United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/094
September 1989
&EPA
Superfund
Record of Decision
FAA Technical Center, NJ
-------
50273-101
REPORT DOCUMENTATION i. REPORT NO. a.
PAGE EPA/ROD/R02-89/094
4. TOe and SubtWe
SUPERFUND RECORD OF DECISION
FAA Technical Center, NJ
First Remedial Action
7. Authors)
9. Performing Orgdnlntton Name and Addreea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Redplenf • Acceaelon No.
5. Report Dele
09/26/89
6.
a. Performing, Organization Bept No.
10. Pro|ectnaak/Work Unit No.
11. ContractfC) or Gf «nt(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Ho lee
1C. Abetrict (Umtt: 200 worde)
The 5,000-acre multipurpose FAA Technical Center site is a Federal Facility eight miles
northwest of Atlantic City, in Atlantic County, New Jersey. The site includes a jet
fuel farm, an air terminal, a State national guard fighter group, the extensive
facilities of the FAA Technical Center, and the Upper Atlantic City Reservoir. Atlantic
City's municipal water supply is provided by nine ground water supply wells located just
north of the reservoir on FAA property as well as by water drawn directly from the
reservoir. Land use in the site vicinity includes forested land and commercial and
residential areas. There are 25 known areas of contamination at the FAA Technical
Center. This is the first Record of Decision (ROD) for an area of contamination at this
facility. Further areas of contamination will be addressed in future RODs. Soil and
ground water at the site are contaminated with VOCs apparently attributable to the jet
fuel farm. Subsurface jet fuel contamination is probably the result of leaking pipes,
storage tanks, and spills associated with above-ground and underground storage tanks,
associated valves, piping, and dry wells, or a truck loading stand. As an interim
remedial measure, free product recovery pumps were installed in 1988-89 in three onsite
wells to recover the hydrocarbon plume floating on the water table. Product is
currently being extracted and incinerated offsite. The total volume of spilled free
product has been estimated at 360,000 gallons, the total volume of contaminated soil
found in two hot spot areas was estimated to be 33.000 cubic (Continued on next page)
NJ
17. Document Amlyato a.
Record of Decision - FAA Technical Center,
First Remedial Action
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, phenols),
metals (chromium, lead)
b. Menu Aera/Open-€nded Terme
c. C03ATJ Reid/Group
II. AvaUabilty Statement
It. Security CtaMfTnta Report)
None
20. Security O*M (IN* Pig*)
None
21. No. of Page*
59
22. Price
(See ANSt-ZM.1*)
SMinelrucltan* on fleweraw
OPTIONAL FORM 272 (4-77)
(Formerly MTIS-3S)
UGptfttnwit of Conwntf ct
-------
EPA/ROD/R02-89/094
FAA Technical Center, NJ
16. Abstract (Continued)
yards, and the total volume of contaminated ground water was estimated to be 13,300,00
gallons. The jet fuel farm will be closed within the next year as new facilities come on
line. The primary contaminants of concern affecting the soil and ground water are VOCs
including benzene, toluene, and xylenes; and other organics including PAHs (naphthalene)
and phenols.
The selected remedial action for this site includes in situ soil vacuum extraction (soil
venting) and off-gas treatment using either incineration or activated carbon adsorption;
extraction of free product floating on the plume followed by offsite incineration; ground
water extraction and addition of nutrients for subsequent reinjection and in situ
biodegradation of residual ground water contamination; and ground water monitoring. The
estimated present worth cost for this remedial action is $583,000, which includes a total
present value O&M cost of $200,000.
-------
ROD FACT SHEET
SITE
FAA Technical Center, Area D
Atlantic County, New Jersey
USEPA Region II
HRS Score: 39.65
NPL Rank: Proposed on July 14, 1989 (Group 9)
ROD
Date Signed: USEPA, 9/26/89; NJDEP, 9/26/89; FAA, 9/29/89
Remedies:
* free product extraction and off-site cement kiln
incineration,
* ground water extraction and addition of nutrients for
subsequent re-injection and in-situ biodegradation of
volatile organic compounds (VOCs),
* soil venting, a system which extracts gas from the soil
pore space,
* use of off-gas treatment unit for off-gas from soil
venting, consisting either of catalytic incinerator for
combustion of VOCs to carbon dioxide and water, or
activated carbon adsorption of VOCs,
Capital Cost: $286,000
O&M/year: $200,000
Present Worth:
Lead
Federal Facility (Federal Aviation Administration)
Lance R. Richman, P.G. {(212) 264-6695}
(USEPA)
Robert Heitsenrether, COTR {(609) 484-5913}
(FAA)
WASTES
Type: JP-4 Jet Fuel
Medium: soil, ground water, and floating product
Origin: leaking pipes, storage tanks, and spills
Estimated Quantities: Contaminated Soil: 33,000 cubic yards
Free Product: 360,000 gallons
-------
US. Department Technical Center Atlantic City Airport
Of Transportation New Jersey 08405
Federal Aviation
Administration
SEP 2 9 1989
Mr. William J. Muszynski
Acting Regional Administrator
U. S. Environmental Pro-tection Agency, Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Muszynski:
Enclosed is the Technical Center's Record of Decision for Area D,
Jet Fuel Farm, and its supporting documentation. Thank you for
your cooperation in this matter.
If you should have any questions, the Center's point of contact
is Robert B. Heitsenrether at 609-484-5913.
Don at 0-41. Johnson
Manager, Plant Engineering and Services Division
Enclosure
cc:
Mr. Lance R. Richman, USEPA (
Mr. Christopher Daggett, NJDEP (vr/att.)
Mr. Robert Hayton, NJDEP (w/att.)
-------
DECLARATION STATEMENT
RECORD OF DECISION
Area D - Jet Fuel Farm
FAA Technical Center
FACILITY NAME AND LOCATION
FAA Technical Center, Atlantic County
Atlantic City International Airport, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for Area D, the Jet Fuel Farm at the FAA Technical Center,
Atlantic City International Airport, New Jersey. The remedial
action 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 Contingency
Plan (NCP). This decision is based on the administrative record
for Area D.
Both the United States Environmental Protection Agency,
Region II Acting Administrator and the Commissioner of the New
Jersey Department of Environmental Protection concur with the
selected remedy (See Appendices C and D).
ASSESSMENT OF THE AREA
Releases of hazardous substances from this area, if not
addressed by implementing the response action selected in this
Record of Decision, may present a current or potential threat to
public health-, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected action addresses the principal threat to Area D
water table by treating contaminated soils and groundwater. The
selected remedy for Area D includes the following components:
- Free product extraction and off-site cement kiln
incineration.
Groundwater extraction and addition of nutrients for
subsequent re-injection and in situ biodegradation of
volatile organic compounds (VOCs).
soil venting, a system which extracts gas from the soil
pore space.
-------
use of off-gas treatment unit for off-gas from soil
venting, consisting either of a catalytic incinerator for
combustion of VOCs to carbon dioxide and water, or
activated carbon adsorption of VOCs.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action and is cost effective. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that enjoy treatment that reduces toxicity, mobility
or volume CKf\ hazardous substances, pollutants, and contaminants
as a princ/ip/al element.
Donal
Mana
FAA
Johnson
Plant Engineering
Division, ACM-400
Technical Center
and
-------
DECISION SUMMARY
RECORD OF DECISION
Area D - Jet Fuel Farm
FAA Technical Center
SITE DESCRIPTION
The FAA Technical Center encompasses an area of
approximately 5,000 acres in Atlantic County,..New Jersey, 8 miles
northwest of Atlantic City. A location map is provided in Figure
1.
Among the installations on the property are the Atlantic
City International Air Terminal, the New Jersey Air National
Guard 177th Fighter Interceptor Group, the Upper Atlantic City
Reservoir, the Laurel Memorial Park Cemetery and the extensive
facilities of the FAA Technical Center. Atlantic City's
municipal water supply is provided by nine groundwater supply
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 Doughty's Mill Stream, which traverse portions of the
Technical Center grounds. The public water supply facilities on-
site are owned by the Atlantic City Municipal Utilities Authority
(ACMUA).
The FAA Technical Center is located within the Atlantic
Coastal Plain, a broad, flat plain which encompasses the southern
three-fifths of New Jersey. The area within two miles of the
Center has a maximum relief of about 60 feet, ranging from an
elevation of 10 feet above mean sea level (AMSL) at the lower
Atlantic City Reservoir to 70 feet AMSL to the west and north of
the airport. The Facility itself is relatively flat; slopes
generally range from 0 to 3 percent. Forested areas exist north,
south and east of the airport runways. These areas comprise
about 40% of the 5,000 acre FAA property. The remaining 60% of
the site has been cleared for FAA facilities and consists of
buildings and paved surfaces, grassed lawns and native grassland
and shrubs adjacent to the runways.
The area within one mile of the Technical Center boundaries
includes open or forested 1'and and commercial and residential
areas. A large forested tract containing no commercial or
residential property exist west of FAA. To the east, the
property is bordered by the Garden State Parkway, the Atlantic
City Reservoir, and the forested land surrounding the reservoir.
The area north of the Center contains commercial properties along
the White Horse Pike (Rt. 30) and a concentrated residential
area, Pomona Oaks, north of the White Horse Pike. The closest
residential area south of the Center is a series of three trailer
parks at the intersection of Tilton Road and Delilah Road. The
majority of commercial and residential areas south of the Center
are greater than 2,000 feet away from the FAA property, south of
the Atlantic City Expressway. All residential areas in the
-------
vicinity of FAA appear to be upgradient or otherwise isolated
from the groundwater flow at the Technical Center.
Area D - Jet Fuel Farm is located near the juncture of the
access roads to the Atlantic City International Terminal and the
Technical Center's Technical/Administrative Building. Area D is
currently used for the storage of jet fuel in two 420,000-gal Ion
aboveground bermed tanks. Prior to 1972, fuel was stored in two
567,000-gallon underground storage tanks which are currently
clean and empty. A plan for Area D is provided in Figure 2.
SITE HISTORY AND ENFORCEMENT ACTIONS
The first significant development of what is now FAA
property came during tfre 1930s when the Atlantic City Reservoir
was created by damming the South Branch of Doughty Mill Stream.
Prior to 1942, the entire property was wooded, except for the
presence of large borrow pits near the present-day Research and
Development (R&D) facilities. On a 1940 aerial photograph
several dirt roads and what appeared to be a railroad right-of-
way traversed the property. In 1942 a Naval Air Base, including
most of the existing runways, was constructed over much of the
eastern two-thirds of the property. Many of the buildings in the
western built-up area were also constructed at this time. In
1958, the Navy transferred its interests to the Airways
Modernization Board (AMB).
The Federal Aviation Administration took over the operations
of the AMB in November 1958. The early 1960s saw the development
of most of the R&D portion of the Facility south of the Atlantic
City Reservoir. The FAA's large Technical/Administrative
Building was constructed in 1979. The New Jersey Air National
Guard has maintained their facilities at the north end of the
built-up area since 1973.
Initial Investigations:
In 1983 the New Jersey Department of Environmental
Protection directed Weston to conduct an assessment of potential
pollution sources that could impact the then-proposed Atlantic
City Well field. The assessment included a review of all data on
possible contaminant sources in the area, limited field
investigation of these sources, and soil and groundwater
sampling at the five areas considered most threatening to
groundwater supplies in the area. The entire FAA Technical
Center was included in the Weston Study, and the five areas
identified by Weston were all located on the FAA property.
Weston's report led the FAA- to initiate the present Environmental
Investigation/Feasibility Study, and the five areas identified by
Weston have been investigated further, along with additional
areas identified by the FAA.
-------
Environmental Investigation/Feasibility Study:
Area D is one of the additional areas identified by the FAA
subsequent to the Weston Study. Several potential sources of
soil and groundwater contamination exist at Area D (see Figure
2). Both the in-use aboveground and out-of-use underground jet
fuel tanks, and their associated valves and piping are the most
obvious potential sources of contamination at Area D. Plans of
the two abandoned underground storage tanks indicate that there
is a dry well associated with each- of the tanks. No specific
information regarding the purpose of these dry wells is
available.
An active dry well was associated with the fuel/water
separators adjacent to-the truck fill stand, where fuel is pumped
from the two above-ground tanks into fuel trucks. The fuel/water
separators are located in an underground vault. Spillage of fuel
occurred when filters were changed on the separator. Waste
liquids in the vault collected in a sump and were pumped to a dry
well a 30 feet to the south. Waste liquids within the dry well
infiltrate into the surrounding soils. The sump pit, its
associated piping and the dry well were decommissioned in 1985
and are no longer in use.
A surface spill of fuel occurred on the grassy area south of
the fuel fill stand in 1982. One truckload of visibly
contaminated soil from this area was removed shortly after the
spill occurred. An additional area where surface spillage may
have occurred exists adjacent to the west edge of the driveway
across from the fuel fill stand where trucks occasionally park
for short periods of time.
The FAA's Environmental Investigation (El) was conducted in
two phases between December 1986 and December 1988. The most
significant .environmental problem identified during the El is a
hydrocarbon (JP-4 jet fuel) plume floating on the water table. As
an interim remedial measure, product recovery pumps were
installed between August 1988 and March 1989 in three on-site
wells. Product is currently being extracted and transported off-
site for incineration at a cement kiln incinerator.
In June 1989, the Risk Assessment and Feasibility Study (FS)
for Area D- were distributed to USEPA, Region II, Emergency and
Remedial Response Division and New Jersey Department of
Environmental Protection (NJDEP), Bureau of.. Federal Case
Management for their review. The Proposed Remedial Action Plan
was finalized by the FAA and approved by the above mentioned
agencies on August 4, 1989, initiating a 32 day public comment
period.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Area D Proposed Remedial Action Plan (PRAP) was issued
to interested parties on August 4, J989, on the-same day that a
-------
newspaper notification inviting public comment on the EI/FS and
PRAP appeared in the Atlantic City Press. The public comment
period was held from Aug-ust 4 to September 5, 1989. The
newspaper notification also identified the Atlantic County
Library as the location of the Information Repository.
A public meeting was held on August 30, 1989. At this
meeting, representatives from the FAA, TRC Environmental
Consultants, Inc., USEPA and NJDEP were available to answer
questions about Area D and the remedial alternatives under
consideration. A list of attendees is attached (See Appendix B).
A response to the comments received during this period is
included in the Responsiveness Summary, which is part of this
Record of Decision. This decision document presents the selected
remedial action .for Area D of the FAA Technical Center in
Atlantic County, New Jersey, chosen in accordance with CERCLA, as
amended b-y SARA and, to the extent practicable, the NCP. The
decision for Area D is based on the administrative record.
SCOPE AND ROLE OF RESPONSE ACTION
The remedial action described herein addresses the
environmental problems associated with Area D, the Jet Fuel Farm.
SUMMARY OF AREA CHARACTERISTICS
Area D contamination appears to be entirely attributable to
on-site jet fuel. The specific source of contamination at Area D
have not been identified. Subsurface jet fuel contamination
could be associated with the aboveground and underground jet fuel
storage tanks, associated valves, piping and dry wells, or the
truck loading stand. Areas of identified surface sail
contamination mirror areas of historic surface spills.
The media of concern at Area D include the floating free
product, contaminated soil, and contaminated groundwater. The
lateral and vertical extents of the free-phase and dissolved
hydrocarbon plumes at Area D have been well-defined. The
floating hydrocarbon plume is-elongated in a northwest-southeast
orientation parallel to the direction of ..groundwater flow and is
approximately 550 feet long by 300 feet wide (see Figure 3).
True product thicknesses within the formation is estimated to be
3 to 5 feet. The total volume of spilled free product at the
site has been calculated to be 360,000 gallons based on estimated
true product thicknesses and the known area where free product is
present. The actual volume of free product could differ
significantly from this estimate.
The., thickest accumulations of floating product occur in
wells close to the filter bank dry well, suggesting a source in
-------
that area. However, mounding of the top of the free product
layer 50 feet to the north indicates that the source may be
associated with underground piping leading to the nearby fuel
fill stand and that the area of thickest accumulation is actually
downgradient of the source. The Jet Fuel Farm will be closed
within the next year, when the NJ Air National Guard activates
their new Fuels Facility. All on-site fuel storage activities
will be discontinued, thus eliminating any source which may be
presently contributing to the problem.
Monitoring wells within several hundred feet of the
downgradient edge of the floating hydrocarbon plume were not
found to contain detectable concentrations of the organic
constituents which make up jet fuel. The absence of these
dissolved constituents.suggests that the dissolved hydrocarbon
plume is moving at approximately the same rate as the free
product plume. Benzene and ethylbenzene were detected in two
wells northeast of the plume. These constituents may be related
to the floating hydrocarbon plume but are more likely associated
with leakage or spills associated with the operation of the two
large underground tanks which were abandoned in 1972. Despite a
light downward vertical gradient at Area D, neither of the two
deep (94 feet) wells at Area D has been impacted by the presence
of the hydrocarbon plume in the shallow aquifer.
Two hot spots of surface soil contamination in areas of
known or suspected fuel spills have been identified. These areas
include an area south of the fuel/water separator dry well, where
a spill occurred in 1983, and an area west of the fuel fill stand
at a truck turning point. Subsurface soil contamination was
identified by high total petroleum hydrocarbon concentrations
detected in subsurface soil samples. The maximum petroleum
hydrocarbon concentration detected in surface soils was 284 parts
per million (ppm), while 18,500 ppm was the highest level
detected in subsurface soils. The one subsurface soil sample
analyzed for priority pollutants exhibited a total volatile
organic compound concentration of less than 1 ppm.
The areal and vertical extent of surface and subsurface soil
contamination was approximated using analytical results, product
thickness estimates and subsurface soil headspace readings. The
total volume of contaminated soil was estimated to be 33,000
cubic yards.
Groundwater contaminants consist of volatile organics, base
neutrals and metals. Most of the organic contaminants detected
are identical to the major components of jet fuel. The inorganic
contaminants are thought to be attributable to suspended solids
in the unfiltered groundwater samples. The major organic
compounds and their maximum detected concentrations include
benzene at 4,000 parts per billion (ppb), toluene at 3,100 ppb
and naphthalene at 1,000 ppb. Contaminated groundwater volumes
were based on the presence of benzene at levels exceeding the New
'Jersey Maximum Contaminant Level (MCL) of 1 ppb. The total
-------
volume of contaminated groirndwater is estimated to be 13.3
mi 11 ion gal Ions.
SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for Area D and is
presented in a document entitled, Baseline Risk Assessment, Site
D Jet Fuel Farm (TRC, June 1989). The risk assessment consisted
of hazard identification, a dose-response evaluation, exposure
assessment and risk characterization.
Selection of Contaminants of Concern
The hazard identification involved the selection of
contaminants of concern (COCs), detected contaminants which have
inherent toxic/carcinogenic effects that are likely to pose the
greatest concern with respect to the protection of public health
and the environment. Selected contaminants of concern at Area D
included:
Volatile Organic Contaminants
* Benzene
* Toluene
* Ethylbenzene
* Xylene
Base/Neutral and Acid Extractable Compounds
* Naphthalene
* Phenol
* 2-Chloropnenol
Metals
* Chromium
* Nickel
* Lead
The media in which these contaminants were detected and
associated concentrations are summarized in Table 1.
-------
Dose-Response Evaluation
The dose-response evaluation presented available human
health and environmental criteria for the contaminants of
concern, and related the chemical exposure (dose) to expected
adverse health effects (response). Included in this assessment
are the pertinent standards, criteria, advisories and guidelines
developed for the protection of human health and the environment.
An explanation of how these values were derived and how they
should be applied is presented below.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg/day)-1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg/day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from hum^n
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects of humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The Office of Research and Development (ORD) has developed
Health Effects Assessments (HEAs) for 58 hazardous substances.
The intent of these assessments is to suggest an acceptable
exposure level whenever sufficient data are available. These
values reflect the relative degree of hazard associated with
exposure to the chemical addressed.
When possible, two categories of maximum dose tolerated
(MDT) have been estimated for systemic toxicants. The first, the
"Acceptable Intake Subchronic" (AIS), is an estimate of an
exposure level that would not be expected to cause adverse
effects under subchronic exposure. Limited information is
available on subhcronic exposure because .efforts have been
-------
10
directed primarily to lifetime exposures. Subchronic human data
are rarely available. Reported exposures are usually from
chronic, occupational exposure situations, or from reports of
acute accidental exposure. If data are available to estimate a
chronic exposure, the subchronic exposure is also based on this
data, with an uncertainty factor applied.
The "Acceptable Intake Chronic" (AIC) is similar to the
concept of the Reference Dose (RfD) previously discussed. It is
an estimate of an exposure level which would not be expected to
cause adverse effects when exposure occurs for a significant
portion of the life-span. As with the RfD, the AIC does not
reflect the carcinogenic properties of the contaminant since it
is assumed, correctly or incorrectly, that there is no acceptable
intake level for carcinogens. The AIC is also considered to be
route specific, thus it" estimates the acceptable exposure for a
given route with the implicit assumption that exposure via other
routes is insignificant.
AIC and AIS values are generally derived from animal studies
'"to which uncertainty factors have been applied. AIC and AIS
values are expressed both in terms of human intake (mg/kg/day)
and ambient concentration (e.g., mg/1 for drinking water).
Dose-response parameters used in the assessment of
noncarcinogenic and carcinogenic risks at Area D are pr
Table 2.
are presented in
Exposure Assessment
The exposure assessment identified potential pathways and
routes for contaminants of concern to reach the receptors and the
estimated contaminant concentration at the points of exposure.
Contaminant release mechanisms from environmental media, based on
relevant hydrologic and hydrogeologic information (fate and
transport, and other pertinent site-specific information, such as
local land and water use or demographic information), were also
presented. At Area D, the current receptor population was
identified as basically limited to government employees due to
the size and security of the FAA facility. In addition, only a
small percent of the Government employees (<2%) who work at the
Technical Center are authorized access to the Fuel Farm.
Potential exposure pathways evaluated include the ingestion of
groundwater, ingestion of or direct contact with surface soils,
and ingestion of or direct contact with subsurface soils.
Inhalation of airborne contaminants or fugitive dust was not
identified as a significant exposure pathway. For each
potentially significant exposure pathway, exposure assumptions
were made for realistic worst-case and most probable exposure
scenarios.
-------
11
Assumptions used to characterize exposure point
concentrations were all based on a 70-kg adult. Specific
assumptions for each exposure pathway and scenario are summarized
in Table 3.
Risk Characterization
The risk characterization quantifies present and/or
potential future threats to human health that result from
exposure to the contaminants of concern at Area D. The site-
specific risk values are estimated by incorporating information
from the hazard identification, dose-response evaluation, and
exposure assessment.
When sufficient data are available, a quantitative
evaluation is made of either the incremental risk to the
individual, resulting from exposure to a carcinogen or, for
noncarcinogens, a numerical index or ratio of the exposure dose
level to an acceptable dose level is calculated.
Risks which were assessed in the Area D feasibility study
include noncarcinogenic and carcinogenic risks resulting from
exposure to individual COCs.
For noncarcinogenic compounds, various regulatory agencies
have developed standards, guidelines and criteria which provide
"acceptable" contaminant levels considered to protect human
populations from the possible adverse effects resulting from
chemical exposures. A ratio of the estimated body dose level to
the RfD or AIC/AIS provides a numerical index to show the
transition between acceptable and unacceptable exposure. This
ratio is referred to as the chronic hazard index. For
noncarcinogenic risks, the term "significant" is used when the
chronic hazard index is greater than one. When Federal standards
do not exist, a comparison was made to the most applicable
criteria or guideline.
Calculated body dose levels, as described previously, were
compared to the body dose level associated with the most
applicable standard or guideline. The estimated chronic body
dose level in ug/kg/day is estimated using the exposure
assessment assumptions and actual site data as summarized in
Table 3. The body dose level is then compared to the AIC to
determine if chronic exposure to the contaminated soil presents a
risk. Because certain standards are derived for protection
against acute (e.g., 1-day HA), subchronic (e.g., AIS), and
chronic (e.g., AIC) exposures, body dose levels for
noncarcinogens are developed for both acute and chronic exposures
and the associated risks assessed.
For carcinogens or suspected carcinogens, a quantitative
risk assessment involves calculating risk levels considered to
represent the probabili-ty or range of probabilities of developing
-------
12
additional incidences of cancer under the prescribed exposure
conditions. Carcinogenic risk estimates, expressed as additional
incidences of cancer, are determined by multiplying the
carcinogenic potency factor, as described earlier, by the
projected exposure dose level. It is the carcinogenic potency
factor, expressed in (mg/kg/day)"1, which converts the estimated
exposure dose level, expressed in (mg/kg/day), to incremental
risk. These risks are probabilities that are generally expressed
in scientific notation (e.g., 1 x 10~°or 1E-6). An excess
lifetime cancer risk of 1 x 10~6 indicates that, as a plausible
upper bound, an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure
conditions at a site. To put the calculated risk estimates into
perspective, they should be evaluated against a baseline risk
level. Risk levels of 10~4 to 10~7 can be used to determine the
"environmental significance" of the risk incurred and are used as
a target range for remedial purposes (U.S. EPA, 1986). Using
this range as a baseline, a risk level greater than 10~4 is
considered to present a "significant" risk with regard to human
health in an environmental context, and levels less than 10 ~7 are
considered "insignificant". A risk level between 10 and 10""'
is classified as "potentially significant". The use of the terms
"significant", "potentially significant", and "insignificant" are
not meant to imply acceptability; however, they help to put
numerical risk estimates developed in risk assessment into
perspective.
The noncarcinogenic risk characterization for Area D
concluded that under realistic worst-case and most probable
exposure scenarios the acute and chronic noncarcinogenic risks
associated with future exposures (ingestion or dermal contact) to
surface and subsurface soils appear to be "insignificant".
Likewise, acute or chronic ingestion of contaminated groundwater
under realistic worst-case and most probable exposure scenarios
does not appear to result in "significant" noncarcinogenic risk.
A summary of noncarcinogenic chronic hazard indices is presented
in Table 4.
The carcinogenic risk characterization concluded that the
carcinogenic risks associated with future incidental ingestion of
surface or subsurface soils under realistic worst-case and most
probable exposure scenarios are considered "insignificant".
Direct dermal contact with surface or subsurface soils under
future realistic- worst-case and most probable exposure scenarios
also appears to be "insignificant". Future scenarios Which
evaluate the carcinogenic hazard associated with groundwater
ingestion predict the carcinogenic risk to.be "significant"
(i.e., exceeds the EPA target range of 10 to 10 ) for the
realistic worst-case and "potentially significant" for the most
probable exposure scenarios. A summary of carcinogenic risks at
Area D is presented in Table 5.
-------
13
Environmental risks associated with the presence of
contamination at Area D are expected to be minimal. Based on the
investigation results, surficial contamination is limited to the
presence of petroleum hydrocarbons in relatively small areas of
jet fuel spills. The majority of the threats posed by Area D are
associated with the presence of the floating hydrocarbon plume
and subsurface soil contamination.. Therefore, risks to flora and
fauna at the surface are limited.
Regardless of the type of risk estimate developed, it should
be emphasized that all estimates of risk are based upon numerous
assumptions and uncertainties. In addition to limitations
associated with site-specific chemical data, other assumptions
and uncertainties that affect the accuracy of the site-specific
risk characterizations result from the extrapolation of potential
adverse human health effects from animal studies, the
extrapolation of effects observed at high dose to lose dose
effects, the modeling of dose response effects, and route-to-
route extrapolation.
The use of acceptable levels (established standards,
criteria and guidelines) and unit cancer risk values which are
derived from animal studies introduces uncertainty into the risk
estimates. In addition, the exposure coefficients used in
estimating body dose levels are often surrounded by
uncertainties. As such, these estimates should not stand alone
from the various assumptions and uncertainties upon which they
are based. In developing numerical indices of risk, an attempt
is made to evaluate the effect of the assumptions and limitations
on the numerical estimates. When the assumptions and
uncertainties outweigh the meaningfulness of a risk assessment, a
qualitative assessment of the risk is performed.
The uncertainty factors which are incorporated into the risk
estimates are believed to be conservative. As such, when they
are considered collectively, exposure, and subsequently risk, may
be overestimated.
In conclusion, based on the results of the risk assessment,
actual or threatened releases of hazardous substances from Area
D, if not addressed by implementing the response action selected
in this ROD, may present an endangerment to public health,
welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Eight remedial alternatives were developed for analysis in
the Area D FS. Each of these alternatives is described in detail
below. Because a number of the alternatives involve common
remedial elements, these are described separately, where
applicable, and then are referenced in the individual alternative
descriptions.
-------
14
Common Major Elements of Remaining Alternatives
The remedial components described below are common to the
majority of the remaining alternatives. Therefore, these
components are described once and the descriptions are then
referenced in the subsequent alternative descriptions.
Free Product Extraction/Groundwater Extraction and Injection
- Free product extraction involves the removal of floating free
product through the use of extraction wells. The total estimated
volume of free product is 360,000 gallons, based on its currently
defined areal extent, measured thickness in monitoring wells and
application of conversion factors to estimate true thickness
within the formation. Four product extraction wells are proposed
for use in the control "and minimization of the product plume.
The amount of product recoverable by pumping can vary from 20% to
60% of the total volume present. It has been assumed that 35% of
the 360,000 gallons (126,000 gallons) of product at Area D is
recoverable. Product residuals which are not extracted will
subsequently be addressed by soil and/or groundwater remediation.
Recovery of product floating on the groundwater will take
place concurrently with groundwater extraction. The pumping of
adjacent product and groundwater extraction wells will induce a
cone of depression around the product extraction wells and
facilitate the collection of floating product by creating a flow
gradient toward the wells.
The proposed groundwater extraction system consists of five
extraction wells, located within the general contaminant plume
area. Four of the five wells will be paired with product
extraction wells. The total pumping rate of groundwater from the
five extraction wells will be approximately 20 gallons per minute
(28,800 gallons per day). Reinjection of treated groundwater is
expected to significantly decrease the amount of time required to
recover contaminated groundwater and prevent the collection of
large quantities of uncontaminated groundwater.
Soil Excavation - As described earlier, surface soil and
subsurface soil contamination are of concern at Area D. Surface
soil sampling identified two hot spots of surface soil
contamination in areas of known or suspected fuel spills.
Subsurface soil contamination was identified by high total
petroleum hydrocarbon concentrations detected in three subsurface
soil samples.
The areal and vertical extent of subsurface soil
contamination was approximated using analytical results, product
thickness estimates and subsurface soil headspace readings.
Three categories of soil contamination were defined: surface
soil contamination only, surface and subsurface contamination .
combined and subsurface contamination only due to the present of
-------
15.
the floating free product. .Volume estimates were made for each
category of subsurface contamination, with a total contaminated
volume estimate of 33,000 cubic yards.
Alternative 3 - Free Product Extraction and Soil Excavation with
Qn-Site Storage; Groundwater Extraction and
Injection with in Situ Biodegradation
Cost: $7.9 million Time to Implement: 10 years or more to
completion
It would meet the criterion of approaching ARARs, as
required by the NCP.
Free product would be extracted, as previously described,
and stored on-site within a tank. On-site storage of product
would allow for its future use in conjunction with the
remediation of another FAA area. If not used in conjunction with
the remediation of another area, the free product could be
accumulated for off-site disposal at a future data.
Contaminated soil would be excavated and stored on-site
within a secure building. On-site storage would allow for the
future treatment of the soils using improved, more highly
developed treatment technologies. It would also allow for
combined treatment with similarly contaminated soils from other
areas of the facility thereby providing potential economies of
scale. The extent of excavation was discussed previously. Soil
containment structures would be constructed on-site to
specifically contain the excavated soil.
Groundwater extraction and reinjection were previously
described. In situ biodegradation would involve the addition of
nutrients and oxygen to the extracted groundwater prior to
reinjection.
Alternative 4 - Free Product Extraction and Off-Site Cement Kiln
Incineration; Soil excavation and Off-Site
with I
mi 11 ion
n Situ Biodegradation
Time to Implement: 7 years
cleanup
to reach
goals
Disposal; Groundwater Extraction and Injection
Cost: $8.7
This alternative was developed to meet the NCP criterion for
an off-site alternative. It could also be considered to fall
within the treatment range for alternatives required by the
current guidance.
Free product would be extracted, as previously described,
and transported to an off-site cement kiln for incineration.
Only cement kilns, authorized to use waste materials, such as the
-------
16
free product, as supplementary fuel would be used for product
incineration.
Contaminated soil would be excavated and shipped off-site to
a permitted landfill facility. Soil excavation volumes were
addressed previously. Excavated soils would be temporarily
stockpiled on-site and sampled to allow for NJDEP classification
(as represented by Area ID numbers). Based on previous soil
excavation and disposal activities conducted at another FAA area,
it is expected that the majority of contaminated soils will be
classified as I.D. 27 industrial waste. Soils containing
hydrocarbons beyond saturation (generally greater than 3%) would
most likely be classified as X725 waste and require disposal in a
hazardous waste landfill. Soils excavated from near the water.
table in areas of floating product could be expected to be
classified X725, with o-ther contaminated soils classified as I.D.
27. ' It is estimated that 13,500 cubic yards of material would
require disposal as a hazardous waste, while 19,500 cubic yards
of soil could be disposed of as an industrial waste.
Groundwater extraction and reinjection and in situ
biodegradation would be as described previously for Alternative
3.
Alternative 5 - Free Product Extraction and Soil Excavation with
On-Site Incineration; Groundwater Extraction and
Injection with Physical Treatment
Cost: $58 million Time to Implement: 9 years to reach
cleanup goals
This alternative was developed to meet both NCP and current
guidance criteria. The proven characteristics of the chosen
treatment methods and the treatment of all waste materials allow
this alternative to conform with the current guidance criterion
for an alternative which minimizes long-term management while it
also meets the NCP criterion for an alternative which exceeds
ARARs.
Free product would be extracted, as previously described,
and treated- on-site using incineration. On-site incineration
would require construction of an incinerator on-site. Extracted
product, with its high BTU value, would burn readily and would
provide supplementary fuel for the destruction of other
contaminated materials.
Contaminated soil would be excavated and then thermally
treated within the on-site incinerator.
Groundwater extraction and reinjection were described
previously. A physical treatment method would be used to treat
extracted groundwat-er prior, to reinjection.
-------
17
Alternative 6 - Free Product Extraction and Off-Site Cement Kiln
Incineration; Soil Venting; Groundwater Extrac-
tion and Injection with In Situ Biodegradation
Cost: $0.6 million Time to Implement: 6 years to reach
cleanup goals
This alternative was developed to meet both NCP and current
guidance criteria. The alternative will provide treatment to
exceed ARARs, per the NCP, and will provide treatment as a
primary component, per the current guidance.
Free product would be extracted, as previously described,
and transported to an off-site cement kiln for incineration.
J_h_oujd wojj)3 be treated in situ using soil venting, also
referred tb~"as vacuum extraction. Soil venting can remove both
free product and adsorbed hydrocarbons from contaminated soils
without excavation and could be conducted concurrently with free
product extraction and in situ biodegradation. Implementation of
soil venting would require installation of vacuum extraction
wells and the associated vacuum system. If residual soil
contamination remains following product extraction and soil
venting, soil biodegradation could be conducted in conjunction
with groundwater biodegradation.
Groundwater extraction and reinjection and in situ
biodegradation would be as described previously for Alternative
3.
Alternative 7 - Free Product Extraction and Off-Site Cement Kiln
Incineration; Soil Excavation and Off-Site
Incineration; Groundwater Extraction and Injec-
tion with Carbon Adsorption
Cost: $39.6 million Time to Implement: 7 years to reach
cleanup goals
This alternative was developed to meet both NCP and current
g-uidance criteria. The alternative will provide treatment to
exceed ARARs, per the NCP, and will provide treatment as a
primary component, per the current guidance.
Free product would be extracted, as described previously,
and transported to an off-site cement kiln for incineration.
Contaminated soil would be excavated and shipped off-site to
a permitted incineration facility.
Groundwater extraction and injection were described
previously. A physical treatment method would be used to treat
groundwater prior to reinjection.
-------
18
Alternative 8 - Free Product Extraction and Off-Site Distilla-
tion; Soil Excavation and Soil Washing; Ground-
water Extraction and Injection with Chemical
Treatment
Cost: $11.0 million Time to Implement: 9 years to reach
cleanup goals
This alternative was developed to meet both NCR and current
guidance criteria. It provides treatment exceeding ARARs, per
the NCP, and retains innovative treatment technologies for
further consideration, per the current guidance.
Free product would be extracted, as previously described,
and transported off-site to a facility where it would be re-
distilled and separated into its various components for re-
blending. The resulting product would subsequently be used as an
industrial fuel.
Contaminated soil would be excavated and treated on-site in
a soil washing system. Soil washing would require the on-site
construction of a system which would feed the contaminated soils
into soil scrubbers, a filter press and to drying beds, if
necessary.
Groundwater would be extracted and reinjected as described
previously. Treatment of the extracted groundwater would be
accomplished using chemical treatment. A unit would be set up
on-site and extracted groundwater would be fed through the system
prior to reinjection.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The eight alternatives identified above were evaluated using
criteria derived from the National Contingency Plan and the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
These criteria relate to the SARA amendment to Section 121 of
CERCLA (Section 121(b)(1)) and Section 300.68(1) of the NCP and
are as follows:
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.
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.
-------
19
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.
Reduction of tpxicity, mobility or volume through treatment
eva 1uates the reliability of an alternative to reduce risks
through treatment technologies.
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.
Implementability is an evaluation of the technical
feasibi1ity,administrative feasibility, and availability of
services and materials required to implement the alternative.
Cost includes an evaluation of capital costs, annual
operation and maintenance costs, and net present worth costs.
State Acceptance indicates the State's response to the
alternatives in terms of technical and administrative issues, and
concerns.
Community Acceptance evaluates the issues and concerns the
public may have regarding the alternatives.
A comparative discussion of the eight alternatives on the
basis of the evaluation criteria presented above follows.
Comparative analyses of alternatives are also presented in Tables
6 through 12.
Overall Protection -. Alternatives 5, 6, 7 and 8 all would
provide adequate protection of human health and the environment.
The preferred alternative, Alternative 6, offers the shortest
remedial time frame and the greatest protection against short-
term risks since no soil excavation is involved. Alternative 3'
allows for future waste treatment but requires a long-term
remedial time frame. Alternatives 1, 2 and 4 do not treat one or
more of the contaminated media and thereby provide a lesser
degree of protection.
Compliance with ARARs - Alternatives 5, 6, 7 and 8 will
exceed ARARs while Alternativ.es 3 and 4 will attain ARARs.
Alternatives 1 and 2 will not atta-in ARARs.
Long-Term Effectiveness and Permanence - Alternatives 5 and
7, which involve incineration of soil and product as well as
groundwater treatment, are expected to provide the greatest long-
term effectiveness due to the destruction efficiencies of
incineration. The preferred alternative and Alternative 8 also
provide treatment of all three media and are expected to be
effective in- the long-term. Alternatives 1, 2 and 4 do not
-------
20
provide treatment of one or more of the contaminated media,
thereby reducing their long-term effectiveness. Alternative 3,
which allows for future treatment of product and soil, may
ultimately be effective in reducing risk but requires long-term
monitoring until the fate of these materials is determined.
Reduction of Toxicity, Mobility or Volume - Alternatives 5,
6, 7 and 8 all provide a reduction of toxicity, mobility or
volume of the three media of concern. Alternatives 5 and 7 are
expected to provide the greatest reductions due to the
destruction efficiencies of incineration, followed by the
preferred alternative which provides in situ treatment of soil
and groundwater. In situ treatment reduces potential mobility
associated with waste handling and off-site waste transport.
Alternative 6 is followed by Alternative 8, which requires
additional waste handling and involves innovative technologies
whose performance is not well proven. Alternative 3 offers
potential future reductions in waste toxicity, mobility or volume
while Alternatives 1, 2 and 4 offer no treatment of one or more
of the contaminated media.
Short-Term Effectiveness - The preferred alternative offers
the greatest short-term effectiveness because in situ soil
treatment does not involve the short-term risks associated with
soil excavation and it meets cleanup goals within the shortest
time frame. Alternatives 4, 5, 7 and 8 involve increased short-
term risks associated with soil excavation with successively
longer remedial time frames (seven to nine years). Because of
the temporary storage nature of Alternative 3, the time frame to
meet cleanup goals is long. Alternatives 1 and 2, while
providing minimal short-term risks, will not achieve cleanup
goals.
Implementabi1ity - Alternative 1 offers the greatest degree
of implementabi1ity, followed by Alternative 2, which involves
proven technologies and no inter-agency coordination.
Alternatives 4 and 7, which offer off-site handling of product
and soil, are easily implemented, although availability of off-
site soil treatment/disposal capacities could significantly delay
their implementation. Alternatives 6 and 8 involve on-site soil
treatment with 6 being more implementable than 8 on the basis of
equipment simplicity and availability. Alternatives 3 and 5 are
considered to be the least implementable due to the extensive on-
site construction/set-up required.
Cost - Alternative 1 has no cost associated with it. The
preferred alternative has the lowest estimated net cost, with a
total present worth of less than 1 million dollars. Alternatives
2, 3 and 4 have total present worth values between 1 and 10
million dollars. Alternatives 5, 7 and 8 range in cost from 10
to 58 mill ion dollars.
State Acceptance - The preferred alternative is acceptable
to the New Jersey Department of Environmental Protection.
-------
21
Community Acceptance - Community acceptance of the preferred
alternative will be evaluated on the basis of public comments and
will be described in the Record of Decision for the site.
SELECTED REMEDY
The following section describes in detail the remedial
action plan which the Federal Aviation Administration, in
concurrence with USEPA and NJDEP, has selected to implement at
Area D (See USEPA and NJDEP Letters of Concurrance, Appendices C
& D). This selection is identical to that presented in the
Proposed Remedial Action Plan.
The selected remedial alternative is Alternative 6 - Free
product extraction and-off-site cement kiln incineration, soil
venting, and groundwater extraction and injection with in situ
biodegradation. This alternative will address product extraction
and soil and groundwater treatmejrL,AiJLyjt,ajiepjj:s_Ly.
Free product will be extracted via the four.product
extraction wells and will be temporarily stored (for less than 90
days) on-site prior to transport off-site for cement kiln
incineration. The product extraction rate is expected to be 200
gallons per day. Off-site incineration will provide a permanent
reduction in toxicity with minimal short-term and long-term
risks.
Soil venting will provide soil treatment concurrently with
product extraction. In alternatives which involve soil
excavation, excavation would not commence until product
extraction was complete, to allow for soil treatment of the
subsurface interval in which floating free product has
contaminated the soil. Soil venting will aid in subsequent
product extraction through volatilization of the product and
extraction via the soil gas, and therefore could be implemented
simultaneously with direct product extraction. It is estimated
that the combined systems will extract free product over a one-
year period and that soil venting will continue for an additional
year. Soil venting will involve approximately 21 vacuum
extraction wells, a manifold system, blowers and an off-gas
treatment unit.
Groundwater treatment will also be conducted concurrent with
soil'treatment and product extraction. Groundwater will be
extracted via five groundwater extraction wells. The extracted
water will be processed through mixing tanks where nutrients and
oxygen will be added. The water will then be reinjected
upgradient of the contaminated area. To meet cleanup standards,
it was estimated that extraction of three (3) contaminated
aquifer volumes subsequent to completion of soil remediation
activities will be required over a period of four years.
Therefore, it is estimated that qroundwater treatment will be
•implemented for a total period of six years.
-------
22
The proposed remedy has been developed to meet Federal and
State ARARs for drinking water and soil quality. New Jersey MCLs
have been selected as groundwater cleanup levels because they are
promulgated and are more stringent than Federal MCLs. The New
Jersey MCL for benzene, the only carcinogenic COC identified in
groundwater samples, is also more stringent than the cleanup
level back-calculated assuming a worst-case scenario risk of 1 x
1(T6 (6.17 ppb).
The soil cleanup level is based on NJDEP Soil Cleanup
Objectives, which are not ARARs but are To Be Considered (TBCs).
For volatile organic compounds in soils, the cleanup objective is
1 part per million (ppm) total priority pollutant volatile
compounds. For total petroleum hydrocarbons the cleanup
objective is 100 ppm. No chemical-specific ARARs for soil
contaminants were identified.
A cost estimate for Alternative 6 is presented in Table 13.
This cost estimate is based on preliminary design of the remedial
systems. Because of the design's preliminary nature, changes
could be implemented during the final design and construction
processes. Such changes will reflect modifications resulting
from the engineering design process and will not substantially
change the intent of the selected .alternative described herein.
STATUTORY DETERMINATIONS
Under Section 121 of CERCLA and Section 300.68(1) of the
NCP, selected remedies must meet certain statutory and regulatory
requirements. These requirements and a description of how the
selected remedy satisfies each requirement are presented below.
Protection of Human Health and the Environment
The selected alternative will fully protect human health and
the environment through treatment of each contaminated medium
while also meeting ARARs and minimizing short-term risks.
Floating free product will be extracted and thermally destroyed
off-site, resulting in minimal short-term risks and no long-term
risks associated with on-site treatment residuals. Soil
contamination, including residual contamination in areas where
free product has been extracted, will be treated via soil
venting. The soil venting system will extract volatile
contamination from the soil without the short-term risks
associated, with soil excavation, and off-gas treatment will
destroy the extracted organic compounds. In situ groundwater
treatment will similarly remediate organic contaminants within
the groundwater with little or no associated short-term risks.
-------
23
Compliance with ARARs
The selected remedy will attain Federal ARARs and those
State ARARs which are more stringent than Federal ARARs. A list
of applicable ARARs and TBCs is presented in Table 14.
It should be noted that, although evaluated, no location-
specific ARARs were identified which were applicable to Area D.
The area is not within the 500-year floodplain (area is located
in Zone C, defined as an area of minimal flooding on the basis of
the applicable Flood Insurance Rate Map). There are no Federally
designated wild and scenic rivers or coastal barriers in the
vicinity. Additionally-, Area D does not lie within the coastal
zone. Therefore, the Wild and Scenic River Act, the Coastal
Barriers Protection Acts and the Coastal Zone Management Act are
not considered to be ARARs. The National Environmental Policy
Act and other laws, including those listed above, have been
considered and it has been determined that the selected remedy
will have no significant adverse environmental impacts and will
have significant beneficial impact on human health and the
environment.
Cost-Effectiveness
The selected remedy provides product extraction and
treatment of contaminated soil and groundwater and has the lowest
estimated remedial cost of all action alternatives. Combined
soil treatment and product extraction minimizes the cleanup
timeframe and associated costs. The treatment methods included
in the alternative have been proven effective in the treatment
of similarly contaminated materials and are expected to attain
ARARs at Area D.
Utilization of Permanent Solutions and Alternative Treatment
Technologies
The FAA, in cooperation with the USEPA and State of New
Jersey, has determined that the selected remedy utilizes
permanent solutions and treatment technologies to the maximum
extent practicable. This determination was made based on the
comparative evaluation of alternatives with respect to long-term
effectiveness and permanence, reduction of toxicity, mobility or
volume through treatment, short-term effectiveness,
implementability, and cost, as well as the statutory preference
for treatment as a principal element and State and community
acceptance.
The main difference between alternatives in terms of long-
term effectiveness is related to the manner in which the
alternative treats soil contamination. The selected alternative
may not provide the destruction efficiencies of a soil
incineration alternative, but i-t will provide a permanent
-------
24
reduction in the toxicity of soil contaminants while meeting
cleanup objectives and, therefore, be effective in the long-term.
The selected alternative is expected to provide long-term
effectiveness of a degree similar to the soil washing and the
soil incineration alternatives and greater than the other
alternatives examined.
The selected remedy is one of four alternatives (5, 6, 7 and
8) which provide a reduction in toxicity, mobility or volume of
all three media of concern through treatment. Alternatives 5 and
7 may provide a greater degree of toxicity reduction through the
destruction efficiency of soil incineration and more conventional
groundwater treatment methods. However, the selected alternative
has been proven effective in reducing soil and groundwater
contaminant toxicity at sites of similar volatile organic and
petroleum hydrocarbon contamination. Alternative 8 has not been
thoroughly proven and,.therefore, reductions in toxicity of soil
or groundwater contamination may not be as great as anticipated.
The selected remedy provides the greatest short-term
effectiveness. It has the shortest estimated timeframe to meet
cleanup levels due to the fact that soil remediation and product
extraction are concurrent. In alternatives involving soil
excavation, product removal must be completed prior to conducting
soil excavation to ensure contaminated soils are excavated to the
greatest extent possible. Also, soil excavation alternatives
create greater short-term risks due to the volatilization of
organics in the excavated soils.
The selected remedy is less implementable than the no action
or containment alternatives (Alternatives 1, 2 and 3), but those
alternatives do not offer the degree of protection offered by the
selected alternative. The selected remedy is feasible both from
a technical and administrative standpoint. The availability of
services and materials is somewhat limited but not as limited as
for on-site incineration or soil washing alternatives.
The selected remedy is the lowest cost alternative except
for the no action alternative. Its cost is one hundred times
less than the estimated cost of soil incineration alternatives.
The New Jersey Department of Environmental Protection has
indicated that the selected remedy for Area D is considered to
be acceptable.
Overall, community acceptance of the chosen alternative was
good. Opposition was limited to a written comment from the
Township Committee of the Township of Egg Harbor indicating a
preference for Alternatives 5 or 7.
Preference for Treatment as a Principal Element
The principal threats at Area D include the presence of the
-------
25
floating hydrocarbon plume and soil and groundwater contamination
associated with the presence of the plume at Area D. The
selected remedy satisfies the statutory preference for treatment
as a principal element in addressing the human health and
environmental threats posed by the site. Off-site cement kiln
incineration will provide treatment of extracted product, soil
venting with off-gas treatment will treat soil contamination and
in situ biodegradation will treat groundwater contamination.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Remedial Action Plan for Area D was released
for public comment on August 4, 1989. The Proposed Plan
identified Alternative 6 (off-site product incineration, soil
venting and in situ biodegradation) as the preferred alternative.
FAA reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
-------
26
RESPONSIVENESS SUMMARY
AREA D, JET FUEL FARM
FAA TECHNICAL CENTER
The purpose of this responsiveness summary is to review
public response to the Proposed Remedial Action Plan for Area D
and public comment on other remedial alternatives considered but
not recommended. It also documents the FAA's consideration of
such comments during the decision-making process and provides
answers to any major comments raised during the public comment
period.
The responsiveness summary for the Area D Jet Fuel Farm is
divided into the following sections:
* Overview - This section briefly describes the feasibility
study (FS) process used to develop and evaluate remedial
responses for Area D, the remedial alternative recommended
within the Proposed Remedial Action Plan and any impacts on
the proposed plan due to public comment.
* Background on Community Involvement - This section provides
a summary of community interest in the site and identifies
key public issues. It also 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.
* Remedial Design/Remedial Action Concerns - This section
describes public concerns which are directly related to
design and implementation of the selected remedial
alternative.
OVERVIEW
Area D is a Jet Fuel Farm at the FAA Technical Center and is
under investigation for potential environmental contamination.
The FAA Technical Center is located at the Atlantic City Airport
in Atlantic County, New Jersey. This Responsiveness Summary
addresses remediation and public response to the Proposed
Remedial Action Plan for Area D only.
A summary of the site background, the alternatives
evaluated, and a comparison of alternatives are presented in the
Area D Proposed Remedial Action Plan and are more fully described
in the Feasibility Study Report. Both documents, as well as
other supporting information, are available for public review at
the information repository located at the Atlantic County
Library, 2 South Farragut Avenue, Mays Landing, New Jersey.
-------
27
BACKGROUND ON COMMUNITY INVOLVEMENT
This section provides a brief history of community
participation in the investigation and remedial planning
activities conducted at Area D.
Throughout the investigation and feasibility study period,
the USEPA, NJDEP and The Pinelands Commission have been directly
involved through proposal and project review and comments.
Periodic meetings have been held to maintain open lines of
communication and to keep all parties abreast of current
activities.
Prior to the public release of site-specific Area D
documents, the FAA Technical Center 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 included herein as Appendix A.
On August 4, 1989, FAA mailed the Area D Proposed Remedial
Action Plan to concerned parties on the list described above.
Also on that day, a notice appeared in The Press, the local
Atlantic City newspapers, summarizing the feasibility study
process, the remedial alternatives considered and the preferred
remedial alternative. The announcement also identified the time
and location of a public meeting to be held to discuss the
proposed action, .the location of the information repository, the
length of the public comment period, and the address to which
written comments could be sent. Public comments were accepted
from August 4, 1989 through September 5, 1989.
A public meeting was held on August 30, 1989, at 7:00 p.m.
at the Atlantic County Library in Mays Landing, New Jersey. The
Area D site investigations, feasibility study process and
proposed remedial alternative were discussed. FAA
representatives included: Robert B. Heitsenrether, Project
Manager; Michael G. Beres, Manager of the
Engineering/Environmental Branch; and Tony Fazio, Hazardous
Materials and Special Projects Staff. Vincent Petruzello, Chief
of the Program Support Branch, represented the USEPA Emergency
and Remedial Response Division; and Robert Hayton, Case Manager,
represented the NJDEP Bureau of Federal Case Management. Other
NJDEP staff and FAA's contractor, TRC Environmental Consultants,
Inc. (TRC) also attended (see Appendix B).
SUMMARY OF MAJOR QUESTIONS AND COMMENTS
This section addresses public comments received during the
August 4, 1989 through September 5, 1989 public comment period.
Two questions were raised at the public meeting, and one set of
-------
28
written comments received. A summary of these comments and the
FAA reponse are presented below.
Public Meeting Comments
Comment: James W. Herzog, a representative of the City of
Atlantic City, Department of Public Works, questioned the
accuracy of the remedial cost estimate for Alternative 6,
indicating it may be low.
FAA Response: The cost estimate was developed on the basis of
published cost information and is expected to be within the -30%
to +50% accuracy range called for under current guidance.
Considering the relative magnitude of cost of the other
alternatives, Alternative 6 would remain the most cost-effective
alternative even if the actual cost was 100% greater than the
estimated cost.
Comment: James W. Herzog, a representative of the City of
Atlantic City, Department of Public Works, questioned the
relative degree of environmental problems associated with other
areas of the FAA Technical Center Site, especially with respect
to potential impacts to drinking water quality.
FAA Response: The FAA is attempting to address the areas of
environmental contamination in the order of urgency. Area D was
identified as a priority site due to its location near the Upper
Atlantic City Reservoir and the need to formulate and implement a
final remedial plan and thereby supplant interim remedial
measures. For specific information regarding other sites and
associated environmental concerns, the public is encouraged to
visit the information repository and review the environmental
investigation reports and, as they become available, the
feasibility studies and Proposed Remedial Action Plans for other
areas of the FAA Technical Center. The information repository is
located at the Atlantic County Library in Mays Landing, New
Jersey.
Written Comments
Comment: The Township Committee of the Township of Egg Harbor
provided a written comment indicating that the Township is
desirous of having contaminants removed in the most thorough
manner feasible and that it is the consensus of the governing
body that Alternatives 5 and 7 are most desirable, with a
preference for Alternative 7 which provides off-site
incineration. The Township .Committee further expressed its
desire to see an expeditious implementation of the selected
remedial alternative.
FAA Response: The Feasibility Study process allows for a
detailed evaluation of each remedial alternative using nine
evaluation criteria, as well as a comparative analysis between
alternatives. While Alternatives 5 and 7 provide for
-------
29
incineration of contaminated soil and product and may provide
greater contaminant destruction efficiencies than in situ
treatment methods, this advantage is offset by short-term risks
posed by contaminant volatilization during excavation activities,
implementation difficulties due to technical feasibility and/or
availability of services, and the cost differential between these
alternatives and other alternatives considered. Based on the
comparative analysis of the eight alternatives under
consideration, Alternative 6 was identified as
which provides the best balance among the nine
criteria.
the alternative
evaluation
REMEDIAL DESIGN/REMEDIAL ACTION CONCERNS
Public comments which specifically addressed the chosen
remedial alternative were limited to a question about the
estimated remedial cost. This question and the associated FAA
response were presented in the previous section. Overall, due to
the minimal public input received during the comment period,
currently identified public concerns associated with the remedial
action are limited.
-------
FIGURES, APPENDICES AND TABLES
-------
TECHNICA
BUILDING
PLEASANTVILLE, NJ QUADRANGLE
USGS 7.5 MINUTE SE RLE S T OP O G R A P HI C
O 1OOO 3OOC
SCALE, FEET
FIGURE 1 FAA TECHNICAL CENTER
-------
•CORV WELL ASSOCIATED
WITH I>UEL TANK
ACTIVE ABOVE-QROUNO
JET FUEL TANKS
1420.000 GALLONS EACH I
_-''I I
FILTER BANK ORVWELL-^
TANK TRUCK
UNLOADING MANIFOLD
(FUEL ADDED TO TANKS)
FILL TRUCK LOADING STAND
(FUEL REMOVED FROM TANKS)
ABANDONED UNDERGROUND
STORAGE TANKS
1367,000 GALLONS EACHI
TECHNICAL CCHTCN
mv(«iiac<>i*ii*iiitT tit.
AREA D SITE PLAN
-------
S/7E PLAN
ACTIVE
ABOVE-GROUND^-^
JET FUEL TANKS
DRYWELLS
i — V
DRYWELL
APPROX. EXTENT OF
FLOATING PRODUCT PLUME
Scale (approx.)
FIGURE 3
AREA D HYDROCARBON PLUME
-------
APPENDIX A
The Honorable William J. Hughes
Member, United States House of Representatives
Central Park East, Building 4, Suite 5
222 New Road
Linwood, NJ 08221
The Honorable James L. Usry
Mayor of Atlantic City
City Hall
Tennessee Avenue and Bacharach Boulevard
Atlantic City, NJ 08401
The Honorable John W. Mooney
Mayor of Galloway Township
300 Jimmy Leeds Road
Galloway Township, NJ 08201
The Honorable James J. McCullough
Mayor of Egg Harbor Township
Egg Harbor Township Municipal Offices
RD 2A, Box 262
Linwood, NJ 08221-9621
The Honorable John J. Percy, III
Mayor, Township of Hamilton
21 Cantillon Boulevard
Mays Landing, NJ 08330
Mr. Richard E. Squires
Atlantic County Executive
1333 Atlantic Avenue
Atlantic City, NJ 08401
The Honorable Frank Lautenberg
United States Senator
1 Gateway Center
Newark, NJ 07102
Colonel Richard C. Cosgrave
Commander 177th Fighter Interceptor Group
400 Langley Road, ANGBACYIAP
Pleasantville, NJ 08232-9500
The Honorable William Gormley
New Jersey Senate, Second District
1333 Atlantic Avenue
Atlantic.City, NJ 08401
-------
Mr. John F. Gaffney
Chairman Freeholder-at-Large
201 Shore Road
Northfield, NJ 08225
Mr. Terrence Moore
Executive Director, New Jersey Pinelands Commission
Springfield Road
P. 0. Box 7
New Lisbon, NJ 08064
Mr. Neil Goldfine
Executive Director, Atlantic City
Utilities/Water Department
29 South New York Avenue
Atlantic Ci'ty, NJ 08401
Ms. Louise Speitel
Atlantic County Environmental Society
205 Tremont Avenue
Absecon, NJ 08201
Environmental Response Network
ATTN: Ms. Doreen Khebzou
104 East Sterling Drive
Absecon Highlands, NJ 08201
Ms. Ellen Hyatt
Department of Health and Institutions
201 Shore Road
Northfield NJ 08225
Mr. Tom Augspurger
Environmental Contaminants Specialist
U.S. Fish and Wildlife Service
P. 0. Box 534, 705 White Horse Pike
Absecon, NJ 08201
-------
APPENDIX B
PLEASE SIGN IN
PUBLIC MEETING WEDNESDAY, AUGUST 30, 1989
PROPOSED REMEDIAL ACTION PLAN (PRAP)
FOR AREA D - JET FUEL FARM
FEDERAL AVIATION ADMINISTRATION TECHNICAL CENTER
ATLANTIC CITY AIRPORT, NJ 08405
YOUR NAME ADDRESS
V/<^£f%oT P/TflUfrfrTm A f-fofoWL A A-^a AJ-S.-v'i
;r
4
p.?
* C. lg*£C FA A
FAA--
\i7.\ .
I/ A LIT
i\OK+\M.c* i^ J •'£• i / v}\i'tt"-\ Jl lo '.<.{£( *\G
H
-------
USE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
JACOB K. JAVnS FEDERAL BULGING
NEW YORK, NEW YORK 10278
SEP 2 5 19S9
Mr. E.T. Harris, Director
FAA Technical Center
ACT-1
Atlantic City International Airport
Atlantic City, New Jersey 08404
Re: FAA Technical Center Record of Decision (ROD) for Site D, Jet
Fuel Farm
Dear Mr. Harris:
This is to notify you that the United States Environmental
Protection Agency (USEPA) has reviewed the FAA's ROD and supporting
documents for remediating jet fuel contamination at Area D, Jet
Fuel Farm, at the FAA Technical Center and that USEPA concurs with
the remedy as stated.
The remedial action consists of the following:
* free product extraction and off-site cement kiln
incineration,
* ground water extraction and addition of nutrients for
subsequent re-injection and in-situ biodegradation of
volatile organic compounds (VOCs),
* soil venting, a system which extracts gas from the soil pore
space,
* use of off-gas treatment unit for off-gas from soil venting,
consisting either of catalytic incinerator for combustion of
VOCs to carbon dioxide and water, or activated carbon
adsorption of VOCs,
* operation, monitoring, and maintenance of the system.
We look forward to a continued cooperative working relationship
with you and the FAA Technical Center staff to address
environmental concerns at the facility. If you have any questions
374"
-------
-2-
regarding the subject of this letter, please call me at (212) 264-
2525, or have your staff contact Mr. Lance Richman, the facility
Project Manager, at (212) 264-6665.
Sincerely,
William J
Acting Re1
P.E.
Sministrator
cc: Christopher J. Daggett, Commissioner
New Jersey Department of Environmental
Protection
Robert Hayton
New Jersey Department of Environmental
Protection
Mr. T. Flatley, FAA
Mr. R. Heitsenrether, FAA
-------
APPENDIX D "
it\ •*'
c: Constantine Sibanon-cristoff, V C
Regional Adainistrator, USEPA • • cX^'^
Lance Richman, Project Manager, USEPA ^ >
Malinda Dower, DEP
-------
TABLE 1
CONTAMINANTS OF CONCERN - AREA D
MONITORING WELLS
Concentration
VOLATILE ORGANICS (ppb)
Benzene
Toluene
Ethylbenzene
Xylene (total)
SEMI-VOLATILE (BNAs) (ppb)
Naphthalene
Phenol
2-Chlorophenol
INORGANICS (ppb)
Chromium, Total
Nickel, Total
Lead, Total
Maximum
4,000
3,100
530
4,700
1,000
303
192<3>
344<3>
68<3>
Average
390.18
325.41
67.53
404.00
79.82
33.79
29.73
36.51
12.94
Detected
Frequency
5/17
4/17
6/17
5/17
6/17
9/16
8/17
6/17
9/17
SURFACE SOIL
Concent rat ion
Detected
160
150
160
560
600
570
7,700
4,000
EPA
Carcinogenic
Classification
A(D
D<2)
D<2)
—
—
D<2)
D<2>
B2<»
O EPA Carcinogen Classification: A = Known Human Carcinogen
B2 = Probable Human Carcinogen (based on animal studies -
Inadequate evidence in humans)
D = Not Classified
Reference-Memorandum from S. Lee (Toxics Integration Branch), Updated Reference Dose and
Cancer Potency Numbers for use in risk assessment (November 16, 1987)
<2) Drinking Water Regulations and Health Advisories, U.S. EPA Office of Drinking Water (December 1988).
(3) Inorganic concentrations are based on the analysis of unfiltered ground water samples.
-------
[RfO-CPF]
TABLE 2
DOSE-RESPONSE PARAMETERS USED IN THE ASSESSMENT OF NONCARCIMOGEN 1C AND CARCINOGENIC RISK - AREA D
Bsca»»ss*c*3acaaBecsaaa3Bs=css3ssoaa3SS=s3ssssscsss!sssa=a==sssaas==s=sss====sssr=s===========s=s=s===sss5:==s=s
Contaminant of
Concern
Benzene
Ethyl benzene
Toluene
Xylene
Naphthalene
Phenol
2-Chlorophenol
Chromium •
Nickel
Lead
(1)
AIS
(mg/kg/day)
--
9.70E-01
4.30E-01
4.00E+00
4.10E-01
4.00E-02
5.70E-03
2.50E-02
1.40E-02
--
(2)
AIC
(mg/kg/day)
--
1.00E-01
3.00E-01
2.00E+00
4.10E-01
4.00E-02
5.70E-03
5.00E-03
1.00E-02
1.40E-03
(3)
RfD
(mg/kg/day)
--
1.00E-01
3.00E-01
2.00E+00
4.00E-01
6.00E-01
5.00E-03
5.00E-03
2.00E-02
1.40E-03
(4]
Health Advisories (ppb)
1-Day
[Adult]
200
30000
20000
40000
--
--
(6)
(6) 1000
1000
(7)
Long-Term
[Adult]
--
3000
10000
10000
--
--
--
800
600
--
I (5)
Carcinogenic
Potency
Factor -1
(mg/kg/day)
2.90E-02
--
--
--
--
--
--
--
--
(1) Subchronic Acceptable Intake - Memorandum from S Lee (EPA, Toxics Integration Branch), Updated Reference Dose and Cancer
Potency Numbers for use In risk assessment (November 16, 1987)
(2) Chronic Acceptable Intake - Memorandum from S Lee (EPA, Toxics Integration Branch), Updated Reference Dose and Cancer
Potency Numbers for use in risk assessment (November 16, 1987)
Source RfD for lead
(3) Reference Doses (RfDs) of Oral Exposure- EPA Office of Research and Development, Health Effects Assessment Suimary Tables,
First Quarter FY89, January 1989
(4) Health Advisories - Drinking Water Regulations and Health Advisories. U.S. EPA Office of Drinking Water (December, 1988)
(5) Carcinogenic Potency Factor (Oral) - EPA Office of Research end Development, Health Effects Assessment Summary Tables,
First Quarter FY89, January 1989
(6) Reference Dose (RfD) of Oral Exposure - Drinking Water Regulations and Health Advisories, U.S. EPA Office of Drinking Water
(December, 1988)
(7) Reference Dose (RfD) - Superfund Public Health Evaluation Manual, October, 1986
EPA is currently reviewing lead as a carcinogen and may calculate a cancer potency factor (CPF) in the future. The RfD
value listed in this table has been revoked. Since a CPF does not exist at present, the old RfD is being retained so
that the noncarcinogenic potential of lead can be evaluated.
-------
TABLE 3
EXPOSURE ASSESSMENT ASSUMPTIONS
Note: All exposures assume 70-kg adult as ('receptor
GROUND WATER - INGESTION
Most Probable Case; Ingest 1.0 liter/day (1/d), 250 days/year, over 10
years at average contaminant concentration
Worst Case: Ingest 2.0 1/d, 250 days/year over 20 years at maximum
contaminant concentration
SURFACE SOIL - INGESTION
Most Probable Case; Ingest 0.05 g/exposure, 12 exposures/year over 10
years
Worst Case; Ingest 0.01 g/exposure, 6 exposures/year over 20 years
SURTACS SOIL - DIRECT CONTACT
Most Probable Case; Direct contact 12 times/year over 10 years; contact
rate: 0.85 g/exposure over 3,400 cm2 skin area
Worst Case; Direct contact 24 times/year over 20 years; contact rate:
0.85 g/exposure over 3,400 cm2 skin area
SUBSURFACE' SOIL -'INGESTION
Most Probable Case; Ingest 0.05 g/exposure with 20 exposures/year over 2
years
Worst Case; Ingest 0.1 g/exposure with 10 exposures/year over 2 years
SUBSURFACE SOIL - DIRECT CONTACT
Most Probable Case; Direct contact 120 times/year over 2 years; contact
rate: 0.85 g/exposure over 3,400 cm2 skin area
Worst Case: Direct contact 240 times/year over 2 years; contact rate:
0.85 g/exposure over 3,400 on2 skin area
-------
(NC-rik-SUM]
TABLE 4 SUMMARY OF NONCARCINOGENIC. CHRONIC RISKS PRESENT AT FAA AREA D
RISK TYPE
s Noncarclnogenlc
NONCARC IMOGEN 1C. CHRONIC HAZARD INDICES ASSOCIATED WITH EXPOSURE (1)
EXpOaUre
Scenario
Adult
RMlUtlC
Worat-Cete
Adult
Hoet Probable
Case
^JWlt^Mlf^Mlfr nf
Loncemneni OT
Concern
Benzene
Ethyl benzene
Toluene
Xylene
Naphthalene
Phenol
2-Chlorophenol
ChroMlua
Nickel
Lead
Benzene
Ethylbenzene
Toluene
Xylene
Nephthelene
Phenol
2-Chlorophenol
ChroMluM
Nickel
Lead
GROUND WATER
Ingeetlon
NA
2.96C-02 ,
5.7K-02
1.31E-02
1.406-02
2. 826-03
NA
1.07E-01
4. 816-02
1.36E-01
NA
9.44E-04
1.526-03
2.82E-04
2.79C-M
7.B7E-OS
NA
4.15E-03
1.2BE-03
6.ME-03
SURFACE
Ingestlon
NA
3.07E-10
9.5VE-11
5.37E-11
NA
1.92E-10
2.73E-10
i.«K-or
NA
2.74E-07
NA
3.8JE-11
1.20E-11
6.71E-12
NA
2.40E-11
3.41E-11
1.85E-08
NA
3.42E-08
SOIL
Direct Contact
NA
1.82E-Or
5.70E-08
3.19E-08
NA
1.UE-07
1.63E-07
8.78E-03
NA
1.63E-M
NA
4.5AE-08
1 .436-08
7.98E-09
NA
2.KE-08
4.06E-08
2.20E-05
NA
4.07E-05
SUBSURFACE
Ingeetlon
NA
3.5BE-09
1.12E-W
6.26E-10
NA
2.24E-09
3.19E-09
1.72E-06
NA
3. 206-04
NA
8.9SE-10
2.806-10
1.57E-10
NA
5.59E-10
7.97E-10
4.31E-07
NA
7.99E-07
SOIL
Direct Contact
NA
3.65E-07
1.UE-07
4.396-08
NA
2.28E-07
3.25E-07
1.74E-M
NA
3.246-04
NA
1.82E-07
5.706-08
3.196-08
NA
1.UE-07
1.63E-07
8.78E-05
NA
1.43E-04
(1) Maxlaui Contenlnant Concentration! Are Uted to Develop the Adult RealUtlc Worst-Gate Scenario
Average Contaminant Concentration* Are U»*d to Develop the Adult Host Probable Case Scenario
• Indicate* that Hazard Index I* Greater Than 1, and Hay Illicit Chronic, Noncarclnogenlc Health Effect* In Human*.
NA Not Applicable
-------
[C-rsk-SUH]
TABLE 5 SUMMARY OF CARCINOGE1NC RISKS PRESENT AT FAA AREA D
RISK TYPE : Carcinogenic
CARCINOGENIC RISK ASSOCIATED WITH EXPOSURE (1)
c Kposurc
Scenario
Adult
Realistic
Worst-Case
Adult
Host Probable
Case
Coot orni nsnt o*
Concern
Benzene
Ethyl benzene
Toluene
Xylene
Naphthalene
Phenol
2-Chlorophenol
Chromium
Nickel
Lead
Benzene
Ethyl benzene
Toluene
Xylene
Naphthalene
Phenol
2-Chlorophenol
Chromium
Nickel
Lead
GROUND WATER
Ingest ion
6.48E-04 E
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.58E-OS W
HA
NA
NA
NA
NA
NA
NA
NA
NA
Ingest ion
6.23E-11
NA
NA
NA
NA
NA
NA
NA
NA
NA
7.78E-12
NA
NA
NA
NA
NA
NA
NA
NA
NA
SURFACE SOIL
Direct Contact
L 5.29E-10 L
NA
NA
NA
NA
NA
NA
NA
NA
NA
L 1.32E-10 L
NA
NA
NA
NA
NA
NA
NA
NA
NA
Ingest ion
1.04E-11
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.59E-12
NA
NA
NA
NA
NA
NA
NA
NA
NA
SUBSURFACE SOIL
Direct Contact
L 1.06E-09
NA
NA
NA
NA
NA
NA
NA
NA
NA
L 5.29E-10
NA
NA
NA
NA
NA
NA
NA
NA
NA
L
L
=========
(1) = Maximum Contaminant Concentrations Are Used to Develop the Adult Realistic Worst-Case Scenario
Average Contaminant Concentrations Are Used to Develop the Adult Host Probable Case Scenario
-4 -7
W = Carcinogenic Risk Falls Within EPA Target Range of 10 through 10
E * Carcinogenic Risk Exceeds Target Range
L = Carcinogenic Risk Is Less Than Target Range
NA = Not Applicable
-------
TABLE 6
COMPARISON AMONG ALTERNATIVES
OVERALL PROTECTIVENESS OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative I: No action
Baseline risks remain unchanged
Alternative 2: Fencing, capping and slurry wall construction
Provides some containment but risks associated with ground
water contaminants not addressed; approaches but does not
attain ARARS
Alternative 3:
Tree product extraction and on-site storage;
Soil excavation and on-site storage;
Ground water extraction and injection with in situ
biodegradation
Provides temporary containment for future treatment,
short-term risks associated with soil excavation; interim
remedy; attains ARARs
Alternative 4:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
Treatment reduces risks associated with product and ground
water; potential for increased short-term risks due to soil
excavaton; attains ARARs
Alternative S:
Free product extraction and onrsite rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Contaminants from all media treated on-site; potential for
increased short-term risks due to soil excavation; attains
ARARs
Alternative 6:
Free product extraction and off-site cement kiln incineration;
Soil venting;
Ground water extraction and injection with in situ
biodegradation
Contaminants from all media treated off-site or in situ;
short-term risks minimal; short time frame to meet
objectives; exceeds ARARs '
Alternative 7:
Free product extraction and off-site cement kiln Incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Contaminants from all media treated on-slte or off-site;
potential for increased short-term risks due to soil
excavation; exceeds ARARs
Alternative 8:
Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
Contaminants from all media treated on-site or off-site;
potential for increased short-term risks due to soil
excavation; exceeds ARARs
-------
TABLE 7
COMPARISON AMONG ALTERNATIVES
COMPLIANCE WITH ARARs
Alternative 1:
Alternative 2:
No action
Fencing, capping and slurry wall construction
t
ARARs are not attained
Approaches but does not attain ARARs; does not meet the goals
of SARA
Alternative 3:
Free product extraction and on-site storage;
Soil excavation and on-site storage;
Ground water extraction and injection with in situ
biodegradation
Attains ARARS; approval for long-term, on-site storage of
wastes required; meets interim remedy criteria under SARA
Alternative 4:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
Attains ARARs; off-site soil disposal is not consistent with
SARA
Alternative 5:
Free product extraction and on-site rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Exceeds ARARs; consistent with SARA preference for permanent
solutions and reductions in mobility, txocity and volume
Alternative 6:
Free product extraction and off-site cement kiln incineration;
Soil venting;
Ground water extraction and injection with in situ
biodegradation
Exceeds ARARs; consistent with SARA preference for permanent
solutions and reductions in mobility, toxicity and volume,
as well as use of innovative technologies
Alternative 7:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Exceeds ARARs; consistent with SARA preference for permanent
solutions and reductions in mobility, toxicity and volune
Alternative 8:
Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
Exceeds ARARs; consistent with SARA preference for permanent
solutions and reductions in mobility, toxicity and volume,
as well as use of innovatie technologies
-------
TABLE 8
COMPARISON AMONG ALTERNATIVES
LONG-1ERM EFFECTIVENESS AND PERMANENCE
Alternative I:
Alternative 2:
No action
Fencing, capping and slurry wall construction
Baseline risks remain unchanged
Contaminants are untreated but contained;
Long-term monitoring of containment area and ground water
required;
Risks associated with ground water contamination not addressed
Alternative 3:
Free product extraction and on-site storage;
Soil excavation and on-site storage;
Ground water extraction and injection with in situ
biodegradation
Contaminants are treated or removed and contained for future
treatment;
Long-term monitoring of containment areas required;
Treatment reduces risks associated with ground water
contamination, possible future exposures to product and soil
also reduced
Alternative 4:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
Contaminants are treated or removed and contained off-site;
Off-site soil disposal significantly reduces potential risks
on-site; relatively low risks at off-site disposal site;
Treatment reduces risks associated with product and ground
water contamination
Alternative 5:
Free product extraction and on-site rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Contaminants from all media are treated on-site;
Potential risks are low relative to Alternatives 1. 2 or 3
Alternative 6:
Free product extraction and off-site cement kiln incineration;
Soil venting;
Ground water extraction and injection with in situ
biodegradation
Contaminants from all media are treated off-site or in situ;
Potential risks are low relative to Alternatives 1, 2 or 3
Alternative 7:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Contaminants from all media are treated on-site or off-site
Potential risks reduced since contaminated materials are
partially removed off-site during remediaton; off-site risks
are low relative to Alternatives I, 2 or 3
Alternative 8:
Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
Contaminants from all media are treated on-site or off-site.
Potential risks are low relative to Alternatives I, 2 or 3.
-------
TABLE 9
COMPARISON AMONG ALTERNATIVES
REDUCTION OF TOXICITY (T). MOBILITY (H) OR VOLUME (V) THROUGH TREATMENT
Alternative 1: No action
No reductions in T. M or V;
Site conditions remain unchanged
Alternative 2: Fencing, capping and slurry wall construction
No reductions in T or V (H is decreased through containment
but not to the same degree as Alternative 3)
Alternative 3:
Free product extraction and on-site storage;
Soil excavation and pn-site storage;
Ground water extraction and injection with in situ
biodegradation
No immediate reductions in T or V of soil or product (H
reduced by containment);
T of ground water reduced (H reduced through gradient control)
Alternative 4:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
Reduced T of ground water (M reduced through pumping);
Reduced T and V of product (H reduced, through pumping);
(Reduced overall H of soil through containment, although
short-term potential H of soil and product increases due to
transport off-site)
Alternative 5:
Free product extraction and on-site rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Reduced T of ground water (H reduced through pumping);
Reduced T and V of product (H reduced through pumping);
Reduced T of soil
Alternative 6:
Free product extraction and off-site cement kiln incineration;
Soil venting; i
Ground water extraction and injection with in situ
biodegradation
Reduced T of ground water (H reduced through pumping);
Reduced T and V of product (H reduced through pumping, short-
term potential H of product increases due to transport
off-site);
Reduced T of soil
Alternative 7:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Reduced T of ground water (H reduced through pumping);
Reduced T and V of product (H reduced through pumping, short-
term potential H of soil and product increases due to
transport off-site);
Reduced T of soil
Alternative 8:
Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
Reduced T of ground water (H reduced through pumping);
Reduced I of product; V of product not reduced but converted
into reuseable product (short-term potential H of product
increases due to transport off-site);
Reduced T of soil
Note: Reductions in toxicity. mobility or volume through means other than treatment (e.g.. containment, pumping, etc.) are presented
parenthetically. '
-------
TABLE 10
COMPARISON AMONG ALTERNATIVES
SHORT-TERM EFFECTIVENESS
Alternative 1: No action
Baseline risks remain unchanged;
Remedial response objectives not achieved
Alternative 2: Fencing, capping and slurry wall construction
Risks to remediation workers may occur during cap construction
due to surface soil contamination;
Remedial response objectives not achieved
Alternative 3:
Free product extraction and on-site storage;
Soil excavation and on-site storage;
Ground water extraction and injection with in situ
biodegradation
Health and safety factors'1' exist during initial remediation
of contaminated area;
Remedial response objectives not achieved until final
disposition of soils and product (10 years or more)
Alternative 4:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
Health and safety factors'1' exist during remediation;
Remedial response objectives achieved within 7 years
Alternative 5:
Free product extraction and on-site rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Health and safety factors'') exist during remediation;
On-site incineration could potentially pose additional
short-term respiratory risks;
Remedial response objectives achieved within 9 years
Alternative 6:
Free product extraction and off-site cement kiln incineration;
Soil venting;
Ground water extraction and injection with in situ
biodegradation
Health and safety factors'1' limited to direct contact risks
because excavaton is not included;
Soil venting could potentially pose short-term respiratory
risks but risks are more controllable than with soil
excavation alternatives;
Remedial response objectives achieved within 6 years
Alternative 7:
Alternative 8:
Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
Health and safety factors'1' exist during remediation;
Remedial response objectives achieved within 7 years
Health and safety factors'1' exist during remediation;
Remedial response objectives achieved within 9 years
'*' Health and safety factors include potential inhalation of volatilized organics and dust and direct contact with jet fuel and soils
contaminated with petroleum hydrocarbons.
-------
fABlE II
COMPARISON AMONG AtltRHAIlVlS
IKPLCrCNIABUm
AlKR-
HAiiVE
DMtRIPIOM Df ALIUtMAIIWt
ILUM1CAL fLAilBMLIIY
ADMINISIRAIIVE fEASlBILHY
AVAhABIUIV Of
SUV1C1S AM) HAIER'AIS
I: He action
2: Fencing, casing and slurry Hall construction
3: free product extraction and •n->ll* storage;
Soil excavation and on-slto storage;
Ground water extraction and Injection wltk In situ
blodegradatlen
No Implementation
Construction easily Implemented;
Cap could Inhibit future rrmvdlatlon;
Honltorlng could pottntlally miss a
failure of cap or ilurrjr wall
Conitructlon easily Implemented;
facilitate* (uturo re*edlatlmn;
Easily monitored
No Implementation required
Ho Inter-agency coordination required
Requlrei authorliatlon to store
waste >90 day* and to relnject
e>tracted ground water;
Hay require future coordination tor
final disposition of product and
toll
Ho (•pleaantallen required
Supplier* of tervlcei and equipment
readily a»allebla
Suppllari of tervlcei and equipment
generally retdlly avallakla;
In iltu blodtgredatlon lervlcet aay ke
lOMvhat Halted
4: free product extraction and off-ille covent kiln
Incineration;
Sell ancavatlon and off-ilto dlipoial;
Ground xater entractlon and Injection «lth In situ
blodegradatlon
S: free product eilractlon and oo-tlte rotary kiln
Incineration;
Soil encavalton and on-tlto rotary kiln Incineration;
Ground oater eitracllon and Injection "Ith carbon
adsorption
Construction easily lapleaented;
Honltorlng and future remediation not
Inhibited
Requires set-up and start-up of en-site
Incinerator;
technical problems possible;
Honltorlng and future rMediation not
Inhibited
Requires aulhorliatlon to dispose of
certain soils as Industrial ttaste
and to relnjecl ••traded ground
water
Requires aulhorliallon to operate
on-slte Incinerator and to
relnject treated ground vater;
Requires del I sting of treated soli
Cei
sites
peclly of off-site disposal sit
Milted; a»allablllly of In sll
blodegradallon services se«m*iat
limited
Availability of rotary kilns and
experienced operaters la limited
6: free product extraction and off-site cenwnt kiln
Incineration;
Soil venting;
Ground water entract Ion and Injection with In situ
blodegradatlen
Conitructlon fairly easily Iwpleaentad;
Hlnor technical problems possible;
Due to *ln situ* nature of treatment.
monitoring of completeness of
treatment hindered
Requires authorisation for soil
venting emissions and relnjectlon
of extracted ground water
Availability of soil venting and In
situ blodegrttfatlon services Is
some«hat limited
7; Free product extraction and •ff-slto cement kiln
Incineration;
Soil excavation and off-site rotarv kiln Incineration;
Ground water extraction and Injection with carbon ,•
adsorption
Construction easily Implemented;
Honltorlng and future remediation not
Inhibited
Requires authorliallon to relnject
treated ground water
Capacity of off-site rolary kiln
facilities limited
8: free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and Injection with
UV oxidation
Requires set-up and start-up of on-slte
soil waihlng system;
technical problems possible;
Honltorlng and future remedlaton not
Inhibited
Requires dellstlng of treated soil
and authorlxtlon to relnject
treated ground water
AvalUbllllt of soil wuhlng equipment
and enperlenced personnel extremely
limited;
Availability ol off-site dlstlllallen
services and UV oxidation equipment
somewhat limited
-------
TABLE 12
COUP, ,ON AMONG ALTERNATIVES
COST
TOTAL TOTAL TOTAL
CAPITAL COST NET DIM COST PRESENT WORTH1
Alternative 1:
Alternative 2:
Alternative 3:
No action - - -
Fencing,
capping
Free product
and slurry
extraction and
wall construction
on-site
storage;
$2,377.000
6,348,000
$113
200
.000
.000
$2
7
,986.000
,858,000
Soil excavation and on-site storage;
Ground water extraction and injection with in situ
biodegradation
Alternative 4: Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site disposal;
Ground water extraction and injection with in situ
biodegradation
7.079.000
190,000
8.722.000
Alternative 5: Free product extraction and on-site rotary kiln incineration;
Soil excavation and on-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
48,228,000
112.000
58,009,000
Alternative 6: Free product extraction and off-site cement kiln incineration;
Soil venting;
Ground water extraction and injection with in situ
biodegradation
286,000
200,000
583,000
Alternative 7: Free product extraction and off-site cement kiln incineration;
Soil excavation and off-site rotary kiln incineration;
Ground water extraction and injection with carbon adsorption
32,949,000
92.000
39,649,000
Alternative 8: Free product extraction and off-site distillation;
Soil excavation and soil washing;
Ground water extraction and injection with UV oxidation
8,904,000
224,000
10,954.000
1 Includes 20X contingency. See Appendix A for detailed cost estimates.
-------
TABLE 13
SITE 0 • Alternative A:
Fre« Product Extraction and Off-Site Cement Kiln Incineration, Soil Venting, Groundwater
Extraction and Injection with In-SItu llodegradatlon
It en
CAPITAL COSTS - DIRECT
Security
-Fenced ft anow fence)
-Uarnlna Slgne
Equipment Decontamination
-Rental of ate** cleaner
•Conetruct Decon Pit
Excavate Pit
Polyethylene Tarpaulin
Total Equipment Decon Coat*
Engineering Mgmt. Mob/Demob
(1 trailer)
Free Product Removal
-Transport of product
-Dleposal at Cement Kiln
Incinerator
VacuiM Extraction
<4" diameter. 21 10-ft wells)
-Uell Conetruct Ion I Naterlala
-«» Pipe (PVC)
•Health and Safety (17X)
-Mobl llxatlon
-Industrial Blower*
-Catalytic Incineration Unit
Total VacuiM Extraction Costs
Quantity Unit*
I'
1.200 linear ft
6 algna
30 day*
100 cu.yd.
1200 aq.ft.
2 month*
1) load*
73,000 gallon*
210 ft
1950 ft
1 time
2 blower*
2 unit*
Unit Price
S2.01
•32.00
«50.00
S2.59
iO.31
•360.00
SI, 575. 00
SO. 22
S35.00
S12.40
1600.00
S675.00
S60.000.00
Bail* year
1987
1987
19M
1987
1987
1988
1989
1989
1986
1987
1985
1987
1989
Adjustment
Reference factor
11 1.05
11 1.05
23 1.02
11 1.05
11 1.05
11 1.02
38 1
38 1
15 1.09
11 1.05
17
6 1.12
16 1.05
33 1
1989
Unit costs
S2.11
S33.60
SSI. 00
S2.72
SO. 33
» 567. 20
SI, 575. 00
SO. 22
S38.15
S13.02
S672.00
S708.75
160.000.00
1989 Years Present
Costs (OiM> Value(OtH)
S2.532.60
S201.60
S1.530.00
S271.95
S390.60
S2. 192.55
•734.40
S23.625.00
116,060.00
SB, Oil. 50
S25.389.00
SI, 361. 96
1672.00
$1.417.50
S120.000.00 .
1156,851.96
-------
TABLE 13 (Continued)
Adjustment 1989 1909 tears Present
It e« Quantity Unit* Unit Price Basis year Reference Factor Unit cost* Costs (O1M) Value(OW)
Soil Confirmation Sampling
•lor Ings
(10 -20 ft borings) 200 ft $40.00 1959
-Analysis
Total Petroleum Hydrocarbon* 10 samples »100.00 I960
Product/Grounduater Extraction
-Well Construction and Materials
2 -4" Diameter Uells BO ft . »50.00 1986
1 -«• Diameter Well 40 ft . $50.00 1986
-Health and Saf«ty(17X)
•Centrifugal Pumps (10 gpm each) 5 pump* $445.00 1987
•Ejector PUMP (Include* pump, 1 pump M. 210. 00 1989
200 ft hose, 200 ft air Una)
Total Extraction Cost •.
35 1 MO. 00 $8.000.00
16 1.02 $102.00 $1.020.00
,
IS 1.09 $54.50 M, 360.00
IS 1.09 $54.50 $2,180.00
U $1,111.80
11 1.05 $467.25 $2.336.25
1 $3,210.00 S3.210.00
$13,198.05
Product Storage)
-Piping to Existing Tank
(4» PVC)
400 ft.
$12.40
1987
It
1.05
$13.02 $5,208.00
Orounduater Injection
•Infiltration Galleries
2 total (100ft*3ft*4ft each)
1/2 cu. yd. backho*
-Geotextll* lining
•Crushed Stone Fill (3/4")
Total Injection Cost
444
\
289
444
cu.yd. $3.41 1987 11 1.03 $3.58 SI. 589.74
•q.yd. $3.10 1985 6 1.12 $3.47 $1.003.41
cu.yd. $18.45 1987 11 1.05 $19.37 $8.601.39
' $11,194.54
Piping To And From Treatment System
-(2" dlaM. PVC In trench) 1.200 ft
$6.19
1988
23
$6.19
$7.428.00
-------
TABLE 13 (Continued)
Adjustment 19B9 1989 Tears Present
!t«s Quantity Units Unit Price Basis year Reference Factor Unit coats Costs ; (OiN) V«lue(OiM)
•lodegradatlon Syste*
(assuM 20 opm Mount*)
-Polyethylene MU T«nk(2000 gal) 1 tank SI.580.00 19B8 22 1.02 *1,611.60 SI.611.60
•Mobilization 1 tine S600.00 1985 6 1.12 1672.00 (672.00
Total Slod^radatlon Coata S2.28).60
mmmmmmummmmmmmmmmmmmmmmmmm*mmmmmmmmmmmmmmmmmmmmmmmmmmm*mmmm*mmmmmmmmmmmmmmmmmmm*mmmmmmmmmmmmmmmummmmmmmmmmmmmmmmmummmmmmmmmmmmmfmmmmmmmmmmmmmmmmmfmmmmmmmmmmmmm
Direct Capital Coat Subtotal ~ $250,530.30
CAPITAL COSTS • INDIRECT
Engineering and Deslgn(IU) 18 S27.558.33
Legal and AdMtnlstratlve(3X) IB S7.515.91
TOTAL CAPITAL COSTS S2B5.604.54
-------
TABLE 13 (Continued)
AdJintMnt 1989 1989 Yeera Preaent
Iteai Quantity Unlta Unit Price latla year Reference Factor Unit coaU Coata (MM) Value(OlM)
OPERATION AND MAINTENANCE COSTS
-Orounduater Monitoring
Sanpllnfl 40 tempi ea S25.00 1980 9
Analytic
Priority Pollutant • VOC 40 aaoplea >190.00 1988 36
•Infiltration Gallery Malnt. 100 labor hrs S16.56 1987 12
r
•Air tabling 12 anntha . S3BO.OO 1988 16
•lloctefl. Syate* Maintenance 480 labor hra 116.56 1987 12
•Chenlcala 12 anntha S1.SOO.OO 1988 25
•Vactua Extraction Syeteia 1 year S8.000.00 1988 33.34
Op«r. and Malnt.
TOTAL NET PRESENT VALUE OF 0 i M
SUBTOTAL
CONTIHGENCV(20X)
TOTAL PRESENT VALUE COST FOR ALTERNATIVE A
1.S7 S39.2S SI, 570.00 9 S9.043.20
1.02 S193.M S7.752.00 9 S44.6S1.S2
1.05 ' S17.39 SI. 738. 80 6 S7.581.17
1.02 S387.60 S4.6S1.20 2 S8.093.09
1.0S S17.39 S8.346.24 6 S36.389.61
1.02 S1.S30.00 S18.360.00 6 S80.049.60
1.02 S8.160.00 S8.160.00 2 S14, 198.40
S200.006.S8
S48S.611.12
S97, 122.22
SS82.733.34
-------
TABLE 14
SUMMARY OF MAJOR ARARs AND TBCs
CHEMICAL-SPECIFIC ARARs/TBCs
* New Jersey Safe Drinking Water Act (NJSDWA)
- NJSDWA MCLs for: benzene - 1 ppb (final)
xylene (total) - 44 ppb (final)
chromium - 50 ppb (final)
lead - 50 ppb (final)
* Safe Drinking Water Act (SDWA)
- SDWA MCLs for: toluene - 2,000 ppb (proposed)
ethylbenzene - 700 ppb (proposed)
s
total volatile
* New Jersey Soil Cleanup Action Level
- Defines 1 ppm as action level for total voiati
organics and 100 ppm as action level for total
petroleum hydrocarbons in soils
* New Jersey Ground Water Quality Standards
- NJAC 7:9-6 specifies groundwater quality standards for
Class 6W2 waters: phenol (total) - 300 ug/1
toluene ++
ethylbenzene ++
naphthalene ++
LOCATION-SPECIFIC ARARs/TBCs
No location-specifics ARARs/TBCs were identified as being
applicable to Area D remediation
ACTION-SPECIFIC ARARs
* Resource, Conservation and Recovery Act (RCRA)
- 40 CFR 262 Subparts B and C and 264 Subparts I and J
specify manifest and pre-transport requirements for the
temporary storage and off-site transport of hazardous
waste
* Superfund Amendments and Reauthorization Act of 1986
(SARA)
- Section 121(c) allows the transfer of hazardous
substances or pollutants only to a facility operating
in compliance with RCRA or other Federal laws, where
applicable, and all State laws
* Clean Air Act
- 40 CFR 50 New Source Performance Standards establish
emission standards for new sources and require use of
Best Available Control Technology (BACT)
(++ = combined total shall not exceed 50.0 ug/1)
-------
TABLE 14
SUMMARY OF MAJOR ARARs AND TBCs
(Continued)
ACTION-SPECIFIC ARARs (Continued)
• Office of Air Quality Planning and Standards , : ; '
- "Issues Relating to VOC Regulation Cutpoints, Deficieneiea and
Deviations" provides guidance on emission limit goals is ozone
nonattainment areas which are applicable to air strippers and ether
vented extraction techniques. /,.
• New Jersey Air Regulations
- NJAC 7:27-13 specifies ambient air quality standards for selected
contaminants.
- NJAC 7:27-17 specifies control requirements and prohibition of air
pollution by toxic substances.
- NJAC 7:26-16 specifies emissions limitations for volatile organic
compounds.
- NJAC 7:26-17 requires the use of emission control apparatus.
• New Jersey Water Quality Regulations
- NJAC 7:14A-1 specifies New Jersey Pollutant Discharge Elimination
System Requirements.
• New Jersey Solid and Hazardous Waste Management Regulations
- NJAC 7:26-7.3-4 establish requirements of hazardous waste generators
(consistent with RCRA requirements).
------- |