United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-90/105
September 1990
Superfund
Record of Decision
FAA Technical Center, NJ
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50272-101
REPORT DOCUMENTATION i. REPORT NO. J-
PAGE EPA/ROD/R02-90/105
4. TltteandSubBtti
SUPERFUND RECORD OF DECISION
FAA Technical Center, NJ
First Remedial Action - Final
7. Author!*)
0. Performing Organization Nam* and Addrew
12. Sponsoring Organization NMTW and Addree*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1* Aeuuion No.
I. RtportDaU
09/28/90
t.
8. Performing Organlzadon Repl No.
10. ProjecvTt.il/Work Unit No.
11. ContractfC) or Orant(G) No.
(C)
(O
13. Type ol Report • Period Covered
800/000
14.
15. Supplementary Nolea
18. AtaMct (Limit: MO word*)
The 5,000-acre FAA Technical Center site is 8 miles northwest of Atlantic City, in
Atlantic County, New Jersey. The site is comprised of several installations including
the Atlantic City International Air Terminal, the Upper Atlantic City Reservoir, and
the facilities of the FAA Technical Center. Forested land, commercial, and residential
areas are adjacent to the site. A salvage yard (Area 20A), located southeast of the
Atlantic City International Terminal, has been used for storing old aircraft parts,
automobiles, scrap metal, and empty 55-gallon drums. Soil contamination of Area 20A by
PCBs and VOCs has resulted from leaking and deteriorating drums that have been stored
onsite. The total volume of contaminated soil was estimated to be 930 cubic yards.
Additionally, onsite ground water has been contaminated by VOCs leaching out of the
contaminated soil and into the shallow and intermediate aquifers. A ground water
contaminant plume, identified during State site investigations in 1983, is limited to
the shallow aquifer below the salvage yard area. This Record of Decision (ROD)
addresses soil and ground water contamination. The primary contaminants of concern
affecting the soil, and ground water are VOCs including TCE and toluene; other organics
including PCBs; ,and metals including chromium.
(See Attached Page)
NJ
17. Document Analytic a. OeacrlpMr*
Record of Decision - FAA Technical Center,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (TCE, toluene), other organics (PCBs), metals (chromium)
b. Men*
•dT<
e. COSAT1 FkWGroup
it. Availabllty SutmneM
1». Security Claa* (Thl* Report)
None
20. Security Ctau fthl* Page)
None
21. No. ol Pane*
52
22. Price
(See ANSI.Z39.18)
Sw Initnjctiont on Aewme
OPTIONAL FORM 272 (4-77)
(Formerly NDS-35)
Department ol Commerce
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EPA/ROD/R02-90/105
FAA Technical Center, NJ
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes excavating 930 cubic yards of
contaminated soil, temporarily storing the soil onsite before transporting the soil
offsite for rotary kiln incineration, followed by offsite disposal of residual ash;
pumping and onsite treatment of contaminated ground water using air stripping and
emissions controls, if necessary; reinjecting onsite the treated ground water from the
upper aquifer (located upgradient of the contaminated area) ;' discharging the treated
ground water from the intermediate aquifer to an existing borrow pit area; and
continuing site access restrictions. The estimated present worth cost for this
remedial action is $6,300,000, which includes an annual O&M cost of $86,000 for eight
years.
PERFORMANCE STANDARDS OR GOALS? Chemical-specific ground water cleanup levels are
based on SDWA MCLs or stricter State standards, including 1,1,1-TCA 26 ug/1 (State
MCL), PCBs 0.5 ug/1 (State MCL), toluene 2,000 ug/1 (SDWA MCL) and chromium 50 ug/1
(SDWA MCL). Soil cleanup levels are based on State action levels including PCBs
5 mg/kg for the 0 to 0.5-foot interval and 25 mg/kg for soil at greater depths.
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DECLARATION STATEMENT
RECORD OF DECISION
Area 20A - Salvage Yard
FAA Technical Center
FACILITY NAME AND LOCATION
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 20A,
the Salvage Yard 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 20A.
Both the United States Environmental Protection Agency, Regional
Administrator (Region II) and the Commissioner of the New Jersey Department of
Environmental Protection concur with the selected remedy (See Appendices A and
B).
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 at Area 20A by treating
contaminated soils and ground water. The selected remedy for Area 20A
includes the following components:
- Excavation of approximately 930 cubic yards of soil and transport
off-tite for incineration at a permitted rotary kiln and;
- Air stripping of organic compounds in the ground water.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
MRS Score (date):
NPLRank:
FAA Technical Center, Area 20A - Salvage Yard
Atlantic Comity, New Jersey
USEPA Region II
39.65; 12/09/88
N/A
ROD
Date Signed:
Remedy/ies:
Capital Cost:
O&M/Year:
Present Worth:
FAA; 09/28/90
Off-Site Rotary Kiln incineration of contaminated soil and
groundwater extraction with air stripping
$ 5.6 Million (present worth)
$ 86,000 average/yr. for 8 yrs (present worth)
$ 6.3 million
LEAD .
Remedial/Enforcement: Federal Facility (Federal Aviation Administration)
Primary Contact (phone): Keith C. Buch, Project Manager, FAA, (609) 484-6644
Secondary Contact (phone): Carla M. Struble, Project Manager, EPA, (212) 264-4595
WASTE
Type (metals, PCB, &c):
Medium (soil, g.w., &c):
Origin:
EsL Quantity cu.yd.:
Volatile Organic Compounds, BNA Extractable Compounds, PCBs
and metals
Soil and groundwater
Drum Storage, Underground Waste Oil Storage Tanks
930 cu. yards soil
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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 employ treatment that reduces toxicity, mobility or volume of
hazardous substances, pollutants, and contaminants as a principal element.
/2^>
•/
Donald M. Johnson (Date) '
Manager, Plant Engineering and
Services Division. ACM-400
FAA Technical Center
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DECISION SUMMARY
RECORD OP DECISION
Area 20A - Salvage Yard
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 ground water 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 land and commercial and residential areas. A large forested tract
containing vno commercial or residential property exists 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 Citj
Expressway. All residential areas in the vicinity of FAA appear to be
upgradient or otherwise isolated from the ground water flow at the Technical
Center.
Area 20A - Salvage Yard is located southeast of the Atlantic Cits
International Terminal. It consists of two adjacent salvage yards associatec
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with FAA Buildings 206 and 207. The area, which is fenced, is approximately
1,600 feet south of the Atlantic City Reservoir and is currently used for
storage of old aircraft parts, trucks and cars, scrap metal, and empty
55-gallon drums. A location map for Area 20A is provided in Figure 2. A site
plan for Area 20A is provided in Figure 3.
SITE HISTORY AND ENFORCEMENT ACTIONS
The first significant development of what is now FAA property came during
the 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
Roy F. Weston (Weston) to conduct an assessment of potential pollution sources
that could impact the then-proposed .Atlantic City wellfield. The assessment
included a review of all data on possible contaminant sources in the area,
limited field investigation of these sources, and soil and ground water
sampling at the five areas considered most threatening to ground water
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 20A is one of the areas identified by the Weston Study. During the
Weston Study, a-site reconnaissance showed the presence of deteriorated and
leaking drums in the northern half of the Salvage Yard Area, with evidence of
past spillage (visibly stained surface soils). Historical aerial photographs
showed that drums were previously stored along the northern and westerr.
portions of the Building 206 Salvage Yard. No record of previous enforcement
actions has been identified for Area 20A.
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The FAA's Environmental Investigation (El) of Area 20A was conducted in
two phases between December 1986 and December 1988. The most significant
environmental problem identified during the El is the presence of high PCS
levels in the"soil. Phase I analytical results confirmed that soil and ground
water in the vicinity of the Salvage Yard had been impacted by past activities
at the area while Phase II results delineated the extent of contamination. A
risk assessment was included in the SI Technical Report, prepared in May 1988
and revised March 1989.
In August 1989, the Feasibility Study (FS) for Area 20A was distributed to
the 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.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Area 20A Proposed Remedial Action Plan (PRAP) was issued to interested
parties (see Appendix C) on February 15, 1990. On March 1, 1990 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 March 1 to April
2, 1990. The newspaper notification also identified the Atlantic County
Library as the location of the Information Repository.
A public meeting was held on March 28, 1990. At this meeting,
representatives from the FAA, TRC Environmental Consultants, Inc., USEPA and
NJDEP were available to answer questions about Area 20A and the remedial
alternatives under consideration. A list of attendees is attached (See
Appendix D).
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 20A of the
FAA Technical Center in Atlantic County, New Jersey, chosen in accordance with
CERCLA, as amended by SARA and, to the extent practicable, the NCP. The
decision for Area 20A is based on the administrative record.
SCOPE AND ROLE OF RESPONSE ACTION
The remedial action described herein addresses the environmental problems
associated with Area 20A, the Salvage Yard.
SUMMARY OF AREA CHARACTERISTICS
Area 20A contamination appears to be mainly attributable to drum storage
in the Salvage Yard. The media of concern at Area 20A include contaminated
soil and contaminated ground water. A major area of soil contamination is
located along the western edge of the Building 206 Salvage Yard where
concentrations of PCBs and volatile organic compounds in the surface soil
exceed NJDEP Soil Action Levels. An additional area of soil contamination was
identified during Phase II investigations when two underground waste oil
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storage tanks were removed in December 1988. Soil in the excavation was found
to contain levels of both PCBs and petroleum hydrocarbons which exceed NJDEP
Soil Action Levels.
The areal and vertical extent of surface and subsurface soil contamination
was approximated using analytical results. The total volume of contaminated
soil was estimated to be 930 cubic yards.
The volatile organic compounds in the surface and subsurface soil at Area
20A are the likely source of dissolved organic constituents detected in the
shallow and intermediate aquifers. The corttaminant plume is fairly well
defined in the shallow aquifer (Upper Cohansey Sand) and is generally limited
to the immediate Salvage Yard Area. Contaminants in the intermediate aquifer
(Middle Cohansey Sand) were found in monitoring wells (80-100 feet deep) up to
500 feet from the Salvage Yard. In well ACMUA-8S, the concentration of
volatiles is 6 ppb, just above detection limits. Downward movement of organic
constituents into the Middle Cohansey Sand appears to have resulted due to the
significant downward vertical hydraulic gradients at the area.
Inorganic constituents were also detected in the ground water samples
collected at Area 20A, although there was little correlation between Phase I
and Phase II results. In general, the inorganic constituents are thought to
be attributable to suspended solids in the unfiltered ground water samples.
This hypothesis is supported by the collection of both filtered and unfiltered
ground water samples in the Phase II investigations of other areas at the FAA
Technical Center. While unfiltered samples exhibited elevated levels of
several metals, including those detected at Area 20A, the filtered samples
typically exhibited only one metal, zinc, at levels less than regulatory
standards. Since metals adsorbed to silt or clay particles or incorporated in
precipitates are not likely to be transported through the aquifer, the direct
application of regulatory standards to the unfiltered metals data may not be
appropriate at Area 20A.
SlftMARY OF SITE RISKS
A baseline risk assessment was conducted for Area 20A on the basis of
Phase I investigations. It is presented in Section 9.3 of the Final
Environmental Investigation/Feasibility Study Report (Volume I, TRC, March
1989). A discussion of the impact of Phase II analytical results on
calculated risks is presented in Section 1.3.3.2 of the Focus Feasibility
Study for Area 20A (TRC, August 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 20A included:
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Volatile Organic Contaminants
Toluene-
1,1,1-Trichloroethane
1,1-Dichloroethene
Tetrachloroethene
1,2,4-Trichlorobenzene
Base/Neutral and Acid Extractable Compounds
* Bis(2-ethylhexyl)phthalate
Pesticides/PCBs
* PCBs
* 4,4-DDT
Metals
* Chromium
* Cadmium
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. Us* of this approach makes underestimation of the actual cancer risk
highly unliktly. Cancer potency factors are derived from the results of human
epidemiclogical 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
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compared to the RfD. RfDs are derived from human 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 on 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 subchronic exposure because efforts have been
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 20A are presented in Table 2.
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 20A, 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
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access to the Salvage Yard. Potential exposure pathways evaluated include the
ingestion of ground water, 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. During the Environmental Investigation,
ambient air monitoring was conducted with samples analyzed for particulates,
metals, PCBs, and volatile and semivolatile compounds. No PCBs were
detected. Toluene, naphthalene and several metals were detected, all at
concentrations well below their Threshold Limit Values (TLVs). Because of the
relatively low contaminant concentrations, and limited exposures associated
with the site, a qualitative risk assessment concluded that current risks are
not substantial. During remedial excavation activities, however, generation
of fugitive dust could increase, requiring the use of appropriate personal
protection equipment.
For each potentially significant exposure pathway quantitatively assessed,
exposure assumptions were made for realistic worst-case and most probable
exposure scenarios. 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 20A. 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 20A 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.
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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 contamination 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 probability or
range of probabilities of developing 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)"^-, 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"^ 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"* 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 10~4 and 10~7 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 20A concluded that the
chronic noncarcinogenic risk under the realistic worst-case scenario due to
direct contact with subsurface soils is "significant" (ratio of estimated body
dose level to RfD or AIC/AIS is greater than one) based on PCB levels.
Assuming future usage of the intermediate aquifer, bis(2-ethylhexyl)phthalate
shows a "significant" chronic noncarcinogenic risk associated with ground
water ingestion under realistic worst-case conditions. A summary of
noncarcinogtnic 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 scenarios are within or less than the EPA
target range of 10~* to 10~7. Direct dermal contact with surface soils under
the future realistic worst-case and most probable exposure scenarios also
appears to be within or less than this target range. The carcinogenic risk
associated with direct dermal contact with subsurface soils exceeds 10""1
(calculated at 6.52 x 10~4) for the realistic worst-case scenario based on the
detected level of PCBs. Future scenarios which evaluate the carcinogenic
hazard associated with ground water ingestion also predict the carcinogenic
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risk (due to the presence of 1,1-dichloroethene) to exceed 10~4 (5.84 x 10~4)
for the realistic worst-case scenario. For the most probable exposure
scenario, the-carcinogenic risks are within the EPA target range. A summary
of carcinogenic risks at Area 20A is presented in Table 5.
The environmental risk assessment, conducted on the basis of the same COCs
as the human health risk assessment, concluded that concentrations of 4,4-DDT
and PCBs are present in high enough concentrations to induce chronic toxic
effects most likely manifested as reductions in reproductive success. Specific
predictions regarding the individual species are not possible due to a lack of
specific population data.
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 20A, 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
Ten remedial alternatives were developed for analysis in the Area 20A FS.
Three of these alternatives were eliminated during the preliminary screening
due to questionable use of acceptable engineering practices, effectiveness, or
significantly greater costs. These included Alternative 2, Capping of On-Site
Wastes, Alternative 8, Off-Site Fluidized Bed Incineration and Ground Water
Extraction with Carbon Adsorption, and Alternative 10, In Situ Chemical
Stabilization and Ground Water Extraction with Air Stripping. The remaining
seven alternatives are described 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.
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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.
Ground Water Extraction and Injection
Ground water extraction and injection systems are being proposed for the
collection of ground water at Area 20A, and will be combined with a ground
water treatment system. The shallow aquifer system will consist of 3
extraction wells near the downgradient edge of ground water contamination, and
5 injection wells located upgradient of the Salvage Yard. The total pumping
rate from the 3 extraction wells will be approximately 18 gallons per minute
(26,000 gallons per day). The injection wells are expected to significantly
decrease the amount of time required to recover the contaminated ground water,
and prevent the collection of significant quantities of uncontaminated water.
The intermediate aquifer system will consist of 2 extraction wells near the
downgradient edge of the volatile organic plume. The total pumping rate from
the two wells will be approximately 140 gallons per minute (202,000 gallons
per day). Due to the high transmissivity of the intermediate aquifer, direct
subsurface reinjection of treated ground water into the aquifer would not
significantly improve the efficiency of contaminated ground water extraction.
Also, direct subsurface reinjection of 140 gallons per minute would require
the construction of an extensive reinjection system. Therefore, discharge to
an existing borrow pit area, which will act as a recharge basin, is proposed
for the treated ground water from the intermediate aquifer.
Ground Water Treatment
Each of the remedial alternatives which involves ground water extraction
and injection also includes ground water treatment. While the specific method
of treatment considered for inclusion in each alternative is described in the
individual alternative descriptions, other considerations are common to all
ground water treatment alternatives. These include the presence of metals in
the ground water and potential impacts to the proposed treatment system.
Analysis for metals such as calcium or zinc was not included in the
Environmental Investigation. The presence of these metals in the ground water
could potentially foul the proposed treatment processes without some method of
pretreatment. Therefore, prior to the final design of the ground water
treatment system, the presence or absence of such inorganics must be-defined
and, if present, pretreatment may be required.
Soil Excavation
Excavation of contaminated soils will be performed using conventional
excavation techniques. Excavation will begin in areas where the highest PC3
concentrations were detected and will proceed to areas of less contamination.
Pre-remediation and post-remediation sampling will identify the extent of
excavation and will confirm when excavation activities are complete. On-site
soils handling will depend to some extent on the remedial alternative that is
implemented, and is discussed in more detail in the alternative descriptions.
Water will be used to control dust during excavation activities. Any
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stockpiled soil remaining on-site overnight will be covered with a heavy-duty
tarpaulin to minimize wind-blown transport of contaminated soil. If
necessary, stockpiled soils will be sprayed with water before covering. The
total volume of contaminated soil to be removed is estimated at 930 cubic
yards.
Alternative 1 - No Action
Cost: $0.93 million Time to Implement; Not applicable
The no action alternative was developed as required by the NCP. Under
this alternative ground water monitoring of the shallow and intermediate
aquifers would continue. No additional actions would be taken to remediate
Area 20A. No contaminants would be treated or contained and existing health
and environmental risks would remain.
Alternative 3 - On-Site Storage of Soil, Ground Water Extraction
with Air Stripping
Cost; $1.6 million Time to Implement; 10 years or more to
completion
This alternative was developed as a containment alternative, in accordance
with the NCP.
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.
Ground water extraction and reinjection were previously described. Air
stripping, consists of the mass transfer of a volatile chemical from a liquid
phase to air by bringing a flow of air in contact with the liquid. Emissions
controls on the stripping column may be required to collect exhausted
contaminants.
Alternative 4 - Off-Site RCRA Landfill, Ground Water Extraction
with Carbon Adsorption
Cost: S2.2 million Time to Implement; 3 years to reach
cleanup goals
This alternative was also developed as a containment alternative, in
accordance with the NCP. Due to its ground water treatment element, it could
also be considered to fall within the treatment range for alternatives
required by the NCP.
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Contaminated soil would be excavated and shipped off-site to a permitted
landfill facility. The extent of excavation was addressed previously.
Excavated soils would be temporarily stockpiled in an intermediate staging
area prior to transport off-site. The purpose of the staging area is to
permit uninterrupted progress of excavation activities while transport trucks
are loaded and manifested.
Ground water extraction and reinjection were previously described. Carbon
adsorption would be used to treat ground water prior to reinjection. The
process consists of bringing contaminated ground water into contact with a bed
of granular activated carbon, where contaminants are held by physical and/or
chemical forces on the activated surface of the carbon itself.
Alternative 5 - On-Site Rotary Kiln Incineration, Ground Water
Extraction with Air Stripping
Cost: $5.6 million Time to Implement: 3 years to reach
cleanup goals
This alternative was developed to meet NCP treatment criteria. The proven
characteristics of the chosen treatment methods and the treatment of all waste
materials allow this alternative to conform with the NCP criterion for an
alternative which minimizes long-term management.
Contaminated soil would be excavated, as previously described, and treated
on-site using rotary kiln incineration. This alternative would involve the
construction of a temporary incineration facility on-site.
Ground water extraction and reinjection with air stripping would be as
described previously for Alternative 3.
Alternative 6 - On-Site Infrared Incineration, Ground Water
Extraction with Carbon Adsorption
Cost; $4.7 million Time to Implement; 3 years to reach
x N cleanup goals
This alternative was developed to meet NCP treatment criteria. The proven
characteristics of the chosen treatment methods and the treatment of all waste
materials allow this alternative to conform with the NCP criterion for an
alternative which minimizes long-term management.
This alternative is similar to Alternative 5, with the exception that an
infrared incinerator is used to process contaminated soils instead of a rotary
kiln incinerator.
Ground water extraction and reinjection with carbon adsorption would be as
described previously for Alternative 4.
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Alternative 7 - Off-Site Rotary Kiln Incineration, Ground Water
Extraction with Air Stripping
Cost: $6.3 million Time to Implement; 3 years to reach
cleanup goals
This alternative was developed to meet NCP treatment criteria. The
alternative will provide treatment as a primary component, per the NCP.
Contaminated soil would' be excavated and shipped off-site to a permitted
incineration facility. The incineration ash will be disposed of at a
permitted facility, authorized to accept such a waste.
Ground water extraction and injection with air stripping was described
previously for Alternative 3.
Alternative 9 - In Situ Vitrification. Ground Water Extraction with
UV Oxidation
Cost: $3.9 million Time to Implement; 3 years to reach
cleanup goals
This alternative was developed to meet the NCP criterion for developing an
alternative which uses innovative treatment technologies.
Contaminated soil would be treated through in situ vitrification. The
process converts contaminated soils into a stable, glass-like matrix.
Graphite electrodes are placed into the soil to form a square array. A
conductive path is created by placing flaked graphite and glass frit in an "X"
pattern between the electrodes, and high voltage is applied to initiate
melting of soils at approximately 3,660°F. The molten soil zone expands while
organic contaminants in the soil are pyrolyzed, and off-gases are collected
beneath a hood for treatment.
Ground water would be extracted and reinjected as described previously.
Treatment of- the extracted ground water would be accomplished using chemical
treatment. A unit would be set up on-site and extracted ground water would be
fed through the system prior to reinjection.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The seven alternatives identified above were initially evaluated on the
basis of technical effectiveness and feasibility, public health ar.d
environmental effects, institutional issues, and costs, as presented in the
Focus Feasibility Study. Subsequently these alternatives were also evaluated
using criteria derived from the National Contingency Plan and the Superfur.d
Amendments and Reauthorization Act of 1986 (SARA), as presented in the PRAP.
These criteria relate to the SARA amendment to Section 121 of CERCLA (Sectior.
121{b)(D) and Section 300.430(e) (9) (iii) 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
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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.
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 toxicity, mobility or volume through treatment evaluates the
degree to which an alternative reduces risks through the use of 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 feasibility,
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 seven alternatives on the basis of the
evaluation criteria presented above follows.
Overall Protection - The preferred alternative. Alternative 7, provides
the greatest overall protection of human health and the environment through
treatment of both soil and ground water, proven reliability and effectiveness,
and minimal short-term and long-term risks. Alternatives 5 and 6 protect
human health and the environment but on-site incineration may result in
potential increased short-term risks, and long-term monitoring is associated
with on-sit« backfilling of treated soils. Alternative 9 also provides a high
degree of human health and. environmental protection but, due to the innovative
nature of in situ vitrification in treating PCBs, the reliability and
capability of the alternative in attaining ARARs and minimizing short-term and
long-term risks is not as well-defined as for the preferred alternative.
Alternative 3 provides treatment of ground water and allows for future
treatment of soil, although short-term risks associated with soil excavation
and storage exist. Alternative 4 provides ground water treatment but is
limited with respect to its overall protectiveness due to the fact that soil
is not treated. Alternative 1, which offers no soil or ground water
treatment, is the least protective alternative.
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Compliance with ARARs - Alternatives 7, 5, 6 and 9 are expected to exceed
chemical-specific ARARs based on their soil and ground water treatment
components, and are listed in descending order of confidence. Alternative 4
will attain ARARs but, due to its off-site RCRA landfill component, soil will
not be treated. Therefore, it is expected that chemical-specific ARARs for
contaminated soils will be attained but not exceeded. Alternative 3, which
involves temporary on-site containment of contaminated soils, may attain
chemical-specific ARARs for soils if a complete remedy is implemented within
10 years. Chemical-specific ARARs for ground water would be exceeded under
both Alternatives 3 and 4. Each of Alternatives 3, 4, 5, 6, 7 and 9 are
expected to comply with action-specific ARARs.' Alternative 1 will not attain
ARARs.
Long-Term Effectiveness and Permanence - Alternatives 7 and 4 provide the
greatest long-term effectiveness because contaminated soils are transported
off-site for treatment/disposal, minimizing residual risks on-site.
Alternatives 5, 6 and 9 treat soil contamination on-site with residuals also
remaining on-site and potentially requiring long-term monitoring. Alternative
3 could eventually be effective in reducing residual risk but requires
long-term monitoring until the final fate of the soils is determined.
Alternative 1 provides no treatment of soil or ground water and is not
considered to be effective in the long-term because residual risks are not
reduced.
Reduction of Toxicity, Mobility or Volume - Alternatives 5, 6 and 7 are
expected to provide the greatest reduction in contaminant toxicity through PCB
destruction via incineration. Alternative 9 may also provide a great degree
of toxicity reduction but in situ vitrification is relatively unproven for PCB
remediation. Alternative 3 provides a reduction in ground water toxicity
through treatment and allows for potential future reductions in the toxicity,
mobility or volume of soil through treatment while Alternative 4 does not use
treatment of soil to provide any reductions of these characteristics.
Alternative 1 offers no treatment of the contaminated media.
Short-Term Effectiveness - Alternatives 3, 4, 5, 6 and 7 all require
contaminated soil excavation and on-site handling, resulting in potential
short-term risks. Alternatives 3, 5 and 6 have added potential short-term
risks associated with on-site treatment or storage. Alternative 9 treats
soils in situ and collects off gases for treatment, but its performance in
minimizing short-term risks at PCB sites is unproven. Alternative 1 involves
minimal short-term risk but will not achieve cleanup goals.
Implementability - Alternative 1 offers the greatest implementability
followed by Alternative 3, which involves conventional technologies with
proven reliability and performance. Alternatives 4 and 7 also involve
conventional technologies but implementation may be limited by available
landfill or. incinerator capacities. Alternatives 5 and 6 involve a
conventional technology combined with one that is rapidly developing and,
therefore, may have limited equipment availability. Alternative 9 is
implementable but, due to its innovative nature, reliability and performance
are not well-documented and the availability of equipment and services is very
limited.
Cost - Alternative 1, the no action alternative, has the lowest associated
cost. Alternatives 3 and 4 follow with total costs in the 1 to 2 million
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dollar range. Alternatives 9, 6 and 5 have estimated total costs ranging from
3.9 million to 4-9 million dollars. Alternative 7 is the highest cost
alternative, estimated at a total cost of 6.6 million dollars. Alternatives 3
and 4 have the lowest cost sensitivity. Variations in soil volumes,
treatment/disposal costs or discount factors result in potential total costs
varying over a range of 700,000 to 3.6 million dollars for Alternatives 5, 6,
7 and 9.
State Acceptance - The preferred alternative is acceptable to the NJDEP
(See NJDEP letter of concurrence. Appendix B).
Community Acceptance - Community acceptance of the preferred alternative
has been evaluated on the basis of public comments as is described in the
Responsive Summary of the Record of Decision. The alternative appears to be
acceptable to the public.
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 20A (See USEPA and NJDEP Letters of Concurrence,
Appendices A & B). This selection is identical to that presented in the
Proposed Remedial Action Plan. 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.
The selected remedial alternative is Alternative 7 - off-site rotary kiln
incineration of contaminated soil and ground water extraction with air
stripping.
Contaminated soils will be excavated and temporarily stockpiled on-site
prior to transport off-site for rotary kiln incineration. Off-site
incineration will provide a permanent reduction in toxicity although soil
excavation and on-site handling involve short-term risks. Dust control
measures such as the use of water and temporary soil covers (tarpaulins) will
minimize the short term risks associated with soils handling.
Ground water treatment will also be conducted concurrent with soil
treatment. Ground water will be extracted via three ground water extraction
wells for the upper aquifer and two ground water extraction wells for the
intermediate aquifer. The extracted water will be processed through air
stripping columns where volatile organics will be removed from the liquid.
Due to the transfer of contaminants from the aqueous phase to the airstream,
emissions control units will likely be required on the air strippers. The
treatment system, including the emissions control units, will be designed to
meet the substantive requirements of New Jersey air pollution control
regulations.
Once treated, the water extracted from the upper aquifer will he
reinjected upgradient of the contaminated area while the water from tr.e
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intermediate aquifer will be discharged to an existing borrow pit area. To
meet cleanup standards, it was estimated that extraction of three (3)
contaminated aquifer volumes will be required over a period of three years.
The proposed remedy has been developed to meet Federal and State ARARs for
drinking water and soil quality. Pursuant to the New Jersey Ground Water
Quality Standards, N.J.A.C. 7:9-6 et seq., the ground water at FAA is
classified as GW2. Class GW2 ground water is designated for potable use.
Ground water corrective action criteria have been developed for FAA's Area 20A
pursuant to N.J.A.C. 7:9-6 et seq. and N.J.A.C. 7:14A-1 et seq. and are listed
in Table 7 under Chemical-Specific ARARs/TBCs, MCLs will be used as cleanup
levels for ground water. When stricter than Federal MCLs, promulgated New
Jersey MCLs will be used as the cleanup levels. Because no chemical-specific
ARARs applicable to soil contamination were identified, soil cleanup levels
are based on NJDEP Soil Action Levels, which are not ARARs but are To Be
Considered criteria (TBCs). Specifically, soil action levels for total
petroleum hydrocarbons and total volatile organic compounds will be applicable
to remediation of Area 20A. For PCBs, soil cleanup levels of 5 ppm for the 0-
to 0.5-foot interval and 25 ppm for greater soil depths will be used.
Because the risk assessment and PCB cleanup levels are both based on the
fact that Area 20A is located within the FAA Technical Center, a federal
property with access restrictions, these access restrictions or "institutional
controls" are considered to be an integral part of the selected remedy.
A cost estimate for Alternative 7 is presented in Table 6. This cost
estimate is based on a preliminary design of the remedial systems.
STATUTORY DETERMINATIONS
Under Section 121 of CERCLA and Section 300.430(f) 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. Contaminated soils will be excavated
and thermally destroyed off-site, resulting in minor short-term risks
associated with excavation but no long-term risks associated with on-site
treatment rtsiduals. In situ ground water treatment will similarly remediate
organic contaminants within the ground water with little or no associated
short-term risks. If volatile organic emissions result from the air stripping
process, an emissions control system will be installed.
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 7.
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It should be noted that, although evaluated, no location-specific ARARs
were identified which were applicable to Area 20A. 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 20A 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 treatment of contaminated soil and ground
water. Although Alternative 7 results in the greatest cost among the seven
alternatives evaluated, it provides the best balance among the nine evaluation
criteria specified by the EPA. Alternative 7 also provides the greatest
overall protection of human health and the environment. 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 20A.
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 (See Appendices A & B). 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 will provide the greatest long-term
effectiveness because of off-site incineration while those alternatives which
take place on-site with residuals also remaining on-site could potentially
require long-term monitoring. Based on the effectiveness of the treatment
methods utilized, a five-year review of the remedial action is not anticipated.
The selected remedy is one of four alternatives (5, 6, 7 and 9) which
provide a reduction in toxicity, mobility or volume of both medias of concern
through treatment. Alternatives 5, 6 and 7 provide the greatest degree of
toxicity reduction through the destruction efficiency of soil incineration.
Alternative 9 has not been thoroughly proven and, therefore, reductions in
toxicity of soil contamination may not be as great as anticipated.
The selected remedy is among four other alternatives which require
contaminated soil excavation and on-site handling, resulting in potential
short-term risks. The selected alternative does not have the added potential
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short-term risks associated with on-site treatment or storage which
Alternatives 3, 5, and 6 have.
The selected remedy is less implementable than the no action alternative
or Alternative 3, but those alternatives do not offer the degree of protection
offered by the selected alternative. The selected remedy involves
conventional technologies but implementation may be limited by available
incinerator capacities.
Although the selected remedy is the highest cost alternative, it provides
the greatest overall protection of human health and the environment through
treatment of both soil and ground water.
The Commissioner of the New Jersey Department of Environmental Protection
has indicated that the selected remedy for Area 20A is acceptable (See
Appendix B).
Overall, community acceptance of the chosen alternative was good. No
indication of community opposition was voiced at the public meeting.
Preference for Treatment as a Principal Element
The principal threats at Area 20A include the presence of PCB contaminated
soil and ground water contamination in both the upper and intermediate
aquifers. The selected remedy satisfies the statutory preference for
treatment as a principal element in addressing the human health and
environmental threats posed by the area. Off-site rotary kiln incineration
will provide treatment of contaminated soil and air stripping will treat
ground water contamination.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Remedial Action Plan for Area 20A was released for public
comment on March 1, 1990. The Proposed Plan identified Alternative 7
(off-site soil incineration and ground water extraction with air stripping) 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.
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RESPONSIVENESS SUMMARY
AREA 20A, SALVAGE YARD
FAA TECHNICAL CENTER
The purpose of this responsiveness summary is to review public response to
the Proposed Remedial Action Plan for Area 20A 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 20A Salvage Yard Area 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 20A, 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 Area 20A 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 20A is a Salvage Yard 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 20A only.
A summary of the site background, the alternatives evaluated, and a
comparison of alternatives are presented in the Area 20A 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.
BACKGROUND ON COMMUNITY INVOLVEMENT
This section provides a brief history of community participation in the
investigation and remedial planning activities conducted at Area 20A.
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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 Area 20A 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 C.
On February 15, 1990, FAA mailed the Area 20A Proposed Remedial Action
Plan to concerned parties on the list described above. On March 1, 1990, a
notice appeared in The Press, the local Atlantic City newspaper, 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 March 1, 1990 through April 2, 1990.
A public meeting was held on March 28, 1990, at 7:00 p.m. at the Atlantic
County Library in Mays Landing, New Jersey. The Area 20A site investigations,
feasibility study process and proposed remedial alternative were discussed.
FAA representatives included: Keith C. Buch, Project Manager; Howard Kimpton,
Supervisor, Environmental Section; and Michael G. Beres, Manager of the
Engineering/Environmental Branch. Robert Wing, Chief of the Federal
Facilities Section, 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 D).
SUMMARY OF MAJOR QUESTIONS AND COMMENTS
This section addresses public comments received during the March 1, 1990
through April 2, 1990 public comment period. One set of questions/
clarifications was raised at the public meeting. No written comments were
received. A summary of the public meeting comments and the FAA response are
presented below.
Public Meeting Comments
Comment: Robert Heitsenrether, Environmental Specialist with the FAA,
requested clarification of two issues, both in regards to the portion of the
public meeting presentation in which the results of the remedial investigation
were presented. A slide which summarized the results of previous
investigations conducted by Roy F. Weston at Area 20A indicated that the
Western study identified volatile organic compounds in the deep aquifer. Mr.
Heitsenrether wanted to affirm that the aquifer which was referenced in this
slide was the Middle Cohansey Sand, an intermediate aquifer, and not the Lower
Cohansey Sand, in which the ACMUA wells are screened.
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FAA Response: The Weston study did identify the presence of volatile organic
compounds in the Middle Cohansey Sand. As described later in the
Environmental Investigation presentation, for the purposes of the
presentation,"this aquifer was referred to as the "deep" aquifer. The Weston
study did not evaluate the potential impacts of Area 20A on the Lower Cohansey
Sand, although this aquifer was sampled during subsequent TRC studies, with no
contaminants detected.
Comment: The second portion of Mr. Heitsenrether's question was with respect
to the analysis of ground water samples collected from the intermediate
aquifer (Middle Cohansey Sand). A slide from' the Environmental Investigation
portion of the presentation identified a total volatile organic compound
concentration of 6 ppb in a well screened within the intermediate aquifer and
located adjacent to the Upper Atlantic City Reservoir. Mr. Heitsenrether
inquired as to the specific volatile organic compound detected in this well
and a comparison of the detected concentration to the New Jersey Maximum
Contaminant Level (MCL).
FAA Response: The volatile organic compound detected at 6 ppb in the subject
well was 1,1,1-trichloroethane. The New Jersey MCL for 1,1,1-trichloroethane
is 26 ppb. Therefore the detected level in this well is below the New Jersey
MCL for drinking water supplies.
Written Comments
No written comments were received.
REMEDIAL DESIGN/REMEDIAL ACTION CONCERNS
No public comments were received which addressed the remedial design or
proposed remedial action. Due to the minimal public input received during the
comment period, no public concerns associated with the remedial action were
identified.
-22-
-------
FIGURES, APPENDICES AND TABLES
-------
FAA PROPERTY
GARDEN STATE
PARKWAY
AANTIC CITY
INTERNATIONAL
AIRPORT
;• BUILT-UP
AREA
ATLANTfG CITY
' EXPRESSWAY
PLEASANTVILLE, NJ QUADRANGLE
USGS 7.5 MINUTE SERIES TOPOGRAPHIC
O 10OO 500O
SCALE, FEET
FIGURE 1. FAA TECHNICAL CENTER
-------
AREA 20A LOCATION MAP
FAA
TECHNICAL
CENTER
UPPER
RESERVOIR
LOWE
RESERVOIR
AREA
FEET
FIGURE 2.
-------
AREA 20A LAYOUT
SCRAP BLDGJ
STORAGE 206
FORMER
UNDERGROUND
TANKS
BLDG. 206
YARD
BLDG. 207
DRUM STORAGE
AREA
100 FT
FIGURE 3.
-------
TABLE 1
CONTAMINANTS OF CONCERN
MAXIMUM AND AVERAGE CONCENTRATION VALUES
Based on Phase I/Phase II Investigations
AREA 20A
(1)
BORINGS MONITORING WELLS
Concentration Detected Concentration
Volatile Organics (ppb)
1 , 1-Dichloroethene
1.1, 1-Trichloroethane
Tetrachloroethene
Toluene
Maximum Average Frequency Maximum
180
2,300
98
Average
15
168
8
Detected
Frequency
7/24
12/24
3/24
SURFACE SOILS
Concentration
Maximum
410
3,800
1,300
Average
20
186
32
Detected
Frequency
2/21
3/21
2/21
Base/Neutrals (ppb)
Bis(2-ethylhexyl)phthalate<2>
Pesticides/PCBs (ppb)
11,000
530
5/24
4 . 4-DDT
Aroclor-1260
Metals (ppb)
Cadmium
Chromium
56.000
1,400,000 299,000 6/8 49,000
24.7 3.6 5/24 4.200
5,600 5,000 4/4 1,040 107 19/24 21.000
2,676
3.396
1,000
11,000
4/21
5/21
15/21
21/21
Includes results for subsurface soil samples collected from base of tank excavations.
bjs(2-ethylhexyl )phthalate was not chosen as a COC^^ the basis of Phase I investigations but due to t
[level detected in Phase II, it has been included h
evated
-------
TABLE 2 DOSE-RESPONSE FOR THE PRIMARY STANDARDS. GUIDELINES AND CRITERIA
USED TO ASSESS RISK - AREA 20A
/'
/
1 2 3
AIS AIC RfD
PARAMETER (mg/kg/day) (ng/kg/day) (ng/kg/day)
1.1-Dlchloroethene — 9.00E-03 0.01
1.1.1-Trlchloroethane — 5.40E-01 0.54
Tetrachloroethene — 2.00E-02 0.02
Toluene 4.30E-01 3.00E-01 0.3
4.4-ODT — 5.00E-04
PCBs — — 0.0003
Cadmium — 2.90E-04 0.0005
Chromium 2.50E-02 5.00E-03 0.0021
4
Health
Advisories (ppm)
1 Day Long-term
(70kg) (70kg)
3.5 3.5
490 125
6.8
63
—
0.437
0.15 0.018
4.9 0.84
5
Carcinogenic
Potency
Factor -1
(mg/kg/day)
5.80E-01
~
5.10E-02
—
3.40E-01
4.34E+00
6.10E+00
4.10E+01
1. Subchronlc Acceptable Intake - Superfund Public Health Evaluation Manual. October. 1986
Source RfD (except cadmium, chromium IV. and 1.1.1 TCA - HEA)
2. Chronic Acceptable Intake - Superfund Public Health Evaluation Manual.
Source RfD (except cadmium, chromium IV. and 1.1.1 TCA - HEA)
3. RfD's for Oral Exposure- U.S. EPA. Environmental Criteria ft Assessment
(1.1.1-trlchloroethane. cadmium, chromium - ADI's. U.S. EPA. 1985; RfD
4. Health Advisories- Office of Drinking Hater. U.S. EPA. Sept. 30. 1985
(1-Day HA derived from HA for a child using adult conversion)
5. Carcinogenic Potency Factor (Oral) - Source: Health Effects Assessment
(cadmium & chromium (Inhalation). Carcinogenic Assessment Group (CAG).
October. 1986
Office. May 1985
's not derived)
/
(HEA). U.S. EPA. May. 1986
U.S. EPA. April 1984)
-------
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
Worst Case; Ingest 0.2 g/exposure, 2 exposures/year over 20 years
SURFACE SOIL - DIRECT CONTACT
Most Probable Case: Direct contact 12 times/year over 10 years; contact
rate: 10 g/exposure
Worst Case: Direct contact 24 times/year over 20 years; contact rate:
10 g
-------
TABLE 4
SUMMARY AF NONCARCINOGEN1C RISKS
AREA 20A
GROUND HATER
EXPOSURE
SCENARIO
ADULT
REALISTIC
UORST-CASE
ADULT
HOST PROBABLE
CASE
CONTAMINANT OF
CONCERN
1.1-DICHLOROETHENE
1.1.1-TRICHLOROETHANE
TETRACHLOROETHENE
TOLUENE
B1S(2-ETHYLHEXYL)PHTHALATE
4.4-OOT
PCBi
CADMIUM
CHROMIUM
1.1-DICHLOROETHENE
1.1.1-TR1CHLOROETHANE
TETRACHLOROETHENE
TOLUENE
BIS(2-ETHYLHEXYL)PHTHALATE
4.4-OOT
PCBs
CADMIUM
CHROMIUM
INGESTION
ACUTE
2.71E-02
2.04E-03
NA
HA
NA
NA
NA
1.4SE-02
B.29E-03
1.B4E-03
1.5BE-04
NA
NA
NA
NA
NA
1.45E-03
6.47E-04
CHRONIC
1.12E-OI
2.38E-02
2.74E-02
NA
3.07S
NA
NA
4.76E-02
1.16E-01
4.66E-03
B.70E-04
1.71E-03
NA
7.41E-02
NA
NA
4.21E-03
3.SSE-03
DIRECT
ACUTE
NA
2.09E-06
NA
6.16E-05
NA
NA
2.24E-02
1.40E-02
2.14E-03
--
--
--
--
--
--
--
--
--
SURFACE SOIL
CONTACT
CHRONIC
NA
1.02E-06
2.SSE-04
5.B2E 06
NA
1.50E-01
1.76E 02
3.B9E-03
1.13E-03
..
--
--
--
--
--
--
--
--
INGESTION
ACUTE
NA
B.37E-OB
NA
2.06E-06
NA
NA
1.12E-02
2.BOE-04
4.29E-05
.
--
--
--
--
•-
--
--
--
CHRONIC
NA
3.40E-09
B.S1E-07
1.94E-08
NA
S.01E-04
7.31E-04
6.4BE-06
l.BBE-06
--
--
--
--
--
--
--
--
--
DIRECT
ACUTE
NA
NA
NA
NA
NA
NA
6.40E-01
NA
S.71E-04
--
--
--
--
--
--
.
--
SUBSURFACE SOIL
CONTACT
CHRONIC
NA
NA
NA
NA
NA
NA
17.53
NA
l.OSE-02
--
--
--
;-
'•-
T -
--
--
-•
INGESTION
ACUTE
NA
NA
NA
NA
NA
NA
l.COE-01
NA
1.14E-05
--
--
--
--
--
--
--
--
--
CHRONIC
NA
NA
NA
NA
NA
NA
7.31E-01
NA
1.7SE-OS
-.
--
--
--
--
--
--
--
--
NA - Not Applicable
-------
TABLE 5
SUMMARY OF CARCINOGENIC RISKS PRESENT AT AREA 20A
Exposure
Scenario
Adult
Realistic
Worst-Case
Adult
Most Probable
Case
Contaminant of GROUND WATER
Concern INGESTION
1.1-Dlchloroethene
Tetrachl oroethene
B1s(2-ethy1hexyl )phthalate
4.4-DDT
PCBs
Cadnium
Chronl urn
1 . 1 -01 chl oroethene
Tetrachl oroethene
B1s(2-ethylhexyl)phthalate
4.4-DDT
PCBs
CadBluM
ChroMlUB
S.B4E-04 E
2.79E-OS W
4.21E-05 W
NA
NA
NA
NA
1.22E-05 W
8.73E-07 W
S.07E-07 W
NA
NA
NA
NA
SOIL
DIRECT CONTACT
NA
2.60E-07 W
NA
2.S6E-OS W
2.28E-OS W
NA
NA
NA
3.18E-09 L
NA
3.0SE-07 W
3.96E-07 W
NA
NA
SOIL
INGESTION
NA
B.67E-10 L
NA
8.52E-08 L
9.51E-07 W
NA
NA
--
--
--
--
--
BORINGS BORINGS
DIRECT CONTACT INGESTION
NA
NA
NA
NA
6.S2E-04 E
NA
NA
--
.-
--
--
--
NA
NA
NA
NA
2.72E-05 W
NA
NA
--
--
--
--
--
"
-4 -7
U - Carcinogenic risk falls within 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
SITE 20A • Alternat ive 7:
Eicavalion With Oil Site Rotary Kiin Incineration oi Con I ami na i td Soil, Ground Water Extraction gith A!r Stripping
1 1 em
Quantity Units Unit Price Basis Year Reference
Adjustment
factor
1989
Unit Costs
1989
Cost s
Years Present
(OlM) Valui (OlM)
CAPITAL COSTS - DIRECT
Runon/Runoll Controls
-
Total
Di ver slon DI t ch
Construction and Maintenance
Health and Safely (17X)
Runon/Runolf Control Cost
4SO cu. yd.
$2. 11
1980
9
17
1. 57
$3.31
$1. 490
$253
72
42
$1. 744. 14
Ai r Mon i tor i ng
-
Tola!
Soi 1
Total
Soi 1
High Volume Sampler
Personal Sampler
Ana 1 yses:
Par t i culat es
VOCs
PCB/Pesticlde
A i r Don i 1 or ing Costs
Eicavalion and Containment
Eicavat ion With Backhoe
(Crawler mounted, 60 yd/br)
Health and Safely (17X)
Eicavalion and Containment Costs
Sampling During Eicavation
Sur vey ing
Field Sampl ing
1 month
1 month
60 samples
60 samples
60 samples
930 cu. yd.
2 days
20 days
$300. 00
$120. 00
$30. 00
$175. 00
$175. 00
$3.73
$700. 00
$700. 00
1988
1988
1988
1988
1988
1988
1988
1988
16
16
16
16
16
23
17
16
16
.02
. 02
. 02
.02
.02
1.02
1.02
1.02
$306 00
$122. 40
$30. 60
$178. 50
$178. 50
$3.80
$714. 00
$714. 00
$305
$122
$1, 836
$10, 710
$10, 710
$3. 538.
$601.
$1, 428.
$14. 280.
00
40
00
00
00
28
51
00
00
$23.684. 40
$4. 139 79
-Analysls
PCB (Method No. 608)
286 samples
$190. 00
1988
16
1.02
$193. 80
$55. 426. 80
Total Sol I Sampling Costs
$71. 134. 80
-------
1 tern
(quipment Decontamination
-Rental uf SI earn Cleaner
Construct Decon Pit
Eicaval e ft>.
Po 1 yet hy 1 ene Tar paul i n
Total Equipment Decon Costs
s =^s: — —==:=:= = = =;f= =:===^=;===^ ====s==s:c3s:i
Engineering Mgml. Mob/Demob
(3 trai ler s)
Dust Control
Site Rest or at ion
-Hauling (3 mi. roundtrip)
-Backli 1 1
-lopsoi 1 PI acement and
Revegelal ion
lot al Site Restor al Ion Cos! s
_=== — ====_== — === = == ==
01 1 -Si le Inc iner at ion
-Drumming ol Sol 1
-Transportation and Incineration
Total 01 1 -SI le Incinerat ion
Eitract ion We 1 1 s
(3 30 M nel Is, 2 100- It wells.
8' diam )
-Well Construction t Materials
(Hoi low Stem Auger)
-Health and Salety (17X)
-Mobi 1 i 2at i on
Total Eitracl ion Wei 1 Cost
===s=======s=:=====;:±==:=====:=s==::===ris=:
Quant i t y Un i 1 s
30 days
100 cu. yd.
1. 200 sq. II. •''
2 months
30 days
930 cu. yd.
930 cu. yd.
43 MSF
= = S== = = = S=SS=3S==S— sss=
4. 300 drums
4, 300 drums
290 It
1 time
:=SSES==3= = = SSS==BSS====S =
Uni t Pr i ce Ba
$50. 00
$1.41
$0. 31
$1. 100. 00
$102.00
$2. 73
$1.93
$430. 00
$160. 00
$695.00
$150. 00
$1.000.00
sis Yeai
1988
1988
1987
1988
1984
1988
1988
1988
1987
1989
1986
1986
X£S==S«S3
Adjustment
r Reference Factor
23 1.02
23 1.02
11 1.05
23 1.02
21 1.16
23 1.02
23 1 02
23 1.02
35 1.05
36 1.00
15 1.09
17
15 1.09
==3=TS=SS=:S=====S=a = = a=S===*===
1989
Unit Cos
$51.
$1
$0.
$1. 122
$118.
$2.
$1
$438.
$168.
$695
$163.
$1,090.
ZE===== = =
1989
t s Costs
00 $1, 530. 00
44 $143.8?
33 $390.60
00 $2,244 00
32 $3.549.60
78 $2. 589 68
97 $1.830.80
60 $18.859.80
00 $722.400.00
00 $2.988,500.00
50 $47.415.00
$8.060. 55
00 $1.090.00
Years Present
(O&M) Value (O&M)
$2.064 42
$2. 244. 00
$3,549 60
$23, 280 28
$3. 710. 900 00
$56. 565. 55
-------
1 1 em Quant i t y Uni I s
Groundwaler Pumping
•Submersible Pump (4* Pump) 5 pumps
Piping To Treatment System . ''
•PVC in Trench 3.000 It
Air SI r ipp ing Towers
-15 gpm Flowrate 1 tower
• 140 gpm F lowrat e 1 lower
Total Air Stripping Towers
Adjustment 1989 1989 Years Present
Unit Price Basis Year Reference Factor Unit Costs Costs (OIU) Valut (OtM)
$2,440.00 1984 6
$9 28 1988 23
$24,000 00 1986 27
$61,300.00 198S 6
1.16 $2.830.40 $14.
1 02 $9 47 $28.
1 09 $26. 160 00 $26.
1. 12 $68, 656. 00 $68.
152 .00 $14.152 00
396. 80 $28. 396 80
1
160 00
656. 00
$94,816. 00
Equali/alion Tank (2000 gal)
==========
Inject ion We I Is
(5 30-It welIs. 8" diam. )
•Hoi low SI em Auger
•Health and Salely (17X)
•Mob iIilalion
•Cent r i luga I Pump
Total Inject ion WelI Cost
1 tank
150 It
1 I ime
I pump
$1. 580 00
$150. 00
$1. 000. 00
$1. 600. 00
1988
1986
1986
1980
22
15
17
15
9
1. 00
i. 11
1. 09
1. 57
$1. 580. 00
$166 50
$1.090. 00
$2. 512. 00
$1.580 00
$24,975 00
$4,245 75
$1.090. 00
$2, 512. 00
$1, 580 00
Direct Capital Cost Subtotal
CAPITAL COSTS • INDIRECT
132, 822. 75
$4.071.074 52
Engineering and Design (11X)
legal and Administrative (3X)
System Startup and Shakedown (IOX)
TOTAL CAPITAL COSTS
18
$447,818. 20
$122, 132. 24
$22, 833. 31
$592. 783. 74
$4.663.858. 26
-------
Item Quant 1 If Uni Is
OPERATION AND MAINTENANCE COSTS
•GroundNaltr Monitoring
Sampl ing . 44 saropl ti
Ana 1 ITS i s: x
full Priority Pollutant 44 tamp lei
-Grounds Maintenance 100 kours
•Water Treatment System Sampling 12 samples
-Air SI r i ppi ng Tower
18 gpm 1 year
140 gpm 1 year
TOTAL NET PRESENT VALUE OF 0 i M
SUBTOTAL COST
CONTINGENCY (20%)
TOTAL PRESENT VALUE COST FOR ALTERNATIVE 7
Adjustment 1989 1989 Years Pre
Unit Price Basis Year Reference Factor Unit Costs Costs (OtU) Value
$2500 1980 9 1.57 $39 ?5 $1.727.00 8 $9.
$1.800.00 1988 16 1.02 $1.83600 $80.784.00 '8 $430.
$16.56 1987 12 1.05 $17.39 $1.738.80 3 $4.
$1.800.00 1988 14 1.02 $1,836.00 $22,032.00 3 $54.
$12,000.00 1988 16 1.02 $12,240.00 $12,24000 3 $30
$37.000.00 1982 27 1.34 $49,580.00 $49.580.00 1 $45',
$574.
$5.238.
$1.047.
$6.286.
sent
(001)
213 55
982 64
324 40
793. 58
440. 88
068 22
823 26
«t*XS3»*«-
681 52
736. 30
417. 83
-------
TABLE 7
SUMMARY OF MAJOR ARARs AND TBCs
CHEMICAL-SPECIFIC ARARs/TBCs
* New Jersey Ground Water Quality Standards
- NJGWQS for: 1,1-Dich.loroethene - 2 ppb
1,1,1-Trichloroethane - 26 ppb
Tetrachloroethene - 1 ppb
Bis(2-ethylhexyl)phthalate - 5 ppb
Cadmium - 10 ppb
Chromium - 50 ppb
* New Jersey Safe Drinking Water Act (NJSDWA)
- NJSDWA MCLs for: 1,1-Dichloroethene - 2 ppb
1,1,1-Trichloroethane - 26 ppb
Tetrachloroethene - 1 ppb
PCBs - 0.5 ppb
Cadmium - 10 ppb
Chromium - 50 ppb
* Safe Drinking Water Act (SDWA)
- SDWA MCLs for: 1.1-Dichloroethene - 7 ppb (final)
1,1,1-Trichloroethane - 200 ppb (final)
Tetrachloroethene - 5 ppb (proposed)
Toluene - 2,000 ppb (proposed)
Cadmium - 10 ppb (final)
5 ppb (proposed)
Chromium - 50 ppb (final)
* New Jersey Soil Action Levels
- Currently defines 1 ppm as action level for total volatile organics,
10 ppm as action level for total base/neutral and acid extractables
and 100 ppm as action level for total petroleum hydrocarbons in soils
* New Jersey Ground Water Quality Standards
- NJAC 7:9-6 specifies ground water quality standards for Class GW2
waters: 4,4-DDT - 0.001 ppb
PCBs - 0.001 ppb
LOCATION-SPECIFIC ARARs/TBCs
No location-specifics ARARs/TBCs were identified as being
applicable to Area 20A remediation
ACTION-SPSCIFIC 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-s.ts
transport of hazardous waste
-------
TABLE 7 (cont.)
SUMMARY OF MAJOR ARARs AND TBCs
ACTION-SPECIFIC ARARs/TBCs (cont.)
40 CFR 264 Subpart L requires owners/operators that store hazardous
waste in piles to control wind dispersal of particulate matter.
40 CFR 264 Subpart 0 incinerator standards apply to the incineration
of F001-F005 contaminated soil and waste material as well as to
incineration of PCB-contaminated soils. These standards provide for
minimum residence time in the combustion chamber, and monitoring
requirements for combustion products. Ash and scrubber water
resulting from the incineration of a listed waste is also a listed
hazardous waste subject to RCRA standards.
40 CFR 264 Subpart X provides performance and monitoring standards
which are applicable to miscellaneous units which store, treat, or
dispose of hazardous wastes, which would include air stripping units
associated with ground water remediation.
40 CFR 264 and 265 Subparts Z, AA and BB are new regulations being
developed to provide standards for controlling hazardous VOC emissions
from process vents, equipment leaks, tanks, surface impoundments,
containers, and waste fixation units.
40 CFR 268 Land Disposal Restrictions provide standards applicable to
the reinjection of treated ground water into an aquifer, including
compliance with the following: l)the injection is a CERCLA response
or RCRA corrective action, 2) the ground water is treated to
substantially reduce the hazardous constituents prior to reinjection,
and 3) the response action is sufficient to protect human health and
the environment upon completion.
52 FR 3748 2/5/87 provides proposed RCRA regulations on vents and
equipment leaks.
40 CFR 761 provides standards applicable to the incineration of
PCB-contaminated material. These standards define minimum residence
time and monitoring requirements.
* 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 National Primary and Secondary Ambient Air Quality Standards
provide air quality standards for particulate matter and other
pollutants.
* Office of A'ir Quality Planning and Standards
- "Issues Relating to VOC Regulation Outpoints, Deficiencies and
Deviations" provides guidance on emission limit goals in ozone
nonattainment areas which are applicable to air strippers and other
vented extraction techniques.
* Office of Solid Waste and Emergency Response
- Directive 9355.0-28 establishes guidance on the control of ai::
emissions from air strippers used at Superfund sites.
-------
TABLE 7 (cont.)
SUMMARY OF MAJOR ARARs AND TBCs
ACTION-SPECIFIC ARARs (Continued)
* New Jersey Air Regulations
- NJAC 7:27-5.1 regulates emissions of air contaminants and odors;
off-site impacts could trigger NJDEP action under this subchapter.
- NJAC 7:27-6 provides standards for emissions of particles from stacks
or chimneys; certain substances emitted from air strippers might be
considered "particulate matter".
- NJAC 7:27-8 specifies permit/certification requirements to construct,
install, or alter equipment or control apparatus. State-of-The-Art
(SOTA) Air Pollution Control Technology is required pursuant to
N.J.A.C. 7:27-8.5(b), if emissions of non-methane hydrocarbon (NMHC)
are greater than 3.0 Ibs./hr. and/or emissions of toxic volatile
organic substances (TVOS) are greater than .1 Ibs./hr.
- NJAC 7:27-13 specifies ambient air quality standards for selected
contaminants, including suspended particulate matter, hydrocarbons,
and photochemical oxidants.
- 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 Haste Management Regulations
- NJAC 7:26-7.3-4 establishes requirements of hazardous waste generators
(consistent with RCRA requirements).
-------
APPENDIX A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
LETTER OP CONCURRENCE
-------
SEP 2 4 1390
Mr. Harvey Safeer, Director
FAA Technical Center
ACT-1
Atlantic City International Airport, N,J. 08404
Re: FAA Technical Center Record of Decision (ROD) for
Area 20A - Salvage Yard
Dear Mr. Safeer:
This is to inform you that the United States Environmental
Protection Agency (USEPA) has reviewed the draft ROD and
supporting documents for remediation of contaminated soil and
groundwater at the FAA Area 20A - Salvage Yard. The USEPA
concurs with the remedy, subject to incorporation into the final
ROD of USEPA comments sent to Mr. Keith Buch of your staff on
April 26, 1990.
The remedial action consists of the following:
*" Excavation of approximately 930 cubic yards of soil and
transport off-site for incineration at a permitted
rotary kiln and;
* Air stripping of organic compounds in the groundwater.
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 or comments regarding this letter, please call me at
212-264-2525, or Mr. Robert Wing, Chief, Federal Facilities
Section at 212-264-8670.
Sincerely,
Constantino Sidamon-Eristof f
Regional Administrator
cc: Judith A. Yaskin, Commissioner
New Jersey Department of Environmental
Protection
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Robert Hayton, Case Manager
S£w Jersey Department of Environmental
Protection
T. Flatley, FAA
K. Buch, FAA
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APPENDIX B
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
LETTER OF CONCURRENCE
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STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
JUDITH A. YASKIN. COMMISSIONER
CN 402
TRHNTON. N.J. 08625-0402
!•«»: ((>(»)
JUL 1 1 1990
Harvey B. Safeer, Director
FAA Technical Center
ACT-1
Atlantic City International Airport
Atlantic City, NJ 08604
Dear Mr. Harris:
Re: FAA Technical Center
Draft Record of Decision (ROD)
for Area 20A - Salvage Yard
This is to formally notify you that the New Jersey Department of
Environmental Protection has reviewed the Record of Decision for the Federal
Aviation Administration Area 20A, Salvage Yard and concurs with the
recommended remedy. This remedy will consist of the following:
o Off-site incineration of contaminated soils.
Ground water extraction, treatment and re-injection.
Operation, monitoring and maintenance of the system.
The Department's concurrence is contingent upon the incorporation of our
comments, which- have been sent to Mr. Keith Buch of your staff, into the
final ROD. New Jersey fully appreciates the importance of the Record of
Decision in the clean-up process and will continue to take all reasonable
steps to ensure that the State's commitments in this area are met.
Very truly yours,
c:
Ctfudith AT Yaskin
Commissioner
Constantine Sidamon-Eristoff,
Regional Administrator, USEPA
Robert Wing, Federal Facilities Section/USEPA
Michael Cicali, Atlantic County Health Department
; :\ at £d^. (>?;• *r:un;:\ Empio\rr
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APPENDIX C
PRAP MAILING LIST
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APPENDIX C
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 Jimrry 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 Cantilion 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
Pleasantvillt, 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
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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 City, 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
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APPENDIX D
PUBLIC MEETING ATTENDEES
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PLEASE SIGN IN
PUBLIC MEETING WEDNESDAY, MARCH 28, 1990
PROPOSED REMEDIAL ACTION PLAN (PRAP)
FOR AREA 20A - SALVAGE YARD
FEDERAL AVIATION ADMINISTRATION TECHNICAL CENTER
ATLANTIC CITY AIRPORT, NJ 08405
YOUR NAME ADDRESS
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