identify and assess sites posing a potential threat to  human health or the  environment due  to
 contamination from past hazardous materials operations.

 Based on information from historical records, aerial photographs, field inspections, and personnel
 interviews, the  study identified a total of 44 potentially contaminated  sites.  An additional site.
 Bomarc, was also  investigated by NAES.  The Bomarc Site is the responsibility of the U.S. Air
 Force and is  located  on Fort Dix adjacent to  the western portion  of  NAES.  A  Remedial
 Investigation (RI)  was  recommended  to  confirm or  deny the  existence  of the  suspected
contamination and to quantify the  extent of any problems which may exist.  Following further
review of available  data by Navy personnel, it was decided that 42 of the 44 sites should be
 included in the Remedial Investigation.  Two potentially contaminated sites, an ordnance site < Site
41) and an Advanced  Underground Storage Facility (Site  43), were deleted from the  Remedial
Investigation because they had already been addressed through previous investigations or standard
removal procedures.

-------
 In  1987 NAES was designated as a National Priorities List (NPL) or Superfund site under the
 federal Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

 REMEDIAL INVESTIGATIONS

 Investigations at Site 28 were initiated from 1981 to 1984 by NAES, with the installation of two
 groundwater monitoring wells, which were monitored on a  regular basis  for the presence of free
 product. A trace of fuel was detected in 1984. Additional actions conducted at these sites include:

 PHASE I REMEDIAL INVESTIGATION (1985-1986)
 Analysis of groundwater  samples  collected  from monitoring wells at the site  revealed no
 contamination.  Low levels of toluene were detected in a sample from a supply well at the site.  A
 detailed description of the investigations and results is contained in the Focused Feasibility Study
 for Site 28.

 PHASE II REMEDIAL INVESTIGATION (1988)
 Groundwater samples were collected for analysis from three monitoring wells and one supply well
 at the site. Organic contaminants were detected in one monitoring well.  Floating fuel product was
 also detected in this well.  Analysis of four soil samples collected at the  site  revealed petroleum
 hydrocarbon and semi-volatile organic contamination in one of the samples and slightly elevated
 levels of beryllium and cadmium in another. A sediment sample collected from the Paint Branch
 downgradient from the site also contained cadmium. A detailed description of the investigations
 and results is contained in the Focused Feasibility Study for Site 28.

 REMEDIAL INVESTIGATION - PHASE II ADDENDUM (1990)
 A soil gas and groundwater screening survey was implemented at Site 28.  The results confirmed
 the presence of benzene, toluene and xylene as well as other petroleum hydrocarbons.  The source
 of contamination was determined to be the discharge of gasoline into the groundwater as a result of
 a leak unearthed in the subsurface piping running from an above ground gasoline tank to Building
 308. The zone of groundwater contamination was found to extend at least 150 feet from the source
 in a downgradient (easterly) direction. The width of the contaminant plume varied fron. about 50
 to 70 feet, decreasing in the downgradient direction.

 SOIL REMOVAL ACTION (1990)
On August 8, 1990, based on the results of the soil gas/groundwater survey,  soil was excavated
 from an area northeast of Building 308 to expose a copper gasoline pipe  running from an above
 ground gasoline tank into the building. A gasoline leak was observed at one of the pipe couplings
and repaired (the piping was later removed and replaced with above ground piping).   During the
period 9 - !3 August, eight test pits were dug in the area northeast of Building 308.  Based on
observations made in these test pits, soil was excavated from an area measuring approximately 60
ft. long,  20-40 ft. wide and 7-8 ft. deep.  Approximately 65 cubic yards of visually contaminated

-------
 soil was segregated and transferred to a nearby on-site hazardous waste storage area for disposal at
 an approved off-site facility.

 AQUIFER CHARACTERIZATION STUDY (1991)
 In January 1991, an aquifer characterization study was performed at Site 28.  One recovery well
 (RW-1) and one observation well (OW-1) were installed approximately 200 feet downgradient of
 the former gasoline leak  area  A 24-hour pumping test was conducted on the recovery well to
 estimate aquifer parameters.  This information was required to design a groundwater remediation
 system  capable  of capturing and treating the contaminated  plume resulting from the gasoline
 release.

 INTERIM REMEDIAL ACTION - SITE 28 PUMP & TREAT (1991)
 The Navy  determined  in the spring of 1991, that it had sufficient data to perform an interim
 remedial action at Site 28.  Although an in-depth risk assessment and comprehensive feasibility
 study had  not  been completed,  a  decision  to  implement an interim  remedial action to halt
 groundwater plume migration and treat groundwater contamination at Site  28  was made by the
 NAES with the concurrence of the USEPA and NJDEP. An interim Focused Feasibility Study for
 the remedial action at Site 28 was submitted on April 29, 1991. The Proposed Plan was submitted
 to the public on June  13, 1991.   A  Record of Decision, indicating the selected interim remedial
 action was signed by the EPA, with NJDEP concurrence, on September 16, 1991.

 The interim remedial action includes groundwater pumping, treatment and recharge of treated water
 back to the aquifer. Groundwater is extracted  via two wells at a combined rate of 100 gallons per
 minute (gpm).  The existing recovery well (RW-1) located downgradient of the gasoline leak area is
 pumped at  50  gpm. A new recovery well ( RW-2) which was installed at the source area was
 pumped at 50 gpm. After several months of pumping, the pumping rate of the source area well was
 increased to 60 gpm to attempt to capture the higher levels of contamination.  In the spring of 1997.
 RW-2 was  replaced with an new  recovery well screened closer to the water table to improve the
 recovery of contaminated groundwater  for treatment.  Figure 3 indicates the recovery well and
 treatment system locations.

 The extracted groundwater is pretreated to remove metals, free product and solids.  To treat the
 volatile organic compounds (VOCs) in the groundwater, the water is passed through air stripping
 columns. Granular activated carbon polishing filters are used for residual VOC and semi-volatile
 organic compounds (SVOC) removal. The air stripper emissions are treated by granular activated
 air filters before being discharged  to  the atmosphere.  The treated water is recharged to the aquifer
 at an irrigation/subsurface infiltration area located upgradient of the contaminated groundwater to
 form a "closed loop" treatment system.

The treatment system was designed by the Navy anc auarded ror construction in  September 1991.
Construction of tne facility was completed and operations began in  February 1993.  This interim
remedial action was implemented to halt the spread of contaminated groundwater from entering the
downaradient Paint Branch.

-------
 The interim action cost $ 1.3 million for construction of the treatment system.  In addition, yearly
 operational costs include: approximately 5320,000 per year to operate and maintain the system,
 approximately 570,000 per year for power, and approximately 5120,000 per year for project
 oversight.

 ADDITIONAL SOIL INVESTIGATION (November 1995)
 On November 20, 1995, NAES performed field screening of Site 28 soil.at 12 locations with the
 assistance of representatives from the NJDEP and the USEPA. The results of the field screening
 indicated the continued presence of moderate levels of volatile organics in subsurface soil. The
 extent of the remaining subsurface soil contamination is limited to the area of the original gasoline
 leak at the comer of Building 308 and approximately 30-40 feet in the northeasterly direction.

 INVESTIGATION SUMMARY
 A Remedial Investigation at Site 28 had revealed the existence of groundwater contamination. The
 table on page 9  provides a  summary of volatile organic contaminants detected, above applicable
 EPA or State groundwater standards.

 Subsequent investigations conducted at the Site  in  July and August 1990  revealed a leak in
 subsurface gasoline piping running  from a 300 gallon above-ground gasoline tank into Building
 308. The leak, which is believed to be the source of volatile organic contamination at the Site, was
 repaired.  The  underground  piping was later replaced with above ground piping.  Following the
 detection and repair of the leak, during the period 9-13 August 1990, a soil removal action was
 implemented at the Site. All visually contaminated soil was removed for proper disposal off-base.

 On September  16, 1991, an  interim Record of Decision was issued by the Navy and USEPA for
 recovery and treatment of groundwater at  Site 28.  The NJDEP also concurred with the interim
 Record of Decision.

 Based on the results of the  interim remedial action for groundwater, it appears that the existing
 system is not capable of remediating the groundwater contamination to meet applicable or relevant
and appropriate requirements (ARARs). It appears that the higher levels of contamination located at
the source area continue to be a source of the low levels of groundwater contamination throughout
the site.  Modifications to the  groundwater recovery system will allow the highest levels ("hot
 spots") of contamination to be captured for remediation. Refer to the Feasibility Study for Site 28
groundwater for additional information concerning treatment system performance.

Additional remedial actions will be implemented as part of the final alternative for Site 28 to reduce
source area soil and groundwater contamination.

-------
                         Volatile Organic Compounds Detected in Groundwater
                            Which Exceeded EPA MCLs and/or NJDEP PQLs
Contaminant




Benzene
Ethylbenzene
Toluene
Xylenes
Bromodichloroethane
Chloroform
Tetrachloroethane
1,1.1 -Trichloroethane
Highest Detected
Concentration
During Remedial
Investigation
(ug/1)
880
1100
5100
12,000
ND
ND
ND
ND
Highest Detected
Concentration
During Operation of
Interim Treatment
(ug/1)
6
1100
1400
7900
4
19
54
5
Latest
Sampling
Round
(October 1 996)
(ug/1)
ND
70
63
1130
ND
ND
ND
ND
EPA
MCL
(ug/1)


5
700
1000
10,000
-
100
5
200
NJDEP
PQL
(ug/1)


1
5
5
->
1
1
1
1
• These compounds were detected during the beginning of treatment system operation and may be due to the use of sodium hypochiorite ror
sretreatment. This chemical has been removed from use and these chemicals have not been detected in Site 28 monitoring wells since March
MCL - maximum contaminant levels
PQL - practical quantitation levels
\D-noi detected
Primary Maximum Contaminant Levels (MCLs) are Federally enforceable contaminant levels allowable in public dnnkinz water supplies.  The>
have been established from health-based data by EPA's Office of Drinking Water Regulations (40 CFR I -! I) established under the authority ot the
Sate Drinking Water Act. MCLs are periodically revised as more information becomes available. When MCLs are not available, proposed \\CLf
« enr used as '.he comparison criteria for some analytes.

On  13 January 1.993. the revised N J.A.C. 7:9-6 which includes the Groundwater Quality Criteria was signed. The criteria establish the arouneuater
v';2isiticaiions tor the Pinelands. including Class I-PL (Preservation Area) and Class I-PL (Protection Areai. The actual groundwater catena are -.he
natural quality and background quality, respectively (N.J.A.C. 7:9-6.7). However, for some constituents natural quality is orien much lower than car.
be measured in a laboratory, therefore, some measureable criteria are necessary to determine compliance. Practical Quantitation Levels (PQLs) are
ihe  lowest concentration of a constituent that can be reliably achieved among laboratories w ithin specified limits of precision and accuracy dur.r.g
routine laboratory operating conditions. PQLs will be used to determine compliance with groundwater quality criteria for Class I-PL £round«ater.

-------
 HIGHLIGHTS OF COMMUNITY PARTICIPATION

 The Proposed Plan for Site 28 was issued to interested parties on December 30, 1996. On
 December 21 and 22, 1996, a newspaper notification inviting public comment on the Proposed
 Plan appeared in The Ocean County Observej and The Asbury Park Press. The comment period
 was held from January 7, 1997 to February 7, 1997. The newspaper notification also identified
 the Ocean County Library as the location of the Information Repository.

 A Public Meeting was held on January 15,1997 at the Manchester Branch of the Ocean County
 Library from 6:00 to 8:00 p.m. At this meeting representatives from the Navy, USEPA and
 NJDEP were available to answer questions concerning Site 28 and the preferred alternative. The
 attendance list is provided in this Record of Decision as Appendix A.  Comments received and
 responses provided during the public hearing are included in the Responsiveness Summary,
 which is pan of this Record of Decision. A transcript of the meeting is available as part of the
 Administrative Record.

 During the public comment period from January 7, 1997 through February 7, 1997, no written
 comments were received from the  public pertaining to Site 28. On February 4, 1997, the NJDEP
 submitted additional written comments to the Proposed Plan for Site 28. The Proposed Plan was
 revised to include these comments. A copy of the final Proposed Plan for Site 28. dated
 February 5, 1997, has been placed in the Administrative Record for NAES located at the Ocean
 County Library, Toms River NJ.

 This decision document presents the selected alternative (i.e., continued groundwater treatment
 and sparge/vapor extraction) for Site 28, chosen in accordance with CERCLA, as  amended by
 SARA and, to the extent practicable, the National Contingency Plan (NCP).  The decision for
 Site 28 is based on the information contained in the Administrative Record, which is available
 for public review at the Ocean County Library, 101 Washington Street, Toms River, New Jersey.

 SCOPE AND ROLE OF RESPONSE ACTION

 Studies conducted at Site 28 had shown that the groundwater and soil in this area had been
 contaminated with gasoline as a result of a leaking subsurface pipe coupling. The Navy
 implemented interim remedial actions to address the contamination prior to the implementation
of a final action which is described in this document.

GROUNDWATER REMEDIAL ACTIONS
Based on the levels of contamination detected in Site 28 groundwater during Phase I and II of the
 Remedial Investigation, an interim Focused Feasibility Study (April 29,  1991) was prepared to
evaluate alternatives for controlling the migration of contaminated groundwater. The 1991 Site 28
 Focused Feasibility Study indicated  that the implementation of an interim action consisting of
groundwater pumping,  treatment  and  recharge would  be most effective  at  containing the
groundwater contaminants.

                                          10

-------
 An interim Record of Decision was issued on September  16. 1991.  This decision document
 presented the selected remedial action for Site 28.  Documentation supporting the interim action
 conducted at Site 28 can be found in the Administrative Record for the NAES, at the Ocean County
 Library in Toms River, NJ.

 The decision to recover and treat groundwater at Site 28 was made to protect human health and the
 environment by preventing the further migration of groundwater contamination.   This document
 summarizes all remedial actions taken to remediate Site 28 soil and groundwater and evaluates
 alternatives necessary to meet ARARs for all media.

 SOIL REMOVAL ACTION
 On August 8,  1990, a gasoline leak was discovered and repaired at Site 28.  During the period
 August 9-13, eight test pits were dug in the area northeast of Building 308 to identify the extent of
 soil contamination caused by the leak.  Based on observations made in these test pits, soil was
 excavated from  an area measuring approximately 60 ft. long, 20-40 ft. wide and 7-8 ft. deep. Of the
 excavated soil,  approximately 65 cubic yards of visually contaminated soil was  segregated and
 transferred to a nearby on-site hazardous waste storage  area for disposal at an approved  off-site
 facility.

 SUMMARY OF SITE RISKS

 In April 1992, an overall endangerment assessment for NAES was conducted.  Based on available
 information, NAES was considered to be a potential public health concern because of the risk to
 human health caused  by the possibility of exposure to hazardous  substances via contaminated
 groundwater, soil, sediment, and surface water.

 SITE 28 RISK.
 This is a summary of the Endangerment  Assessment (EA) addendum findings for Site 28.   The
 assessment of this site was conducted using all available data generated during previous remedial
 investigations (RI). This summary will discuss (1) the chemicals identified by the EA addendum as
 contaminants of concern (COCs), (2) the land use assumptions upon which estimates of potential
 human exposure to site contaminants are based, (3) the quantitative estimates of carcinogenic risk
 and noncarcinogenic hazard, and (4) a summary interpretation of the EA findings with regard to
 need for site remediation.

CONTAMINANTS OF CONCERN
 For Site 28, contaminants of concern were determined to be the following: Benzene, Ethylbenzene.
Toluene, Xylenes, 2-Methylnaphthalene and Naphthalene.

LAND USE AND EXPOSURE ASSUMPTIONS
Four different scenarios representing current and potential future land uses were evaluated to assess
applicability to  the .site.  Evaluated scenarios included military, light industrial, construction and

                                          11

-------
 residential land uses. For each of these scenarios, human exposure is effected by mechanisms that
 include direct contact, inhalation and ingestion.

 Based on current land use conditions within Site 28, a light industrial  land use scenario  was
 quantified for direct exposure to contaminated groundwater via incidental ingestion.

 Although future  residential land use  conditions  were  not investigated as part of  the  risk
 characterization  for  Site 28, groundwater  cleanup  levels  are based .on residential  land  use
 assumptions.

 HUMAN HEALTH RISK AND HAZARD FINDINGS
 Based on the highest levels of contaminants found at Site 28, the Hazard Index for noncarcinogens
 is 0.45  which is below the EPA's  Hazard Index criteria value of 1.0.  The Hazard Index values
 ranged  from  a minimum value of 2.93 X 10"" for naphthalene to a maximum of 2.5 X 10'' for
 toluene. Carcinogenic risk estimates for groundwater in Site 28 are within EPA's acceptable  risk
 range of 1 X  10"4 to 1 X lO^and above New Jersey's acceptable risk of 1 X 10"6. The overall area
 groundwater risk represented by the sum of the chemical-specific risk estimates  is 8.92  X 10°.
 Benzene was the only compound that contributed to the carcinogenic risk.

 Based on the highest levels of contaminants detected since the interim remedial action was
 implemented at Site 28? hazards for noncarcinogens are 0.25 which is below the EPA's Hazard
 Index criteria value of 1.0.  The hazard index values ranged from a minimum value of 2.93 X  10'"
 for naphthalene to a maximum of  1.08 X  10"'  for ethylbenzene.  Carcinogenic risk estimates for
 groundwater at Site 28 are below EPA's acceptable risk range of 1 X lO"1 to 1 X 10"6 and New
 Jersey's acceptable risk of 1 X 10"6. The overall area  groundwater risk represented by the sum of
 the chemical-specific risk  estimates is  6.08 X  10" .  Benzene  was  the only  compound that
 contributed to the carcinogenic risk.

 These risk numbers are based on non-residential assumptions. If residential assumptions are used.
 the risk  numbers would be higher and may fall out of the EPA acceptable risk range.

 ECOLOGICAL ASSESSMENT
 As part  of the Endangerment Assessment, a Baseline Ecological Evaluation (BEE) was conducted
 to obtain a description of the ecosystems at NAES. Currently, it does not appear that groundwater
 is having an  impact on the ecology of the Site.  Flow net analysis indicates that although  some of
 the site  groundwater discharges into the Paint Branch, most of the groundwater flows under the
 Paint Branch in an easterly direction. There are no other potential exposure pathways to ecological
 receptors identified for Site 28.

 ENDANGERMENT SUMMARY
 In summary, the results of the EA indicate that contaminants present in groundwater at Site 28 may
pose a concern relative to current and potential future exposed populations.  Therefore, alternatives
 for the remediation of soil and groundwater contamination at this Site are warranted.

                                           12

-------
SUMMARY OF REMEDIAL ALTERNATIVES

Under CERCLA, the alternative selected must be protective of human health and the environment,
in accordance with statutory requirements and cost effective. Permanent solutions to contamination
are to be achieved wherever possible.   The remedial alternatives considered  for the site are
summarized below.  Detailed descriptions of the remedial alternatives can be found in the FFS
(July  1996), which is available in the Administrative Record for NAES.  .

All the alternatives presented include the establishment of a classification exception area (CEA)
pursuant to N.J.A.C. 7:9-6.6.

The alternatives  1G  through 5G are  the final remedial alternatives for groundwater.   The
alternatives 1S  through 4S are the final  remedial alternatives for soil.  The final remedial action
conducted at Site 28 will involve the combination of groundwater and soil remedial actions.

ALTERNATIVE SUMMARY - GROUNDWATER TREATMENT

ALTERNATIVE 1G: NO ACTION

Estimated Construction Cost: S 69,100
Estimated Net O&M Cost: S 0
Estimated Implementation Time Frame: immediately

The groundwater contamination present at Site 28  is the result of a past gasoline leak which
occurred at the site.  The leaking pipeline  was removed.  However, soil which may be contaminated
at Site 28 may still provide a source of contamination for groundwater. This alternative involves no
action to control or remove contamination at Site 28.  Under this alternative, the existing treatment
of groundwater would  be discontinued and the equipment abandoned or removed.

This alternative has been included to provide a baseline for the comparison of other alternatives.

ALTERNATIVE 2G:  NATURAL REMEDIATION/GROUNDWATER  MONITORING -
DISCONTINUE EXISTING GROUNDWATER TREATMENT

Estimated Cost: S 164,100
Estimated Net O&M Cost: S 82,600/yr
Estimated Implementation Time Frame: 1 year

This  alternative  involves groundwater  monitoring of the aquifer and  study  of the natural
remediation processes  occurring within the Site. The existing groundwater treatment system would
be discontinued.  Extensive monitoring of the plume extent and migration would be monitored
through the existing well network and additional monitoring wells if  necessary.  Contaminants

                                         13

-------
 would not be treated but would be allowed to reduce naturally. The natural remediation occurring
 at the site would be studied to determine if the microorganisms at the site have the potential to
 degrade the VOCs to harmless products.

 Under this alternative, no further action to control the source would be taken.

 Additional costs  involve the installation of up  to 5 additional monitoring wells and an initial
 restoration study to prove that this process will effectively remediate the. Area  Yearly operation
 and maintenance costs include quarterly sampling and analysis and project oversight.

 ALTERNATIVE  3G:     EXISTING  RECOVERY  SYSTEM  WITH  POTENTIAL
 MODIFICATIONS TO TREATMENT SYSTEM

 Construction Cost: S 1.3 million
 Estimated Additional Construction Cost: S 0
 Estimated Net O&M Cost: S 443,000/yr
 Estimated Implementation Time Frame: already implemented

 This alternative involves groundwater pumping from the existing downgradient recovery well RW-
 1.  This well is pumped at 40 gallons per minute (gpm).  A recovery well located at the source area
 (RW-2) will continue to be pumped at 60 gpm.  Figure 3 provides the location of existing treatment
 system and recovery wells.  The pumping rates of the two recovery  wells may be adjusted to
 optimize groundwater contaminant capture based upon continuing evaluation during system O&M.

 At the existing treatment facility, a tank serves as an initial flow equalizer. A pretreatment unit is
 used for metals, free product and solids removal.  Air stripping columns and granular activated
 carbon polishing  filters  are used to  treat the volatile organic contaminants  in the extracted
 groundwater.  The air stripper emissions are treated by granular activated carbon air filters and
 clean air is discharged to the atmosphere. Treated groundwater which meets Primary Safe Drinking
 Water Standards is recharged to the aquifer via spray irrigation during temperate months and  is
 infiltrated back into the aquifer through an underground piping system during winter months. The
 treated water  is discharged upgradient of the recovery wells to form a closed-loop system.  The
 construction cost  provided for this alternative was the cost to build  the existing facility.  No
 additional construction cost would be incurred under this alternative.

 Natural remediation processes occurring  at  the Site  would  also be considered  part of this
 alternative.

Modifications to the sampling frequency would be included under this alternative.  Based on
previous sampling results, it is appropriate to reduce the frequency of sampling.  The sampling of
monitoring wells will be reduced from quarterly to biannually for VOCs and annually for SVOCs
and metals.  The frequency  of sampling for  semi-volatile organic  compounds in the treatment
process will also be reduced to annually for system influent and quarterly for system effluent. The

                                           14

-------
 following modifications may also be implemented based on future influent data from the recovery
 system.

 MODIFICATIONS TO TREATMENT
 Under this alternative, three potential modifications  to the existing treatment  system  will be
 developed individually. Costs associated with each should be considered additional to those shown
 in Alternative 3G.

 The individual  development presented  here is conducted to  aid  any  future decision  making
 processes which center on treatment system optimization.

 Treatment system modifications could include one or several of the following alternatives.

 ALTERNATIVE 3GT1 ELIMINATION OF pH ADJUSTMENT FOR TREATMENT
 Sodium hydroxide is currently used in the Site 28 treatment process for pH adjustment. The pH of
 the plant influent is raised to allow metal hydroxides to precipitate out of solution.  The use of this
 chemical is currently increasing the sodium content in the Area groundwater. Under this alternative
 the reduction and possible elimination of pH adjustment would be investigated. The cost savings
 resulting from the elimination of sodium hydroxide for treatment would be approximately S4000
 per year. However, this change would not be made to save money but to eliminate the introduction
 of sodium into Area groundwater.  The effects of this  change on treatment system performance
 would be investigated to determine implementabiliry.

 ALTERNATIVE 3GT2 ELIMINATION OF PRETREATMENT
 If contaminant levels entering the treatment facility do not increase above the existing levels, once
 the recovery  well at  the  source area is  operating,  the elimination of pretreatment will be
 investigated. This would involve the elimination of oxidation/flocculatioa'precipitation.   These
 processes are currently used at Site 28 to remove metals and solids from the system influent.  The
 elimination of pretreatment  may cause excessive iron to buildup in air strippers and carbon units.
 The precipitated  iron may also block subsurface infiltration piping.  The cost to  implement this
 alternative would be approximately S5000 to redirect system piping.  Additional costs  would be
 incurred based on how much iron impacts the treatment and infiltration systems.

 ALTERNATIVE 3GT3 OPEN AERATION TO TREAT GROUNDWATER
 Based on the existing levels of VOCs in the treatment system influent, controls on air emissions are
 not required. If the influent levels from the replacement recovery wells to be installed continue to
 meet these requirements, the use of alternate open aeration treatment would be investigated.  The
use of this technology would require no pretreatment  of groundwater.   However, the level of
contaminants  entering the  system  would  have to meet the NJDEP  air pollution  control
requirements.  The discharge requirements would have  to meet applicable  Federal and State
requirements.  The cost to implement this type of treatment varies depending on the type of open
aeration system chosen.
                                          15

-------
 If the use of open aeration is implemented, the use of surface infiltration basins may be required to
 return treated water back to the aquifer. This type of discharge system would be more capable of
 handling precipitated iron than subsurface infiltration since the basins are more easily maintained.

 If system modifications are implemented, an air permit equivalency would be obtained from the
 NJDEP if required.

 ALTERNATIVE 4G: MODIFICATIONS TO RECOVERY AND TREATMENT SYSTEM

 Estimated Construction Cost: S 1.3 million
 Estimated Additional Construction Cost: S 75,600
 Estimated Net O&M Cost: S 443,000/yr
 Estimated Implementation Time Frame: 1 year

 This alternative would utilize the existing treatment system, however changes in recovery  well
 locations or pumping intervals would be implemented.  Modifications to the existing groundwater
 recovery system would be made based on the results of the interim treatment system performance
 and quarterly data and additional modeling conducted in February 1996.

 An additional recovery  well would be  installed  near MW-1.  which  appears to  be  in  the
 downgradient direction of the plume, to enhance plume recovery and limit migration. RW-1 would
 be pumped at a reduced rate or pumping would be discontinued based on monitoring results once
 the new well has begun pumping.  The construction cost provided for this alternative was the cost
 to build the existing facility.  An additional construction cost of S75.600 would be incurred under
 this alternative.

 Natural remediation processes occurring at the  Site would also be considered part of this
 alternative.

 Modifications to the sampling frequency would also be included as part of this alternative. Based
 on previous sampling results, it is appropriate to reduce the frequency of sampling. The sampling
 of monitoring wells will be reduced from quarterly to biannually for VOCs and annually  for
 SVOCs and metals.   The  sampling  of deep monitoring wells  that have  not detected  any
 contamination may be  discontinued.   The  frequency of sampling  for semi-volatile  organic
 compounds  in the treatment process will also be reduced to annually for system influent and
 quarterly for system effluent.

 ADDITIONAL MODIFICATIONS TO TREATMENT
 Under  this  alternative, three potential modifications to  the  existing treatment  system  will  be
developed individually. Costs associated with each should be considered additional to those shown
 in Alternative 4G.
                                           16

-------
 The individual development presented here is  conducted  to aid any  nature decision making
 processes which center on treatment system optimization.

 The influent data from the recovery  system proposed  as  alternative 4G will be reviewed to
 determine if modifications to the current treatment system are possible. These modifications could
 include one or several of the following alternatives.

 ALTERNATIVE 4GT1  ELIMINATION OF pH ADJUSTMENT FOR TREATMENT
 Sodium hydroxide is currently used in the Site 28 treatment process for pH adjustment.  The pH of
 the plant influent is raised to allow metal hydroxides to precipitate out of solution. The use of this
 chemical is currently increasing the sodium content in the Area groundwater.  Under this alternative
 the reduction and possible elimination of pH adjustment would be investigated.  The cost savings
 resulting from the elimination of sodium hydroxide for treatment would be approximately S4000
 per year. However, this change would not be made to save money but to eliminate the introduction
 of sodium into Area groundwater.  The effects of this change on treatment system performance
 would be investigated to determine implementability.

 ALTERNATIVE 4GT2 ELIMINATION OF PRETREATMENT
 If contaminant levels entering the treatment facility do not increase above the existing levels, once
 the new recovery scenario is implemented, the elimination of pretreatment will be investigated.
 This would involve the elimination of oxidation/flocculation/precipitation.  These  processes are
 currently used at Site 28 to remove metals and solids from the system influent.  The elimination of
 pretreatment may cause excessive iron to buildup in air strippers and carbon units. The precipitated
 iron may also block subsurface infiltration piping. The cost to implement this alternative would be
 approximately S5000 to redirect system piping. Additional costs would be incurred based on how
 much iron impacts the treatment and infiltration systems.

 ALTERNATIVE 4GT3 OPEN AERATION TO TREAT GROUNDWATER
 Based on the existing levels of VOCs in the treatment system influent, controls on air emissions are
 not required. If the influent levels from the new recovery wells to be installed under alternative 4G
 continue to meet these requirements,  the use of alternate open aeration treatment  would be
 investigated. The use of this technology would require no pretreatment of groundwater.  However,
 the level of contaminants entering the system would have to meet the NJDEP air pollution control
 requirements.  The  discharge requirements  would have to meet applicable  Federal  and State
 requirements. The cost to implement this type of treatment varies depending on the type of open
 aeration system chosen.

 If the use of open aeration is implemented, the use of surface infiltration basins may be required to
 return treated water back to the aquifer.   This type of discharge system would be more capable of
handling precipitated iron than subsurface infiltration since the basins  are more easily maintained.

If system modifications are implemented, an air permit equivalency would be obtained from the
NJDEP  if required.

                                          17

-------
 ALTERNATIVE SG:  GROUNDWATER SPARGING

 Estimated Construction Cost: 582,600 (includes vapor extraction)
 Estimated Net O&M Cost: $58,400/yr (includes vapor extraction)
 Estimated Implementation Time Frame: I year

 This  alternative would involve the modeling, design and construction of a  groundwater sparge
 system within the upgradient higher area of groundwater contamination- at Site 28.  This sparge
 system would be designed and constructed in conjunction with a vapor extraction system which is
 proposed as a remedial alternative for soil.  The systems would be  designed to remediate both
 groundwater and soil contamination at the "source" area and eliminate the continuing source of
 groundwater contamination.

 The abandonment of the present groundwater treatment system would be considered based upon
 the performance of the sparge system.

 System performance would be monitored through scheduled monitoring well and  soil  vapor
 sampling.

 ALTERNATIVE SUMMARY - SOIL TREATMENT

 ALTERNATIVE IS: NO ACTION

 Estimated Construction Cost: S 0
 Estimated Net O&M Cost: S 0
 Estimated Implementation Time Frame: N/A

 This alternative involves no action to control or remove contamination at Site 28. The existing soil
 contamination would continue to act as a source of groundwater contamination.

 This alternative has been included to provide a baseline for the comparison of other alternatives.

 ALTERNATIVE 2S: NATURAL REMEDIATION

 Estimated Cost: S 164,100 (included as part of Alternative 2G)
 Estimated Net O&M Cost: S 82,600/yr
 Estimated Implementation Time Frame: I year

This alternative involves no additional interim actions at Site 28 other than  monitoring of soil
contaminant levels and study of the natural remediation processes occurring. Contaminants in soil
would not be treated but would be allowed to reduce naturally. The natural remediation occurring
 at the site  would be studied to determine if the  microorganisms at the site have the potential  to
degrade the VOCs'to harmless products.

                                         18

-------
 Under this alternative, no further action to control the source would be taken.

 Yearly operation and maintenance costs include quarterly sampling and analysis of soil within the
 source area and project oversight.

 ALTERNATIVE 3S: EXCAVATION/RECYCLING OF CONTAMINATED SOIL

 Estimated Construction Cost: S 21,000
 Estimated Net O&M Cost: S 0
 Estimated Implementation Time Frame: 3 months

 Based on additional soil sampling conducted at Site 28, the area of soil contamination appears to be
 limited to the corner of Building 308 where  the gasoline leak occurred.  Elevated  levels were
 detected  six  feet below the  ground surface to the  water table  which was encountered  at
 approximately 7.5 feet. The estimated quantity of soil to be excavated for recycling is 25 ydj. The
 area of contamination is located next to and possibly beneath the northeast comer of building 308.
 Therefore, excavation would require bracing and support of the structure.

 ALTERNATIVE 4S: VAPOR EXTRACTION

 Estimated Construction Cost: $82,600 (includes groundwater sparging)
 Estimated Net O&M Cost: S58,400/yr
 Estimated Implementation Time Frame: 1 year

This alternative involves the installation of a vapor extraction system at the area of remaining soil
contamination at Site 28.  The system would be designed in combination with a groundwater sparge
 system to remediate both groundwater and soil contamination \v ithin the higher level "source" area.

 EVALUATION OF ALTERNATIVES

During the entailed evaluation of remedial alternatives, each alternative is assessed against the nine
evaluation criteria which are summarized below.

 1.     Overall Protection  of Human Health and The Environment draws on the assessments
      conducted under other evaluation criteria and  considers  how the alternative addresses site
      risks through treatment, engineering, or institutional controls.

2.     Long-Term Effectiveness and Permanence evaluates the  ability of an alternative  to
      provide long term protection of human health and the environment and the magnitude  of
      residual risk posed by untreated wastes or treatment residuals.
                                          19

-------
 3.      Reduction  of Toxicity,  Mobility or  Volume  Through  Treatment  evaluates  an
        alternative's ability to reduce risks through treatment technology.

 4.      Short-Term  Effectiveness  addresses the cleanup time frame and any adverse impacts
        posed by the alternative during the construction and implementation phase, until cleanup
        goals are achieved.

 5.      Implementability is an evaluation of the technical feasibility, administrative feasibility.
        and availability of services and material required to implement the alternative.

 6.      Cost includes an  evaluation of capital  costs, annual operation and maintenance (O&M)
        costs.

 7.     Compliance With ARARs  evaluates the ability of an alternative to meet Applicable  or
       Relevant and Appropriate Requirements (ARARs) established through Federal and State
       statutes and/or provides the basis for invoking a waiver.

 8.     Agency  Acceptance indicates the EPA's and the  State's response to the alternatives in terms
       of technical and administrative issues and concerns.

 9.     Community Acceptance evaluates the issues and concerns the public may have regarding
       the alternatives.

 The first two criteria, protection of human health and the environment and compliance with
 Applicable or Appropriate Requirements (ARARs) are considered by the EPA to be threshold
 criteria which each alternative must meet. The next five  are balancing criteria, and the final two are
 considered modifying criteria.
ANALYSIS OF ALTERNATIVES

COMPARATIVE ANALYSIS OF ALTERNATIVES - GROUNDWATER

Overall Protection of Human Health and Environment -
Alternative 4G provides overall protection of human health and the environment through treatment
of both  higher and downgradient groundwater contaminant areas and extensive monitoring.  An
additional downgradient recovery well will be installed to remove and treat downgradient lower
levels of contamination.

Alternative 3G provides protection of human health and the environment through continuation of
existing treatment of groundwater and extensive monitoring.
                                          20

-------
 Alternative 5G provides protection of human health and the environment through treatment of areas
 of higher levels of groundwater contamination.

 Alternative 2G, which offers no groundwater treatment, may provide protection of human health
 through extensive monitoring of groundwater migration and natural remediation.

 Alternative 1G, which offers no groundwater treatment or monitoring, is not protective.

 Long-Term Effectiveness and Permanence -
 Alternative 4G provides an effective and permanent option for protection of human health and the
 environment  through  removal and treatment  of  both  higher and  downgradient  levels  of
 contamination.   Long  term permanence  is  ensured since monitoring wells throughout and
 downgradient of the plume are monitored until all levels within the plume have been reduced below
 ARARs.  The estimated time for this alternative to meet ARARs through the combined effects of
 treatment and natural remediation is approximately 5 years.

 Alternative 5G will accelerate  the  remediation of contaminated groundwater  and remove  the
 continued source of groundwater contamination.

 Alternative 3G would  provide long-term  protection  of human health through the removal and
 treatment of higher levels of contamination.  The estimated time for this alternative to meet ARARs
 through the combined effects of treatment and natural remediation is approximately 5 years.

 Alternative 2G provides no active treatment and is not considered to be effective at remediating the
 aquifer.  The current levels of contamination appear to be  too high for natural remediation  to
 effectively control contaminant migration.  This alternative would be effective toward the closing
 stages of remediation when pumping is no longer an effective option.

 Alternative 1G provides no treatment and is not considered effective.

 Reduction of Toxicity, Mobility or Volume Through Treatment -
 Alternative 4G  recovers and treats the largest area of contamination.  The toxicity, mobility and
 volume are reduced through capture and treatment of the plume.

 Alternative 3G recovers and treats contamination at  the source area and as it migrates  to the
 existing downgradient recovery well.

 Alternative 5G volatilizes the higher area of contamination for recovery and removal through vapor
extraction.

Alternative Nos. 1G and 2G offer no reduction of toxicity, mobility or volume through treatment of
the contaminated media.
                                           21

-------
 Short-Term Effectiveness -
 Remedial action Alternatives 3G and 4G in the short-term, would halt the continued migration of
 contaminated groundwater downgradient of residual source areas.  The estimated cleanup duration
 for Alternative 3G or Alternative 4G is approximately 5 years to reach ARARs.  The predictions for
 these alternatives are only applicable if combined with an alternative to remove soil contamination.
 Otherwise, cleanup will take much longer.

 Alternative 5G would be effective in the short term at accelerating the rate of contaminant removal.
 Modeling has not been conducted to determine the time to reach  ARARs under this alternative.
 However, it is believed that the implementation of a sparge system can achieve ARARs in less than
 5 years.

 Alternative 2G is effective at monitoring the movement of contamination but would not prevent the
 short term migration of contamination. This alternative would achieve ARARs in 10-15 years.

 Alternative 1G provides no treatment of groundwater and is not considered to be effective in the
 short-term  because residual risks are not reduced. This alternative would achieve ARARs in  10-15
 years.

 Implementability -
 Alternative 1G offers the  greatest implementabiliry.  This alternative involves the shutdown of the
 existing treatment facility and  no further action.

 Alternative 3G is the  current  interim remedy. This alternative requires continued operation  and
 maintenance of the existing treatment facility.

 Alternative 2G involves the shut down of treatment and continued monitoring of the aquifer. This
 alternative  can be implemented in several  months with  the initiation of a study to determine the
 natural remediation occurring  within the aquifer.

 Alternative 4G would be more  difficult to implement  due to the construction of an additional
 recovery well and associated piping.

 Alternative 5G would involve  the design and construction of a small scale sparge system.

Cost-
Altemative 1G, the no action alternative, has the lowest associated cost. Alternative 2G the natural
 remediation/long-term monitoring alternative has the second lowest cost.  The cost for Alternative
3G involves operation and maintenance costs only and is therefore the lowest cost treatment option.
Alternative 4G involves the construction of additional groundwater recovery wells.  Alternative 5G
 involves the design and construction of a groundwater sparge system.

Compliance with ARARs -

                                            22

-------
 EPA considers drinking water Maximum Contaminant Levels (MCLs) and because of the location
 of NAES within the Pinelands, State Water Quality Standards for Class I-PL areas, which default to
 Practical Quantitation Levels (PQLs), whichever is more stringent for each contaminant of concern.
 to be ARARs.

 Alternative 1G does not comply with ARARs because no remedial action takes place. Alternative
 2G  will not reduce contamination  to meet ARARs in  a reasonable  time frame before  the
 contamination migrates to areas that could potentially harm human health and the environment.
 Alternatives 3G, 4G and 5G are designed to meet ARARs. Alternative 5G would accelerate the
 remediation of groundwater and allow for a more rapid attainment of ARARs.

 It is estimated that under alternatives 3G and 4G ARARs would be  attained in 5 years.   With the
 addition of a sparge system under alternative 5G ARARs would be achieved in less than 5 years.

 An air permit equivalency would be obtained from the NJDEP, if required,  for modifications to
 existing systems or additional treatment systems to be installed.

 Agency and Community Acceptance -
 Agency and  Community Acceptance are addressed in the  Responsiveness Summary of this
 document.
COMPARATIVE ANALYSIS OF ALTERNATIVES - SOIL

Overall Protection of Human Health and Environment -
Alternative 3S provides overall protection of human health and the environment through removal of
contaminated soil which may be acting as a continuing source of groundwater contamination.
Alternative 4S provides overall protection of human health and the environment through treatment
of both groundwater and soil contamination within the higher area of contamination.

Alternative 2S,  offers  protection of human health  and the environment through long-term
monitoring. Contaminant reduction would take place over time through natural remediation.

Alternative IS, which offers no contaminant treatment or  monitoring,  is the least protective
alternative.

Long-Term Effectiveness and Permanence -
Alternative 3S provides the overall most effective and permanent options for protection of human
health and the environment through removal of higher levels of soil contamination. Alternative 4S
provides long-term effectiveness through treatment of  soil  and groundwater.  There is a bias for
treatment of contamination over removal.
                                          23

-------
 Alternative 2S may provide long-term permanence through natural remediation of the sites.  This
 alternative would provide long-term protection of human health through long-term monitoring until
 ARARs are met through natural remediation.

 Alternative IS provides no active treatment and is not considered to be effective at remediating the
 soil.  The current levels of soil contamination may  still be impacting groundwater conditions at the
 sites. This alternative provides no long-term effectiveness.

 Reduction of Toxicity, Mobility or Volume Through Treatment-
 Alternative 4S reduces the toxicity, mobility and volume of contamination through recovery and
 treatment of contamination in Site 28 soil and groundwater.

 Alternative 3S would reduce toxicity, mobility or volume through treatment.  The  contaminated
 soil would be excavated and removed from the Site for recycling.

 Alternative IS and 2S offer no reduction of toxicity, mobility or volume through treatment of the
 contaminated media

 Short-Term Effectiveness -
 Remedial action Alternatives 3S and 4S in the short-term, would remove the continued source of
 groundwater contamination through treatment or removal of soil contamination.

 Alternatives 2S and IS are not effective at reducing contamination in the short term.

 Implementability -
 Alternative IS consists of no action and is easily implementable.

 Alternative 2S would involve the implementation of a natural remediation study and continued soil
monitoring.

Alternative 3S involves excavation and post excavation sampling. To implement this alternative, a
shoring system would have to be designed for Bldg. 308 to prohibit settling of the structure during
excavation.

Alternative 4S  involves  the   modeling,  design   and- construction  of  a small  scale  vapor
extraction/sparge system to treat the elevated "source" area of contamination.

Cost-
Altemative No. IS, the no action alternative, has the lowest associated cost.  Alternative No. 2S, the
restoration alternative, has the second lowest cost which includes study and additional  sampling.
Alternative 3S involves cost for excavation, disposal, post excavation sampling and shoring.
Alternative 4S includes costs  for modeling, design, vapor extraction system  construction  and
continued monitoring.

                                           24

-------
 Compliance with ARARs -
 There are no ARARs for soil contamination, however, the New Jersey Soil Cleanup Criteria are to
 be considered (TBC) criteria, particularly the Impact to Groundwater Criteria.

 Alternative No. IS does not attain ARARs because no remedial action takes place. Alternative No.
 2S does not actively remove or  treat contamination but would eventually meet TBCs through
 natural  remediation of contamination.  Alternatives 3S and 4S  are  designed to  remove  soil
 contamination and aid in groundwater remediation through active treatment or removal of residual
 soil source areas.

 An air permit  equivalency would be obtained from the NJDEP, if required, for modifications to
 existing systems or additional treatment systems to be installed.

 Agency and Community Acceptance -
 Agency and Community Acceptance will not be addressed in this document.
THE SELECTED ALTERNATIVE

The selected alternatives to address groundwater and soil at Site 28 are Alternatives 3G. 5G and 4S:
Existing   Recovery   System  with  Potential  Modifications   to  Treatment  and   Vapor
Extraction/Sparging.

The NAES  will  continue to operate the existing groundwater treatment  system.  Also, a
sparge/vapor extraction system will be designed and installed to accelerate the remediation of the
areas  of higher groundwater and soil contamination. Additional modifications (3GT1-3GT3) to
treatment are also included as part of the selected action and could be implemented based on future
system influent concentrations.

A classification exception area (CEA) will be established pursuant to N.J.A.C. 7.9-6.6.

The objectives of the selected action  are to:  1) protect human health and the environment by
reducing the downgradient migration of contaminated groundwater; 2) remediate source areas with
the highest  concentration of contaminants; and 3) ensure groundwater quality complies with
ARARs.
STATUTORY DETERMINATIONS

Under CERCLA, the alternative selected must protect both human health and the environment,
be cost effective and comply With statutory requirements.  Permanent solutions to contamination
problems are to be achieved whenever possible.

                                          25

-------
Based on the consideration of alternatives, Alternatives 3G, 5G and 4S have been selected as the
preferred alternatives to address the groundwater and soil at Site 28 for the following reasons:

 - The selected alternatives will provide protection of human health and the environment through
active treatment of both soil and groundwater. The remedial systems will be designed to meet
ARARs.  Extensive monitoring will be used to ensure protection of human health.

 - The treatment systems described in the selected alternative have already been implemented
and will continue to be operated with modifications made to enhance system performance.

 - The selected alternatives are cost effective.
                                          26

-------
                              RECORD OF DECISION
                           RESPONSIVENESS SUMMARY
                        SITE 28 SOIL AND GROUNDWATER
                       NAVAL AIR ENGINEERING STATION
 The purpose of this responsiveness summary is to review public response to the Proposed Plan
 for Site 28. It also documents the Navy's consideration of comments during the decision making
 process and provides answers to any comments raised during the public comment period.

 The responsiveness summary for Site 28 is divided into the following sections:

 OVERVIEW - This section briefly describes the remedial alternative recommended in the
 proposed plan and any impacts on the proposed plan due to public comment.

 BACKGROUND ON COMMUNITY INVOLVEMENT - This section describes community
 relations activities conducted with respect to the area of concern.

 SUMMARY OF MAJOR QUESTIONS AND COMMENTS - This section summarizes verbal
 and written comments received during the public meeting and public comment period.

 OVERVIEW

 Site 28 is located at the NAES in Ocean County, Lakehurst, New Jersey. This responsiveness
 summary addresses public response to the Proposed Plan, proposing continued operation of the
 existing groundwater treatment system with potential modifications to the treatment system to
 enhance system performance and vapor extraction/sparging to treat the source area.

 The Proposed Plan and other supporting information are available for public review at the
 information repository located at the Ocean County Library, 101 Washington Street. Toms River.
 New Jersey.

 BACKGROUND ON COMMUNITY INVOLVEMENT

 This section provides a brief history of community participation in the investigation and interim
 remedial planning activities conducted for Site 28. Throughout the investigation period, the
 USEPA and NJDEP have been reviewing work plans and reports and have been providing
 comments and recommendations which are incorporated into the appropriate documents. A
Technical Review Committee (TRC), consisting of representatives of the Navy, the USEPA, the
 NJDEP, the Ocean County Board of Health, the New Jersey Pinelands Commission, other
agencies and communities surrounding NAES was formed and has been holding periodic
meetings to maintain open lines of communication and to inform all parties of current activities.
                                        27

-------
 Prior to public release of site-specific documents, NAES's public relations staff compiled a list of
 local public officials who demonstrated or were expected to have an interest in the investigation.
 Local environmental interest groups were also identified and included on this list.  The list is
 attached as Appendix B to this Record of Decision.

 On December 21 and 22, 1996, a newspaper notification inviting public comment on the
 Proposed Plan appeared in The Ocean County Observer and The Asbury Park Press. The public
 notice summarized the Proposed Plan and the preferred alternative. The announcement also
 identified the time and location of a Public Meeting and specified a public comment period, and
 the address to which written comments could be sent. Public comments were accepted from
 January 7, 1997 to February 7, 1997.  The newspaper notification also identified the Ocean
 County Library as the location of the Information Repository.

 A Public Meeting was held on January 15, 1997, from 6:00 to 8:00 p.m. at the Manchester
 Branch of the Ocean County Library, Colonial Drive, Manchester, New Jersey. At this meeting
 representatives from the Navy, USEPA and NJDEP were available to answer questions
 concerning Site 28 and the preferred alternative.  NAES representatives present included: CAPT
 Leroy Fair, Commanding Officer; CAPT Michael Dougherty, Executive Officer; Robert
 Kirkbright, Director of Public Works Engineering; Lucy Bottomley, Supervisory Environmental
 Engineer; and Environmental Branch personnel: Dorothy Peterson, Greg Bury, Ray Hahn, Jill
 Sarafin, Bob Previte, Michael Figura, Carol Uhrich, Larry  Lemig, Bill Korosec, and Joe Rhyner:
 and Carole Ancelin, Public  Affairs Officer.  Mr. Jeff Gratz, represented the USEPA's Federal
 Facility Section; Ms. Donna Gaffigan represented the NJDEP's Bureau of Federal Case
 Management and Mr. Kevin Schick represented the NJDEP's Bureau of Environmental
 Evaluation and Risk Assessment. The complete attendance list is provided in Appendix A.

 SUMMARY OF MAJOR QUESTIONS AND COMMENTS

Written Comments

 During the public comment period from January 7, 1997 through February 7, 1997, no written
comments were received from ihe public pertaining to Site 28.

On February 4, 1997, the NJDEP submitted additional written comments to the Proposed Plan
 for Site 28.  The Proposed Plan was revised to include these comments. A copy of the final
 Proposed Plan for Site 28, dated February 5, 1997, has been placed in the Administrative Record
 for NAES located at the Ocean County Library, Toms River NJ.

 Public Meeting Comments

No questions or comments concerning Site 28 were received at the Public Meeting held on
January 15, 1997.  A transcript of the Public Meeting is provided in the Administrative Record at
the Ocean County Library, Toms River NJ.

                                         28

-------
           APPENDIX A

Attendance List for Public Meeting Held
          January 15,1997

-------
                   NAVAL AIR ENGINEERING STATION
                     Public Meeting January 15,1997

                           SIGN-IN  SHEET
NAME
ADDRESS (for future mailings)
HOW DID YOU HEAR
OF THE MEETING?
CIRCLE ONE
                                                              POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                               NEWSPAPER  MAIL
                                                             POSTERS  RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL
                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL

                                                             POSTERS RADIO
                                                              NEWSPAPER  MAIL

-------
                  NAVAL AIR ENGINEERING STATION
                     Public Meeting January 15,1997

                          SIGN-IN SHEET
NAME
ADDRESS (for future mailings)
HOW DID YOU HEAR
OF THE MEETING?
CIRCLE ONE
                                                           POSTERS  RADIO
                                                            NEWSPAPER  MAIL
                                                           POSTERS  RADIO
                                                            NEWSPAPER  MAIL
                                                           POSTERS  RADIO
                                                            NEWSPAPER  MAIL
                                                           POSTERS  RADIO
                                                            NEWSPAPER  MAIL
                                                          POSTERS  RADIO
                                                            NEWSPAPER  MAIL

                                                          POSTERS RADIO
                                                            NEWSPAPER MAIL
                                                          POSTERS RADIO
                                                            NEWSPAPER MAIL
                                                          POSTERS RADIO
                                                            NEWSPAPER MAIL
                         r/?  y  -  j.
                                                          POSTERS RADIO
                                                           NEWSPAPER MAIL
                                                          POSTERS  RADIO
                                                           NEWSPAPER MAIL
                                                          POSTERS  RADIO
                                                           NEWSPAPER MAIL

-------

-------
 updated 2-18-97
                                   APPENDIX B
                         LIST OF CONCERNED PARTIES
 Naval Air Engineering Station - Lakehurst

 Captain L. Farr                               (908) 323-2380
 Commanding Officer
 Naval Air Engineering Station
 Lakehurst, NJ 08733-5000

 Ms. Carole Ancelin, Public Affairs               (908) 323-2811
 Naval Air Engineering Station
 Lakehurst, NJ 08733-5000

 Commander Mike Murtha                      (908) 323-2601
 Public Works Officer
 Naval Air Engineering Station
 Lakehurst, NJ 08733-5000
Northern Division. Naval Facilities Engineering Command

Mr. Lonnie Monaco                           (610) 595-0567
Northern Division
Naval Facilities Engineering Command
Code 182
10 Industrial Highway
Mail Stop 82
Lester, PA 19113-2090
Federal Elected Officials

Senator Frank R. Lautenberg                    (609) 757-5353
208 White Horse Pike
Suite 18-19
Harrington, NJ 08007

Senator Robert Torricelli                       (201) 639-2860
1 Newark Center
16th Floor
Newark. NJ  07102

-------
 Congressman Dick Zimmer                    (908)788-1952
 36 West Main St.
 Suite 201
 Freehold, NJ  07728

 Congressman Christopher H. Smith              (908) 350-2300
 lOOLacey Road
 Suite 38A
 Whiting, NJ 08759

 Congressman Frank Pallone, Jr.                 (201) 571-1140
 540 Broadway
 Room 118
 Long Branch, NJ 07740
State Elected Officials

Senator Leonard T. Connors, Jr.                 (609) 693-6700
620 West Lacey Road
Forked River, NJ 08731

Assemblyman Jefferey Moran                   (609) 693-6700
620 West Lacey Road
Forked River, NJ 08731

Assemblyman Christopher J. Connors            (609) 693-6700
620 West Lacey Road
Forked River, NJ 08731
Other Federal Agencies

Mr. Steve Aoyama                            (404) 639-6070
Agency for Toxic Substances and
Disease Registry
1600 Clifton Road
Mail Stop E-56
Atlanta, GA 30333

-------
New Jersey Pinelands Commission

Mr. Todd DeJesus                            (609) 894-9342
The Pinelands Commission
P. O. Box 7
New Lisbon, NJ 08064
Ocean County Officials

Mr. Alan W. Avery, Jr., Director                 (908) 929-2054
Ocean County Planning Board
P.O. Box 2191
Toms River, NJ 08754-2191

Mr. John C. Bartlett, Director                   (908) 244-2121
Ocean County Board of Freeholders
P.O. Box 2191
Toms River, NJ 08754

Mr. Joseph Przywara, Acting Health Coordinator   (908) 341-9700
Ocean County Health Department
P.O. Box 2191
175 Sunset Avenue
Toms River, NJ 08754

Mr. A. Jerome Walnut, Chairman                (908) 505-3671
Ocean County Environmental Agency
1623 Whitesville Road
Toms River, NJ 08755

-------
 Dover Township Officials

 Hon. George Whittman                        (908) 341-1000
 Mayor of Dover Township
 P.O. Box 728
 33 Washington Street
 Toms River, NJ 08753

 Ms. Janet Larson, Chairperson                  (908) 341 -1000
 Dover Township Environmental Commission
 P.O. Box 728
 33 Washington Street
 Toms River, NJ 08754
 Manchester Township Officials

 Hon. Jane Cardo Cameron                     (908) 657-8121
 Mayor of Manchester Township
 One Colonial Drive
 Lakehurst, NJ 08733

 Mr. Warren Sweeney, Chairman
 Manchester Township Environmental Commission
 One Colonial Drive
 Lakehurst, NJ 08733
Jackson Township Officials

Vicki Rickabaugh, Mayor
Municipal Building
95 W. Veterans Highway
Jackson, NJ 08527

Mr. Richard Bizub, Chairman                  (908) 928-0900
Jackson Township Environmental Commission
128 Willow Drive
Jackson, NJ 08527

-------
 Borough of Lakehurst Officials

 Hon. Stephen Childers                         (908) 657-4141
 Mayor of Lakehurst Borough
 5 Union Avenue
 Lakehurst, NJ 08733

 Mr. Robert J. Morris                          (908) 657-4141
 Municipal Clerk, Borough of Lakehurst
 5 Union Avenue
 Lakehurst, NJ 08733
 Plumsted Township Officials

 Hon. Ronald S. Dancer                        (609) 758-2241
 Mayor o f P lumsted Township
 P.O. Box 398
 New Egypt, NJ 08533-0398
Community Groups and Interested Citizens

Pine Lake Park Association
100 Oakdale Drive
Toms River, NJ 08754

Mr. Holmes Ertley                           (908) 657-4690
699C Friar Court
Lakehurst, NJ  08733

Mr. John Lewis                              (908) 657-1890
315BeckervilleRoad
Lakehurst, NJ  08733

Ms. Candy Vesce
733 Sixth Ave.
Pine Lake Park
Toms River, NJ 08757

-------
Ms. Theresa Lettman                           (609) 893-4747
Pinelands Preservation Alliance
120-34B White Bogs Road
Browns Mills, NJ 08015

Ms. Susan Marshall
1716 Ninth Ave.
Toms River, NJ 08757

Ms. Gisela Tsambikou
1162 Beacon St.
Pine Lake Park
Toms River, NJ 08757

Mr. Dieter Rand
3288 Johnson Ave.
Lakehurst, NJ 08733

Mr. & Mrs. Blackwell Albertson
 135BeckervilleRd.
Lakehurst, NJ 08733

Heritage Minerals, Inc.
 Attn: Ms. Adele Hovnanian
 One Hovchild Plaza
 4000 Route 66
 Tinton Falls, NJ  07753

 Chuck Lindstrom
 526-D Crescent Ave.
 Jackson, NJ 08527

 Ben Epstein
 Ocean County Citizens for Clean Water
 2230 Agin Court Road
 Toms River, NJ 08733

-------
 Media
 Advance News                               (908) 657-8936
 2048 Route 37 West
 Lakehurst,NJ 08733

 Alyn Ackerman                              1-800-822-9770
 Asbury Park Press
 3601 Highway 66
 P.O. Box 1550
 Neptune, NJ 07754-1550

 Ms.  Debra Coombe                           (908) 244-7 1 7 1
 Newark Star Ledger
 44 Washington Street
 Toms River, NJ  08753

 New Egypt Press                             (609) 758-2112
 37 Main Street
 P.O. Box 288
 New Egypt, NJ 08533

 Ocean County Leader                          (908) 899-1000
 P.O. Box 1771
 Point Pleasant Beach, NJ 08742

 Ms. Lisa Peterson                             (908) 793-0147
 Ocean County Review
 P.O. Box 8
 Seaside Heights, NJ 08751

 Ocean County Reporter                        (908) 349- 1 50 1
 8 Robbins Street
 P.O. Box 908
Toms River, NJ  08753

 Mr. Sam Christopher                          (908) 349-3000
Ocean County Observer
 8 Robbins Street
CN2449
Toms River, NJ  08753

-------
Radto

Mr. Shawn Marsh                           (908) 774-7700
WJLK Radio
Press Plaza
Asbury Park, NJ  07712

Ms. Joan Jones                              (908) 270-5757
WJRZ Radio
22 West Water Street
P.O. Box  100
Toms River, NJ 08754

Mr. Doug Doyle                             (908) 269-0927
WOBM Radio
U.S. Highway 9
Bayville,NJ 08721

Mr. Gary  Myervich                          (908) 341-8818
Adelphia Cable
830 Highway 37  West
Toms River, NJ  08753

Mr. Abi Montefiore                          (908) 681 -8222
Monmouth Cable
P.O. Box 58
Belmar,NJ 07719

-------
Federal and State Case Managers

Mr. Jeffrey Gratz, Project Manager               (212) 637-4320
U.S. Environmental Protection Agency
Region II
290 Broadway
18th Floor East
New York, NY 10007-1866

Ms. Donna Gaffigan, Case Manager              (609)633-1455
Bureau of Federal Case Management, CN 028
New Jersey Department of Environmental
Protection
401 East State Street
Trenton, NJ 08625-0028

Ms. Linda Welkom, Geologist                   (609) 292-8427
Bureau of Groundwater Pollution Abatement
New Jersey Department of Environmental
Protection
401 East State Street
Trenton, NJ 08625-0028

Mr. Kevin Schick                              (609) 984-1825
Bureau of Environmental Evaluation
and Risk Assessment
New Jersey Department of Environmental
Protection
401 East State Street
Trenton, NJ 08625-0028

-------
FIGURES

-------
                                       '    ^a^^
                                       £**™v&'    N3j*

                                                                                        T\ WPQINT PLEASANT

                                                                                        «.][ BEACH
                                  v&    VTimon "x    ^^>t  |  LA

                                  K*K     »'«« ^—-- WV i
i   ttVicTil   ^*S

\  lAKKA'OOD
|      I   lakcw
I      f   Almc
ISSv PLUMSTED
                                                                                       ,!ASIDE HEIGHTS

               Naval Air Engineering Station Vicinity Map
                       Figure 1

-------
         NAES Lakehurst  NPL Sites
u
a
Map shows locations of 45 sites.
Sites in close proximity have been
grouped into geographical areas
labeled A through L.
                            FIG

-------
                             XRIF 65690M81 DWG
                                                    NEW WATER
                                                    TREATMENT
                                                      PLANT
AOANDONH)
  DRAIN
  fit IDS
                                                                                       l\
   VKV\
   ®      / /    1
  MW6
   NO
                "AREA E. SITE 28 fJULY-sEPTEMBER.
ISOCQNCENTRATIONS OF TO
          NAVAL AIR ENGINEERING STATION (NAES) LAKEHURST. NJ
                                   «
     LEQEJ4D.

     INFLUENT

-EFF	EFFLUENT

	DRAIN FIELD

   0 EXISTING RECOVERY WELL

   6 EXISTING OBSERVATION WELL

     NEW MONITORING WELL

     NEW HYDRANT

B307| EXISTING BUILDING


                  FIGURE  3
                                   i be
                                SCAlt IN TEEI

-------
                          ROD FACT SHEET
SITE
Name
Location/State
EPA Region
HRS Score  (date)
Site ID #
NAEC Lakehurst, Area E/Site 28
Ocean County, New Jersey
II
49.48 (July 22, 1987)
NJ7170023744
ROD
Date Signed
Remedy/ies
Operable Unit
Capital cost
Completion
O & M
Present worth

LEAD	
July 7, 1997
Existing groundwater treatment system,
addition of a sparge/vapor extraction system,
additional modifications to treatment
dependent upon future system influent
concentrations, and establishment of a
classification exception area pursuant to
N.J.A.C. 7.9-6.6
OU-20
$1,382,00(construction)
12 months for the additional enhancements
$501,400 per year for 8 years
$4,376,600
Remedial/Enforcement
EPA/State/PRP
Primary contact  (phone)
Secondary contact  (phone)
Main PRP(s)
PRP Contact  (phone)

WASTE	
Type
Medium  (soil, g.w.,etc.)
Origin
Est. quantity
       Federal Facility
       Navy
       Sharon Jaffess 212-637-4396
       Robert Wing 212-637-4332
       Navy
       Lucy Bottomley 732-323-2612
       Petroleum hydrocarbons,  VOCs,  semi-
       VOCs (benzene,  toluene,  ethylbenzene,
       xylene).
       Soil and groundwater
       Discharge of gasoline due to a leak in
       a subsurface pipe running from an
       above ground tank to Building 308
       The zone of groundwater contamination
       extends approximately 150 feet to the
       east/northeast  from the corner of
       Building 308 with a width of
       approximately 100 feet.

-------