EPA/ESD/R02-95/252
October 1995
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
FAA Technical Center, Area 20A
Salvage Yard Area, Atlantic City
International Airport, NJ
6/18/1995
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EXPLANATION OF SIGNIFICANT DIFFERENCES
AREA 20A, SALVAGE YARD AREA
FAA TECHNICAL CENTER
ATLANTIC CITY INTERNATIONAL AIRPORT, NEW JERSEY
JUNE 1995
I. Introduction
The purpose of this Explanation of Significant Differences (ESD) is .to explain
modifications to the soil remedy selected in the Record of Decision (ROD), signed on September
28, 1990, for Area 20A, the Salvage Yard Area of the Federal Aviation Administration (FAA)
Technical Center at Atlantic City International Airport, New Jersey. This ESD modifies the ROD
to require landfilling of a substantial portion of PCB-contaminated soil instead of incineration of
all PCB-contaminated soils. FAA, as lead agency, developed this ESD, with support from the
U.S. Environmental Protection Agency (EPA). The New Jersey Department of Environmental
Protection (NJDEP) has reviewed and approved of this ESD. FAA issues this ESD in accordance
with Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended, 42 U.S.C. § 9617(c) and Section 300.435(c)(2)(i) of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
300.435(c)(2)(i). These regulations require that, if after the adoption of a ROD, an action is
proposed which differs significantly but does not fundamentally alter the remedy selected, an
explanation of significant differences and the reasons such changes were made must be published
by the lead agency, FAA.
The Explanation of Significant Differences will become part of the Administrative Record
for Area 20A of the FAA Technical Center. The entire Administrative Record for the site, which
includes the Remedial Investigation (RI) Report, Feasibility Study (FS) Report, Proposed Plan,
ROD and other documents related to the site, is available for review at the following location:
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Atlantic County Library
2 South Farragut Avenue
Mays Landing, NJ 08330
(609) 625-2776
Should there be any questions regarding this Explanation of Significant Differences, please
contact:
Mr. Keith Buch, COTR
FAA Technical Center
ACM-440
Building 270, Room A117
Atlantic City International Airport, NJ 08045
(609)485-6644
n. Summary of Site History, Contamination Problems, and Selected Remedy
The FAA Technical Center covers an area of approximately 5,000 acres oh a site in
southeastern New Jersey, 8 miles northwest of Atlantic City (see Figure 1). Installations on the
property include the Atlantic City International Airport, a New Jersey Air National Guard station,
and the extensive facilities of the FAA Technical Center. The Atlantic City municipal water
supply is provided by nine ground water production wells located just north of the Upper Atlantic
City Reservoir on FAA property as well as by water drawn directly from the Atlantic City
Reservoirs. The reservoirs are fed by the North and South Branches of Doughty1 s Mill Stream,
which cross portions of the Technical Center grounds. The public water supply facilities are
managed by the Atlantic City Municipal Utilities Authority (ACMUA).
Area 20A is one of more than 20 areas of concern currently being investigated at the FAA
Technical Center; its location is indicated in Figure 2. Area 20A consists of two adjacent salvage
yards associated with FAA Buildings 206 and 207 (Figure 3). Area 20A, which is fenced and
located approximately 1,600 feet south of the Upper Atlantic City Reservoir, is currently used for
storage of old aircraft parts, trucks and cars, scrap metal, and empty 55-gallon drums.
In 1983, R.F. Weston conducted an initial study for ACMUA which showed the presence
of deteriorated and leaking drums in the northern half of the Salvage Yard Area, with evidence
of past spillage (i.e. visibly stained surface soils). The FAA's Environmental Investigation (El)
of Area 20A was conducted in two phases between December 1986 and December 1988. The
Phase I El identified the presence of high PCB levels in the soil and volatile organic ground water
contamination in the vicinity of the Salvage Yard. Phase U El results delineated the extent of
contamination in both media.
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The ROD for Area 20A included the excavation of approximately 930 cubic yards of soil
with transport off-site for incineration at a permitted rotary kiln incinerator and air stripping of
organic compounds present in the ground water.
El. Description of Significant Differences and the Basis for those Differences
During the remedial design of the soil remediation portion of the ROD for Area 20A, it
was determined that a new approach was warranted based on additional information which was
not available at the signing of the ROD. This information included revised soil cleanup criteria,
limitations on the rate at which the incinerator could accept the soil for treatment, and existing
backlogs at incinerator facilities. These factors are described in more detail below:
Revised Soil Cleanup Criteria - Based on newly developed NJDEP soil cleanup
criteria, the state's cleanup level for PCBs in surface soil is 2 parts per million.
FAA has volunteered to meet this new criteria at Area 20A, even though the ROD
included a cleanup level of 5 ppm PCBs for the top 6 inches of soil and a cleanup
level of 25 ppm PCBs for soils at greater depths. To meet the revised cleanup
criterion, the estimated volume of soil requiring remediation increased by 45 %
(i.e., from 930 cubic yards to 1,450 cubic yards), thereby significantly increasing
both the implementation period and cost of incineration under the ROD soil
remedy.
Limitations nn Soil Acceptance Rate - It was determined during the remedial design
that the receiving incinerator would accept contaminated soils more slowly than
originally anticipated (due to the soils' low BTU value), thereby delaying the
implementation of the ROD soil remedy.
Incinerator Backings - Incineration facilities were also experiencing backlogs in
terms of their ability to accept wastes for treatment, due to an overall national
shortage of incinerator capacity, thereby delaying implementation of the ROD soil
remedy.
Based upon a consideration of these factors, it became apparent that significant delays and
increased costs would result if the ROD soil remedy were implemented. However, if a portion
of the PCB-contaminated soils were landfilled within a TSCA-regulated landfill rather than
incinerated, significant reductions in the implementation time period as well as the associated cost
for the remedial action could be realized. This revision to the remedy was initially proposed in
a letter from TRC Environmental Corporation (TRC) to EPA dated July 20, 1992. Prior to
finalizing such a proposal, however, a determination of whether the contaminated soils would
meet land disposal restrictions was required.
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FAA conducted sampling and analysis of surface soils to provide additional information
as to whether the contaminated soils could be landfilled. The existing land disposal restrictions
prohibit landfiUing of soils that are characteristically hazardous, as defined by the Toxicity
Characteristic Leaching Procedure (TCLP) analysis. In addition, land disposal restrictions
prohibit land disposal of soils characterized as hazardous wastes that contain total halogenated
organic compounds (THOC) at concentrations greater than 1,000 parts per million (ppm).
Laboratory results of this additional sampling and analysis, as presented in the PfTB-
Cnntarmnafftfl Soils Investigation 'Report, Area 20A - Salvagp. Varr^ (V.tr>hp.r 1QQ3 (TRC, January
1994), indicated that no surface soil samples were characteristically hazardous and that THOC
concentrations of the surface soils were below 1,000 ppm. Accordingly, the surface soils samples
do not fall within the land disposal restrictions and therefore can be landfilled at TSCA disposal
facilities instead of incinerated. The EPA reviewed and approved of the sampling results. While
the surface soil samples analyzed as part of the PCB-contaminated soils investigation did not fall
under land disposal restrictions, subsurface soils sampled during the El in a former underground
waste oil storage tank area exhibited PCB contaminant levels as high as 1,400 ppm (the highest
level of PCB contamination detected at the site). If these soils are determined to be hazardous
upon excavation and the presence of THOC levels greater than 1,000 ppm is confirmed, the soils
will require incineration, in accordance with the land disposal restrictions and the soil remedy as
outlined in the ROD. The supporting documents, as described above, are available in the
Administrative Record at the Atlantic County Library.
On the basis of the additional surface soil sampling results, the development of this
Explanation of Significant Differences was proposed in a letter from TRC to the FAA dated
March 14, 1994. The soil remediation portion of the ROD for Area 20A is being changed from
incineration of all PCB-contaminated soils to off-site land disposal of PCB-contaminated soils in
combination with incineration of those soils which cannot be landfilled due to land disposal
restrictions. The ground water remedy will remain unchanged. As discussed above, the change
in remedy will reduce both implementation time period and the cost. The period of
implementation will be reduced, since soils to be landfilled can be readily transported via roll-off
containers to the receiving TSCA-regulated landfill. Landfill disposal is preferable to incineration,
which requires loading soil into individual drums, slow incinerator feed rates, and delays due to
limited incinerator capacities. The remedial cost will also decrease, from an estimated range of
$6.3 to $7 million for incineration of all PCB-contaminated soils at Area 20A, to an estimated
range of $1.2 to $1.6 million for landfilling of all surface soils and incineration of a portion of
PCB-contaminated soils.
IV. Support Agency Comments
On August 18,1992, NJDEP indicated in a letter that it would support modifying the ROD
to require off-site disposal of PCB-contaminated soils which are not subject to land disposal
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restriction, at a TSCA-approved landfill. The EPA indicated its support for the development of
this Explanation of Significant Differences in a letter dated June 29, 1994.
V. Aiffinnation of the Statutory Determinations
While the soil remedy for Area 20A PCB-contaminated soils is being changed from
incineration to land disposal for a majority of the PCB-contaminated soils, those soils which
present a principal threat, based on RCRA hazardous waste definitions and land disposal
restrictions, will still require treatment by incineration. This approach will maintain consistency
with the expectation of Superfund that principal threats at a site should be treated and will not
fundamentally change the remedy, since incineration will be retained as a component of the PCB-
contaminated soil remedial action.
Considering the new information that has been developed and the changes that have been
made to the selected soil remedy, the FAA, with support from EPA, believes that the remedy
remains protective of human health and the environment, complies with federal and state
requirements that are applicable or relevant and appropriate to this remedial action, and is cost-
effective. In addition, the revised remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site.
VI. Public Participation Activities
The Administrative Record for Area 20A, including the information which supports this
Explanation of Significant Differences, is available at the Atlantic County Library for public
review. Public notice of this Explanation of Significant Differences has been published in a major
local newspaper as required by the NCP Section 300.435(c)(2)(i). It appeared in the Atlantic City
Press on July 6, 1995.
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*^'X :-?-XV,i FAA PROPERTY
\4;:3$ LINE
STAT
WAY
ATLANTIC CITY
INTERNATIONAL
- AIRPORT T'
TECHNICAL
, BUILDING
BUILT-UP
AREA
ATLANTIC CITY
EXPRESSWAY
X'TT,>yrV-
PLEASANTVILLE, NJ QUADRANGLE
USGS 7.5 MINUTE SERIES TOPOGRAPHIC
O 1OOO 500O
SCALE, FEET
FIGURE 1. FAA TECHNICAL CENTER
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AREA 20A LOCATION MAP
FAA
TECHNICAL
CENTER
UPPER
RESERVOIR
FEET
FIGURE 2.
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AREA 20A LAYOUT
SCRAP BLDG/
STORAGE 206
RESERVOIR
FORMER
UNDERGROUND
TANKS
\
BLDG. 206
YARD
BLDG. 207
DRUM STORAGE
AREA
100 FT
FIGURE 3.
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UNfTfcD STATES ENVIRONMENTAL PROTECTION AGENCY - REGION U
280 BROADWAY
NEW YORK, NEW YORK 10007-1666
-1UN 1 9 1995
CERTIFIED MAIL
RETUrtN RECEIPT REQUESTED
Mr. Gary E. Poulsen, P.E.
Manager, Plant Engineering and Operations Division
FAA Technical Center
ACM-400
Adtentki City InteitnationaJ Airport. NJ 08405
Re: bRAFT FINAL EXPLANATION OF SIGNIFICANT DIFFERENCES & DRAFT
PUBLIC NOTICE - AREA 20A, SALVAGE YARD
Deer fvlr. Poulaen:
EPA has reviewed the Revised Draft Final Explanation of Significant Differences
(i-SD) end Revised Draft Public Notice for FAA's Area 20A Salvage Yard, submitted by
TRC Erwirorunantal Corporation on behalf of the Federal Aviation Administration
Technical Center via letter dated April, 26, 1995. The ESD has been prepared to
explain a modification of the Record of Decision (ROD) for Area 20A, signed on
September 28, 1980. The ESD modifies the ROD by allowing disposal of a portion of
PCB-contarnlnated soils al a TSCA landfill, rather than requiring that all PCB
contaminated soils be Incinerated Reductions in remedial action costs and
implementation time will be realized with this modification.
Based upon EPA'e review and comments on previous iterations of tha Area ZOA
ESD, EPA hereby concurs with .the technical approach and language found In the April
1995 Revised Draft Final ESD and Revised Draft Public Notice. If you have any
questions ptease;calf Robert Wing, Federal Facility Section Chief (212) 637-4332.
Sincerely,
cc: R. Shlnn, NJDEP
Printed on Recycled Paper.
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Christine Todd Whitman
Governor
Department of Environmental Protection
Robert C. Shinn, Jr.
Commissioner
Mr. Keith Buch
FAA Technical Center
Environmental Programs Branch
ACM-440
Atlantic City International Airport, N.J. 08405
Mr. Vincent Petrozullo
USEPA - Region II
290 Broadway Avenue
New York. NY 10007 -1856
JUNO 2 1995
!995
Dear Messrs. Buch and Petrozullo,
Re: Area 20A ESD
FAA Technical Center
Egg Harbor Township, Atlantic County
The NJDEP has reviewed the draft Explanation of Significant Differences (ESD) dated April 1995, for
Area 20A (Salvage Yard Area) of the FAA Technical Center Superfund Site located at the Atlantic City
International Airport, New Jersey and we approve the document as submitted.
Background
Area 20A, the Salvage Yard Area, has been found to contain contaminated soils with high levels of
PCBs and related contaminants, as well as ground water with significantly elevated volatile organic
contamination. The Record of Decision (ROD) for the site required the excavation of approximately
930 cubic yards of soil with transport off-site for incineration at a permitted rotary kiln incinerator.
The ground water is to be pumped and treated in an on-site ground water treatment system comprising
of an air stripper for the removal of organic compounds. This ESD addresses only the soil portion of
the remedial action, the ground water remedial action remains unchanged.
The ESD
The ESD states three basic reasons for its execution; Revised soil cleanup criteria, limitations on soil
acceptance rate, and incinerator backlogs.
Revised criteria. Since the signing of the ROD, the NJDEP has revised the soil cleanup criteria
for non-residential use. The revised criteria for PCBs has changed from 5 ppm to 2 ppm. This
change has resulted in an additional 520 cubic yards of PCB contaminated soils in need of
remediation.
Limited soil acceptance rate. The low BTU value of the soils will result in a slower
acceptance/treatment of PCB contaminated soils than originally estimated in the ROD.
New Jersey is an Equal Opportunity Employer
Recycled Paper
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Incinerator backlog. Due to an overall national shortage of incinerator capacity, there could be
significant problems and delays carrying out the ROD soil remedy.
Changing the remedial option will result in incineration of only those soils which are determined to be
hazardous and contain total halogenate organic compounds (THOC) at greater than 1,000 ppm. Those
soils not above the land disposal restriction criteria will be landfilled at a TSCA regulated landfill.
Additionally, through the ESD, the FAA has voluntarily agreed to meet the NJDEP soil cleanup criteria
for PCBs established after the ROD. This non-residential cleanup criteria is 2 parts per million (ppm),
while the ROD required for the cleanup of PCB contaminated soils to 5 ppm. This will increase the
volume of soil requiring remediation by 45%, from 930 cubic yards to 1,450 cubic yards.
The changes in the remedy will result in a reduction of both implementation time and cost (from $6.3
to $7.0 million for incineration to an estimated range of $1.2 to $1.6 million for landfilling).
Based on our review, this document has no significant changes to the document reviewed, commented
on and approved in August 1994, therefore, the NJDEP approves of this version of the ESD and looks
forward to the remediation of this site.
If you should heed any assistance or additional information, please feel free to contact me a (609) 633-
1455.
Sincerely,
JUwvvA^
hief I
Bruce Venner, Chief
Bureau of Federal Case Management
cc. Steven Byrnes, BEERA
George Nicholas, BGWPA
S:\GRP\flPC E\BFCMVFAA47 .IRC
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ESP FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score & date:
Site ID #:
FAA Technical Center, Area 20A - Salvage Yard
Atlantic County, New Jersey
US EPA Region II
39.65 - 12/09/88
NJ9690510020
Date Signed:
Remedies:
Operating Unit #:
Capital cost:
June 18, 1995
off-site landfill & incineration
OU-02
$1.6 million (in 1995 dollars)
LEAD
Remedial:
Primary contact:
Secondary contact:
Federal Facility (Federal Aviation
Administration)
Keith Buch, FAA Project Manager 609/485-6644
Betsy Donovan, EPA Project Manager 212/637-
4303
WASTE
Type:
Medium:
Origin:
Estimated quantity:
PCBS
soil
drum & waste oil storage
930+ cubic yards
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