United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/093
September 1989
SEPA
Superfund
Record of Decision
Picatinny Arsenal, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/093
3. Recipient1 a Acceaalon No.
I 4. Title and Subtitle
I^^UPERFUND RECORD OF DECISION
j^Bicatinny Arsenal, NJ
l^^irst Remedial Action
5. Report Date
09/28/89
7. Autfior(a)
8. Performing Organization Rept No.
8. Perfonning Organization Nun* and AddreM
10. Pro|ectfTaak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponaoring Organization Nama and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type ol Report & Period Covered
800/000
14.
15. Supplementary Notee
18. Abelract (Limit: 200 worda)
The Picatinny Arsenal is a munitions and weapons research and development installation
covering 6,491 acres and containing 1,500 buildings in Morris County, near the city of
Dover, New Jersey. Ground Water contamination above State and Federal action levels has
been detected in the vicinity of Building 24, where past wastewater treatment practices
Hulted in the infiltration of metal plating waste constituents (i.e., VOCs and heavy
als) into the ground water. Two unlined lagoons alongside Building 24, thought to be
ource of contamination, was eliminated during a 1981 action during which the unlined
lagoons were demolished, contaminated soil removed, a two concrete lagoons installed.
Two additional potential sources of contamination are a dry well at Building 24 and a
former drum storage area at Building 31, directly across the street from Building 24.
This interim ground water cleanup remedy is designed to prevent deterioration to Green
Pond Brook, a major drainage artery onsite, while the Arsenal as a whole is evaluated.
The primary contaminants of concern affecting the ground water are VOCs including TCE,
and metals.
The selected interim remedy for this site includes ground water pumping and treatment
using a pretreatment system for the removal of metals and solids and air stripping to
remove VOCs; GAC filtration of VOCs from the air stripper exhaust and air stripper
iiont- • Hi nf 1-roat-oH rnnnH wat-iar fn (7roon front- -i niioH on novi-
IT. Document Analyaie a. Descriptor*
Record of Decision - Picatinny Arsenal,
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (TCE), metals
DL Identifiera/Open-Ended Term*
NJ
f. COSATI RetoVGroup
Statement
IB. Security deaa (Thto Report)
None
20. Security CUae (Thto Page)
None
21. No. of Pagee
71
22. Price
(See ANS1.ZM.18)
See (rufruc
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EPA/ROD/R02-89/093
Picatinny Arsenal, NJ
Abstract (Continued)
?nd Brook; and effluent and air monitoring. Cost data was not provided because USAGE
was preparing to offer a competitive bid contract for the system.
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DEPARTMENT OF THE ARMY
OFFICE OF THE ASSISTANT SECRETARY
WASHINGTON, DC 20310-0103
3 0 OCT 1989
MEMORANDUM THRU THE ASSISTANT CHIEF OF ENGINEERS
FOR THE COMMANDER, U. S. ARMY'MATERIEL COMMAND
SUBJECT: Picatinny Arsenal's Record of Decision (ROD)
Declaration, Interim Remedial Response for
Building 24 Area
The subject ROD declaration has -been approved and
signed.
Point of contact in this office is Mr. Rick Newsome,
ext. 49531.
Lewis D. Walker
Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational Health)
OASA(I,L&E)
Attachment
cf:
SAGC
DAJA-EL
ENVR-E
-------
AMCEN-A (ASA/30 Oct 89) 1st End Mr. King/AV 284-9016
SUBJECT: Picatinny Arsenal's Record of Decision (ROD)
Declaration, Interim Remedial Response for Building 24 Area
5 D
CDR, USAMC, 5001 Eisenhower Ave., Alex, VA 22333-0001
FOR Commander, U.S. Army Toxic and Hazardous Materials Agency,
ATTN: CETHA-IR, APG, MD 21010-5401
1. Copy of subject signed record of decision is enclosed for
your retention. The original is transmitted directly to ARDEC
via copy of this endorsement.
2. Point of contact at AMCEN-A is Robert King, AV 284-9016.
FOR THE COMMANDER:
/
sf
T"
ANDRES TALTS, P.E.
/' Chief, Environmental Quality Division
Office of the Deputy Chief of Staff
for Engineering, Housing, and
Installation Logistics
CF:
Commander, U.S. Army Armament Research Development and
Engineering Center, ATTN: SMCAR-ISE-N, Dover, NJ 07801-5001
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DEPARTMENT OF THE ARMY
HEADQUARTERS, U S. ARMY MATERIEL COMMAND
5001 EISENHOWER AVENUE, ALEXANDRIA, VA 22333-0001
AMCEN-A (200-lc)
MEMORANDUM THRU COL R. MA
WASH DC 20310-2600
250CT
j^, 'n
.ONMENTAL OFFICE,
FOR MR. LEWIS D. WALKER, DASA (ESOH), WASH DC 20310-0103
SUBJECT: Picatinny Arsenal's Record of Decision (ROD) Declaration, Interim
Remedial Response for Building 24 Area
1. The subject ROD declaration is provided for your approval and signature.
An advanced copy of the package was provided earlier to your office directly
by the installation.
2. No comments were received during the 25 Sep 89 public meeting. The
comment received from the Army Environmental Office concerning the sampling
and analysis of the treated water before discharge to the environment will be v
addressed during implementation, as appropriate. Final EPA and State concerns
with the ROD are attached as part of the package. AMC concurs with the
package as presented.
3. Request this office be advised on the expected date for approval and
signature of this ROD.
4. The POC at HQAMC is Ms. Lydia Sanchez, 274-9016, and at the installation
is Ms. Andrea Pastuck, AV 880-5818, Picatinny Arsenal's Environmental Affairs
Office. The POC for legal issues is the Arsenal's Office of General Counsel.
FOR THE COMMANDER:
Encl
JERR/ A. HUE
Coldnel, GS
Deputy Chief of.Staff for
Engineering, Housing, and
Installation Logistics
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AMCEN-A
SUBJECT: PICATINNY ARSENAL'S RECORD OF DECISION, INTERIM REMEDIAL
RESPONSE FOR BUILDING 24 AREA
CF: (W/0 ENCL)
COMMANDER,
AMCCOM, ATTN: AMSMC-ISE, AMSMC-GC(D)
ARDEC, PICATINNY ARSENAL, DOVER, NJ 07806-5000
ATTN: SMCAR-ISE, AMSMC-GC(D)
USATHAMA, ATTN: CETHA-IR-B (MS. MORAN)
-------
AMSMC-ISE (200-U)
MEMORANDUM FOR Ccmmancer, U,S, Army Materiel Command, ATTN: AMCEN-A,
Elsenhower Avenue, Alexandria, VA 22333-0001
5001
SUBJECT: P1cat1nny AHsenal
Remedial Response for
's Record of Decision (ROD) Declaration, Interim
Building 24 Area
2. Headquarters, U.S.
environmental staff have
DEPARTMENT OF THE ARMY
U». ARMY AAMAMCNT. MUNmONft AND CW MCAU COMMAND
NOCK »UANO. UJNO*
10 OCT 1969
1. Reference memorandum, HQ, AMC, AMCEN-A, datafaxed 28 Sep 89, subject as
above.
Army Armament, Munitions and Chemical Command
reviewed subject ROD and concur with it.
required by AMSMC-GC (R) because authority for said
AMSMC-GC (D)(—0>*>jri,.-^. jA^u^St*-u*^iJ.
3. No legal review 1i
legal review rests with
4. The point of contact for this action 1s Mr. William Coogan, AMSMC-ISE-E,
AUTQVON 793-1435.
FOR THE COMMANDER:
RONALD T/S^NBORI
Chief, Environmental Quality 01v
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DEPARTMENT OF THE ARMY
U.S. ARMY ARMAMEKT RESEARCH, DEVELOPMENT AND ENGINEERING CENTER
PICATINNY ARSENAL, NEW JERSEY 07806-5000
September 21. 1989
trrumo*cr
Environmental Affairs
Office
Mr. Robert King/Ms. Lydia Sanchez
Headquarters AMC
5001 Eisenhower Avenue
Alexander, VA 22333-0001
Dear Mr. King/Ms. Sanchez:
Enclosed please find a copy of the Record of Decision Declaration,
Responsiveness Summary, Effluent Limitations, Record of Decision and Supporting
letter from EPA for the Interim Groundwater Remediation of Picatinny Arsenal,
Building 24 Study Area, Dover, New Jersey.
The public comment period was from 12 July - 11 August 1989. No
significant comments were received. After the public comment period was
closed, the EPA and the New Jersey Department of Environmental Protection
requested a public meeting. A public meeting will be held on 25 September
1989. Request you forward this package to Mr. Walker's office for
signature, and request that he sign the Declaration after 26 September 1989,
due to the fact that an addendum may have to be added if there are any
comments at the public meetings. If an addendum is required it will be
forwarded on 26 September 1989. The EPA is fully behind this approach.
Should you have any questions regarding this package phase contact
myself or Andrea Pastuck at 201-724-5818
or 724-2878.
Sincerely,
THOMAS J. SOLECKI
Environmental Affairs
Office
Enclosure
As stated
CF:
Robert Lubbert ENVR-EH (w/ROD Declaration, Responsiveness Summary &
EPA letter dated 3 August 1989)
Richard Newsome SAIL-ESOH (w/encl same as above)
Ronald Shimbori AMSMC-ISE (w/encl same as above)
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| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' REGION n
* **at* JACOB K. JAVITS FEDERAL BULGING
NEW YOAK. NEW YORK 10278
SEP: f i:-J3
Colonel Richard M. Gilligan, Jr.
Commanding Officer
U.S. Army Armament R & D Command
Picatinny Arsenal, NJ 07806-5000
Dear Colonel Gilligan:
This is to notify you, that, after reviewing the Army's Record of
Decision and supporting documents for remediating a plume of
contaminated ground water in the vicinity of Building 24 at
Picatinny Arsenal, the United States Environmental Protection
Agency (USEPA) concurs with the recommended remedy as stated,
provided the remedy is designed to meet the effluent limitations
and monitoring requirements specified by the New Jersey
Department of Environmental Protection (NJDEP). This Army
initiative will expedite clean up of an area of known
contamination.
The Record of Decision is for an interim action which focuses on
the remediation of ground water contamination emanating from the
Building 24 area. This interim action is intended to control
short term contaminant migration without specifying long term
clean up levels. Picatinny Arsenal will conduct a formal
Remedial Investigation/Feasibility Study (RI/FS) in 1990 which
will evaluate all areas of known or suspected contamination at
the Arsenal (including the Building 24 area). The RI/FS will
include an assessment of this interim action in light of new data
which will be collected and propose final actions (which will
include source areas as well as soil and ground water
contamination) for complete site remediation. Final actions will
include contaminant specific clean up objectives. We believe
that this interim action will be consistent with future remedial
actions.
The ground water remediation will consist of the following
components:
* extraction of contaminated ground water,
* pretreatment system for the removal of metals, solids,
etc. from ground water,
-------
-2-
* air stripper for removal of volatile organic compounds
(VOCs) from ground water,
* granular activated carbon (GAC) filtration of VOCs from
the air stripper exhaust,
* GAC filter for the removal of additional VOCs from the
air stripper effluent (treated vater),
* discharge of effluent via a holding tank and piping to
Green Pond Brook,
* operation and maintenance of the system, and
* effluent and air monitoring.
EPA fully appreciates the environmental concern you have shown by
taking this action. If you have any questions regarding the
subject of this letter, please call me at (212) 264-2525, or Mr.
Jeffrey Gratz, the facility Project Manager at (212) 264-6667.
Sincerely,
Acting Regional
P.E.
inistrator
cc: Christopher J. Daggett, Commissioner
New Jersey Department of Environmental
Protection
Steve Anderson
New Jersey Department of Environmental
Protection
Ed Kaup
New Jersey Department of Environmental
Protection
Mr. Thomas Solecki, Picatinny Arsenal
Mr. Peter Rowland, Picatinny Arsenal
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STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
CURlSTOPlinR J. DACGirrr, COM.M1SS1OM-H
CN 402
TRHNTON. N.J. OXf.25
609-292-2XS5
iP 2 8 1989
Brigadier General Joseph Raffiani Jr.
Commanding Officer
US Army Armament R & D Command
Picatinny Arsenal, NJ 07806-5000
Dear General Raffiani:
This letter serves as formal notification that the New Jersey Department oF
Environmental Protection (Department) has reviewed the draft Record of
Decision (ROD) as set forth in the Proposed Remedial Action Plan, dated
September 12, 1989, prepared for the U.S. Army as an interim remedial action
to control the migration of contaminated groundwater emanating from the
Building 24 area at Picatinny Arsenal in Dover, New Jersey. The Department
concurs with the selected remedial alternative.
This alternative will be comprised of:
o Extraction of contaminated groundwater
o Pretreatment system for the removal of metals, solids, etc.
o Air-stripping for removal of VOC's
o GAG filtration for removal of VOC's from the air-stripper exhaust
o GAC filtration for removal of additional VOC's from the air-stripper
' effluent (treated water)
o Discharge of treated water via a holding tank and piping to Green Pond
Brook
o Operation and maintenance of system, and
o Effluent monitoring
This concurrence is based on the assumption that the Department's comments
on the draft document and the Department's environmental guidelines and
standards will be incorporated in the final document.
New Jersey a an Equal Opportunity Employer
Recycled Paper
-------
'Brig. General Joseph Raffiani
Plcattiny Arsenal
Page 2
•-jr^n^^^^^^
commitments are met.
Very truly yours,
\rv«i
Christopher J. Daggett
c William J. Muszinski, P.E.,
Acting Regional Administrator, USEPA
J. Gratz, Project Officer, USEPA
M. Dower, Chief, BFCM
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RECORD OF DECISION DECLARATION
INTERIM REMEDIAL RESPONSE
FOR BUILDING 24 AREA
SITE: Picatinny Arsenal, Dover, New Jersey
STATEMENT OF BASIS AND PURPOSE;
This decision document presents the selected interim remedial
action for the building 24 area, Picatinny Arsenal, Dover, New Jersey.
This decision is based on the administrative record, which includes the
following documents describing the analysis of the cost and effectiveness
of interim remedial alternatives for the building 24 area:
- Engineering Feasibility Study for Interim Groundwater
Remediation at Picatinny Arsenal, Building 24 Study Area, Dover, New
Jersey (ERC Environmental and Energy Services Co., Inc., April 1989).
- Section C - Description/Specifications/Work Statement for
Groundwater Remediation System Installation and Operation at Picatinny
Arsenal, Building 24 Study Area, Dover, New Jersey (ERC Environmental
and Energy Services Co., Inc., June 1989).
- Draft Record of Decision and Environmental Assessment Report
for Interim Remediation Plan, Building 24 Study Area, Picatinny Arsenal,
New Jersey (ERC Environmental and Energy Services Co., Inc.)
- Develop Documentation/Prepare Remedial Action Concept Plan for
Building 24 Contamination Plume at Picatinny Arsenal-Final Report (Engi-
neering Technologies Associates, Inc., April 1989).
- Groundwater studies completed by U.S. Geological Survey, Trento
New Jersey, 1986-1988.
DESCRIPTION OF SELECTED INTERIM REMEDY;
An interim remedial action has been selected to prevent deter-
ioration of Green Pond Brook water quality. This action will minimize
movement of the contaminated groundwater plume caused by past activities
at Building 24 and the surrounding area. The alternative chosen con-
sists of:
extraction of contaminated groundwater,
pretreatment system for the removal of metals, solids, etc.
from groundwater,
air stripper for removal of volatile organic compounds
(VOCs) from groundwater,
- granular activated carbon (GAC) filtration of VOCs from the
air stripper exhaust.,
-------
- GAC filter for the removal of additional VOCs from the air
stripper effluent (treated water) ,
- discharge of effluent via a holding tank and piping to
Green Pond Brook,
operation and maintenance of the system, and
- effluent and air monitoring.
A Remedial Investigation Concept Plan is currently being prepared
for the entire installation.
DECLARATIONS;
Consistent with the Comprehensive Environmental Response Compensa-
tion, and Liability Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and the National Con-
tingency Plan (40 CFR Part 300) , the interim remedial action described
above, together with proper operation and maintenance, constitutes a
cost effective interim remedy which mitigates and minimizes damage to
public health, welfare, and the environment. The State of New Jersey
and U.S. EPA have been consulted and agree with the approved interim
remedy. A letter of concurrence will be provided by the EPA subsequent
to approval by Mr. Walker.
We have determined that the action being taken is a cost effect!^
treatment alternative, which reduces the volume of waste and provided
an interim solution to the maximum extent practicable and will protect
public health, welfare and the environment.
The Army will conduct a formal Remedial Investigation/Feasibility
Study beginning in 1990, which will include an assessment of this in-
terim remedial action in light of new data which will be collected and
propose final actions for complete site remediation.
5S LEWIS D. WALKER
COL, OD Deputy for Environment, Safety and
Acting Commander Occupational Health
Office of the Assistant Secretary of
the Army (Installations and
Logistics)
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RECORD OF DECISION
FOR
INTERIM GROUNDWATER REMEDIATION PLAN
PICATINNY ARSENAL, NEW JERSEY
Prepared For:
U.S. Army Corps of Engineers
Huntsville Division — CEHND-ED-PM
Contract No. DACA87-88-D-0079
Delivery Order 0005
Prepared By:
ERC Environmental and Energy Services Company
725 Pellissippi Parkway
P.O. Box 22879
Knoxville, Tennessee 37933
22 May 1989
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TABLE OF CONTENTS
PAGE NO.
FOREWORD iii
1.0 INTRODUCTION 1-1
1.1 Purpose and Objectives 1-1
1.2 Site Description 1-i
1.3 Site History 1-2
'• *i
2.0 PLANNED REMEDIAL ACTION 2-1
2.1 Remedial Action Objectives 2-1
3.0 EVALUATION OF INTERIM REMEDIAL ACTION 3-1
ALTERNATIVES
3.1 Evaluation of Alternatives 3-1
3.2 Selection of Interim Remedial Action 3-5
4.0 STATUTORY FINDINGS - 4-1
4.1 Applicable or Relevant and Appropriate 4-1
Requirements (ARARs)
4.2 Permits and Approvals 4-1
4.3 Reduction of Mobility, Toxicity, or 4-2
Volume
4.4 Cost-Effectiveness of Planned Action 4-2
4.5 Use of Alternative Technologies and 4-2
Permanent Solutions
5.0 SUMMARY AND CONCLUSIONS 5-1
5.1 Summary 5-1
5.2 Conclusions 5-2
REFERENCES R-l
APPENDIX A
LIST OF TABLES AND FIGURES
TABLES PAGE NO.
2-1 Contaminants and Naturally Occurring 2-2
Groundwater Constituents
3-1 Summary of Alternatives Evaluated 3-2
3-2 Comparison of Alternatives 3-6
FIGURES
3-1 Flow Sheet for Interim Groundwater 3-8
Treatment System
3-2 Location of System Components 3-9
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FOREWORD
The Record of Decision was written to address points described in
EPA's February 1989 "Guidance on Remedial Actions for Contaminated
Groundwater at Superfund Sites", EPA/G-88/003, OSWER Directive
9283.1-2 (Appendix C, Documenting an Interim Action).
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1. 0 INTRODUCTION
1.1 PURPOSE AND OBJECTIVES
The US Army Toxic and Hazardous Materials Agency (USATHAMA) is
preparing to perform CERCLA RI/FS activities at Picatinny Arsenal,
New Jersey. This document*is the US Army's Record of Decision
(ROD) for selection and implementation of an interim groundwater
remediation action at Picatinny Arsenal, New Jersey. A formal
remedial investigation and feasibility study (RI/FS) is currently
being planned. The final remedial action will be implemented
following the RI/FS.
Groundwater contamination above State of New Jersey and Federal
action levels has been detected in the vicinity of. Building 24,
where past wastewater treatment practices allowed the infiltration
of metal plating waste constituents (volatile organic compounds and
heavy metals) into the groundwater. Previous investigations
conducted by the U.S. Geological Survey (USGS) have defined a
contaminant plume that consists primarily of trichloroethylene
(TCE) . Picatinny Arsenal has elected to implement interim remedial
measures, including groundwater treatment, rather than wait until
the RI/FS activities are completed.
1.2 SITE DESCRIPTION
"Picatinny Arsenal is located in north-central New Jersey in Morris
County near the City of Dover. The installation, formally known
as the U.S. Army Armament Research, Development and Engineering
Center, employs approximately 6,400 people in research and
development of munitions and weapons. The Arsenal covers 6,491
acres and contains more than 1,500 buildings serviced by
approximately 85 miles of road.
The Arsenal property is approximately rectangular in shape,
approximately 8.5 miles long by 1.5 miles wide. It is situated in
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an elongated northeast-southwest trending valley bounded by Green
Pond Mountain on the west, Green Pond Mountain and Copperas
Mountain near northwestern border, and an unnamed ridge to the
southeast. Green Pond and Copperas Mountains are
characteristically rugged, rocky and steeply sloped with a maximum
altitude of 1,200 feet above National Geodetic Vertical Datum of
1929 (NGVD of 1929). The 'southeastern ridge is not as rugged or
steeply sloped and has a maximum altitude of 1,100 feet above NGVD
of 1929. The valley is drained to the southwest primarily by Green
Pond Brook. It has two manmade lakes—Lake Denmark and Picatinny
Lake. The study area is located in the valley southwest of
Picatinny Lake. The area is drained by a number of small brooks
and drainage ditches in addition to Green Pond Brook. Topography
is flat and generally at an altitude of 700 feet. Some parts of
the area is swampy, prone to flooding, and generally underlain by
organic-rich soil. In the developed areas, stony fill has been
added to give support to structures.
1.3 SITE HISTORY
The Arsenal has a long history of manufacturing explosives,
beginning in the mid-1800s. In 1908, it was designated a U.S. Army
Arsenal. Picatinny Arsenal has been a site for the production of
various munitions including cannon shot in its earlier days and,
during the World War I, artillery ammunition bombs, high explosives
and other ordnance. During World War II, 20,000 people were
employed to produce artillery, ammunition, bombs, high explosives,
pyrotechnics, and other ordnance items. The Arsenal was a major
source of munitions for the Korean and Vietnam Conflicts. More
recently, the Arsenal, officially known as the U.S. Army Armament
Research, Development and Engineering Center (USARDEC), has been
tasked to perform the research on and development of large caliber
munitions. Past industrial activities and past waste-disposal
practices have resulted in contaminated surface and groundwater in
parts of the area.
1-2
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2.0 PLANNTED INTERIM REMEDIAL ACTION
2.1 INTERIM REMEDIAL ACTION OBJECTIVES
The remedial action objectives for this project were determined by
the US Army to be cleanup of groundwater as an interim measure
while environmental contamination of the Arsenal as a whole was
evaluated. This action will also prevent deterioration of Green
Pond Brook water quality by minimizing movement of contaminated
groundwater into the brook. A source of contamination, two unlined
lagoons alongside Building 24, was eliminated during a 1981 action
during which the unlined lagoons were demolished, contaminated soil
removed, and two concrete lagoons installed. A dry well, thought
to be a second source of VOCs, is still present at Building 24,
beneath asphalt pavement just outside the building. The condensate
line connecting the plating shop fume/vapor collecting system to
the dry well was capped in 1985. A potential third source of VOCs
is a former drum storage area at Building 31, directly across the
street from Building 24.
Contaminants of interest for the study are the VOCs and heavy
metals shown in Table 2-1. Other naturally occurring groundwater
constituents of interest include iron, manganese, calcium, copper,
and zinc. These constituents are of interest because of their
potential effect on treatment system units (i.e., iron, manganese,
calcium), and effects on aquatic microogranisms (cooper, zinc) in
the event of discharge to surface waters.
-------
Table 2-1. Contaminants and Naturally Occurring Groundwater Constituents
Volatile Organic Contaminants fVOCsl
voc
Benzene
Chloroform
1,1 - Dichloroethylene
1,2 - Trans Dichloroethylene
Methylene Chloride
Tetrachloroethylene
Toluene
Trichloroethylene
1,1,1 - Trichloroethane
1,1 Dichloroethane
Freon 113
Phenols, total
Ranqe
ND -
ND -
ND -
ND -
ND -
ND -
ND
ND -•
ND -
ND -
ND -
ND -
of Concentrations fppb)
TR
TR
3.6
160
9.6
78.4
25,200
20.7
1.5
15
50
Average Concentration fppbi
ND/TR
ND/TR
1.3
18.6
1.2
8.9-
ND
854.3
15.2
0.4
TR
LT 50
a. Based on average of 1983-1987 data from 9 shallow wells in Study Area
ND
Not detected
TR -» Trace (LT 5 ppb)
LT " Less than
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Table 2-1.
Contaminants and Naturally Occurring Groundwater Contaminants
(continued)
fieavv Metals
Range of Concentration fppb)
Cadmium
Chromium
Lead
Selenium
Arsenic
Copper
Zinc
Iron
Note:
1-34.9
4-57
8-108
1-9
1-16
1-89
39-1400
87-77,895
The nine shallow wells in the study area are:
Average Concentration
10
19.4
14.7
5
6.5
32
244.5
9359
270093
270094
270095
270096
270238
270239
270243
270267
270282
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3.0 EVALUATION OF ALTERNATIVES
3.1 EVALUATION OF ALTERNATIVES
Table 3-1 contains a brief description of the interim remedial
action alternatives developed and evaluated in the engineering
feasiblity study (FS). An* expanded discussion of alternatives
returned for detailed evaluation and comparison is included as
Appendix A. Those marked by an Asterisk (*) were selected for
final evaluation; the others were eliminated on the basis of cost
or failure to satisfy EPA and NJDEP regulatory criteria.
Alternative 1, the No Action alternative, was retained as the base-
line for final evaluations. The .interim remedial action
alternatives initially considered encompassed the following basic
actions:
o No action
o Groundwater withdrawal for treatment by air stripping,
followed by discharge to surface water (Green Pond Brook)
or reuse by the arsenal
o Groundwater withdrawal for treatment by carbon adsorption
o Groundwater withdrawal for treatment by spray irrigation
o Groundwater withdrawal and discharge to the local sewage
treatment plant with no pretreatment
The final evaluation of alternatives eliminated all alternatives
except the mandatory No Action alternative and those alternatives
employing a groundwater withdrawal system, a groundwater treatment
system, and an air stripper (Alternatives 3A, 3B, 3C, 3D, and 3G).
-------
Title/Descriptior)
*1 No Action.
Table 3-1
Summary of Alternatives Evaluated
Advantages
Cost savings; no additional
expenditures.
Groundwater extraction and pretreatment;
discharge to STP.
Minimum effort; cost depends
largely on fee charged by
STP.
*3A
*3B
Groundwater extraction and pretreatment;
air stripper-basic system; discharge to
surface waters.
Groundwater extraction and pretreatment;
air stripper-basic system; GAC polisher;
discharge to surface water.
**3C Air stripper-complete system (air stripper
polisher, off-gas filter); discharge to
surface waters.
Achieve "in house" ground-
water cleanup goals at
reasonable cost.
BAT for groundwater treat-
ment.
BAT for groundwater, air
stripper off-gas; meets all
ARARs for air and surface
water. Favored by NJDEP and
EPA Region II.
**
Alternatives selected for detailed evaluation
Alternative selected for implementation
Disadvantages
Does not provide
control or
reduction of
contamination,
except slow
reduction due
to dispersal.
Questionable "true"
reduction
of VOCs (dilution).
Possible adverse
affect on STP due
to reduced biomass
concentration.
No water effluent
polishing or off-
gas control. Cost.
Minor cost increase
over Alt. 2. No
off-gas control.
Cost.
Cost.
-------
Table 3-1.
Summary of Alternatives Evaluated
(continued)
Title/Description
Groundwater extraction and pretreatment
air stripper-complete system; recycle
to drinking water treatment system as
raw water replacement.
Groundwater extraction and pretreament;
air stripper-complete system; slurry
wall and groundwater extraction trench;
discharge to surface water.
Groundwater extraction; air stripping
raw groundwater; discharge to
groundwater (DGW).
Groundwater extraction and pretreatment
air stripping; GAG effluent polishing
filter; GAG air filter; discharge to
surface water initially, consider
discharge to Drinking Water System
baaed on system performance (approx.
3-6, months) .
Groundwater extraction; utilize
existing drinking water system
with addition of air stripper
and GAG polishing filter.
Advantages
BAT for groundwater, air
stripper off-gas. Eliminates
need for treated water
discharge permit. Reduced
cost of operating water
treatment plant.
Favored by Arsenal.
Reduced infiltration from
Green Pond Brook; small re-
duction of water volume to be,
extracted.
Reduced capital and O&M cost
over Alternatives 3A-3E.
Combines the institutional
advantages of Alternatives
3C and 3D.
pisadvantagea
Cost. Potential
Public relations
problems in
"Selling" reuse of
purified water
from contaminated
area.
Additional cost of
slurry wall and
gallery, (approx.
$950,000).
May not achieve of
NJDEP effluent
quality
requirements for
DGW. Negotiable.
Same as 3C, 3D.
Utilize/upgrade existing
system; reduce overall
costs; eliminate need for
industrial wastewater
discharge permit.
Possible delay in
implementation.
-------
B
Table 3-1.
Summary of Alternatives Evaluated
(continued)
Title/Description
Groundwater extraction and pretreatmenti
GAG filteration; discharge to surface
water.
Groundwater extraction and pretreatment;
GAC filteration; discharge as raw-water
source to Arsenal's drinking water
treatment system.
Groundwater extraction, no pretreatment;
spray irrigation to uninhabitated/
unfrequented area(s) of arsenal.
Groundwater extraction and pretreatment;
spray irrigation to uninhabitated/
unfrequented area(s) of arsenal.
Advantages
Reduce number of unit
operations (eliminates air
stripper and off-gas
controls).
Reduced number of unit
operations (eliminates
air stripper and off-gas
controls).
Low cost.
Low to moderate cost;
toxic metals removal.
Disadvantages
Greater GAC usage at
high VOC
concentrations.
Cost.
Greater GAC usage at
high VOC
concentrations.
Cost.
NJDEP
permits/approval
required for
discharge to air,
surface water, and
groundwater.
NJDEP permits
required for
discharges to air,
-------
These remedial action alternatives encompass all alternatives
deemed to be both technically and institutionally feasible for this
project. ' These alternatives were discussed and evaluated in two
documents previously developed for this project — the Engineering
Feasibility Study and the Cost Estimate reports. Table 3-2 is a
summary of the evaluation for the nine criteria required under
CERCLA. Background documents used for these reports are listed in
the reference section of this ROD.
3.2 SELECTION OF INTERIM REMEDIAL ACTION
USAGE has decided to implement Interim Remedial Action Alternative
3C (Table 3-1). Alternative 3C consists of the following:
o groundwater withdrawal
o pretreatment
o air stripping (w/GAC air filter for air emissions control)
o GAG polishing filter
o discharge of treated water to Green Pond Brook
Figure 3-1 is a schematic of the system.
The primary considerations were:
o capability to achieve interim remedial action objectives
o minimization of adverse public health and environmental
impacts associated with remedial action implementation
o implementability and dependability of action
o speed with which the alternative could be implemented
o effectiveness and dependability of the unit operations
employed in the system
o probability of continuing the interim remedial action as
part of the long-term remedial action to be' selected
following the formal RI/FS
Figure 3-2 provides additional information on location of system
components.
-------
Table 3-2. Comparison of Alternatives
Iternative
No.
Short-term
Effectiveness
Long-term
Effectiveness
and Permanence
Reduction of
Toxicity,
Mobility and
Volume
Implementability
*1
2
*3A
*3B
**3C
*3D
3E
3F
*3G
4
5A
5B
6A
6B
L
H
H
H
H
H
H
M
H
H
H
H
H
M
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
L
M
M
M
H
H
H
M
H
II
M
M
M
M
H
M
M
M
H
M
H
L
H
M
L
L
M
H
elative Achievement of Criterion: H «= high; M = moderate, L
relative to other alternative presented)
•A: Criterion no applicable for this interim remedial action
Alternatives selected for detailed evaluation
low
Alternatiive selected for implementation
-------
Table 3-2. (continued)
Iternative
No.
*1
2
*3A
*3B
**3C
*3D
3E
3F
*3G
4
5A
5B
6A
6B
Cost
Effectivness
H
H
M
M
M
M
H
H
M
M
L
L
M
I!
ARARS
Compliance
L
M
M
M
H
H
H
M
H
H
M
M
M
L
Overall
Protection
L
M
M
M
H
H
H
M
H
H
M
M
M
L
State
Accept .
NA
M
M
M
H
M
M
M
H
M
L
L
L
L
Comro
Accept
NA
H
M.
M
H
M
M
M
H
M
L
L
L
L
-------
FLOW
EQUALIZATION
TANK
PRETREATMENT
UNIT
CONTAMINATED
WATER
WELL FIELD
T I I I T
H20
SLUDGE
GAC AIR
FILTER
TO
ATMOSPHERE
/ L
AIR
AIR
STRIPPING
UNIT
H20
GAC
POLISHING
FILTER
PRETREATMENT: METALS, SOUDS REMOVAL
AIR STRIPPING UNIT: VOC REMOVAL - 99*
GAC POLISHING FILTER: RESIDUAL VOC REMOVAL
GAC AIR FILTER: VOC REMOVAL FROM EXHAUST AIR
PURIFIED
WATER—
TO
DISCHARGE
FIGURE 3-1. FLOW SHEET FOR Gfl^NDWATER TREATMENT SYSTEM
-------
UNITED STATES DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
.•
J>
•tf.
•V
.k
APPROXIMATE
LOCATION OF
.TREATMENT SYSTEM
Bast map from basic Information map< of Plcallnny Arsenal, 1975
s \ /
•l .*k
FIGURE 3-2. APPROXIMATE LOCATION OF WITHDRAWAL WELLS, TREAT
-------
OPEN-FILE REPORT 86-58
(USGS 1986)
APPROXIMATE EFFLUENT
DISCHARGE POINT TO
GREEN PND BROOK
'ROXIMATE LOCATION tF
WITHDRAWAL WELLS EXPLANATION
{P = PRIMARY WELLS-, —10o TOPOGRAPHIC CONTOUR--
S s SECONDARY WELLS)
0 400 100 1100 FEET
0 100 300 300 METERS
Shows line ol equal land
surface elevation. Interval
SO feet. National Geodetic
Vertical Datum of 1929.
^ Well sampled lor analyila
231 Well number
Building, permanent
Drainage channel
— - — Arsenal boundary
•—• — • Fence
•-4=*= Bridge
"^ Culvert
== Road, surfaced
:::::: Road, unimproved
N
"«.
SYSTEM, AND EFFLUENT DISCHARGE POINT
Figure 3-2
-------
After consultation with responsible NJDEP and EPA Region II
authorities, the .US Army has determined that Alternative 3C
satisfies these considerations.
-------
4.0 STATUTORY FINDINGS
Because this action is an interim remedial action, it is not
necessary to achieve all requirements that would apply to a final
action under CERCLA. This action provides for the minimization of
contaminant migration by hydraulically controlling groundwater
movement, and concurrently" ^treating contaminated groundwater for
removal of VOCs. Care has been taken to minimize or prevent cross-
media contamination; waste streams have been identified and plans
made for effective waste management.
4.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS fARARs^
ARARs will be provided by the NJDEP for the following effluents
and wastes:
o treated water (to be discharged to Green Pond Brook)
o air emissions from the air stripper
o sludge from pretreatment unit
o spent carbon from GAC air filter and GAC treated water
polishing filter
The ARARs shall be used to establish effluent quality and allowable
VOC emissions to the atmosphere, and to provide for the management
of generated wastes in accordance with NJDEP regulations for the
management of industrial and hazardous solid wastes. ARARs for
groundwater cleanup will apply to the final remedial action, but
not this remedial action. However, cleanup of groundwater and soil
will progress under this interim action.
4.2 PERMITS AND APPROVALS
Because this action is being performed under CERCLA, .formal permits
for discharges to air and surface water and operation of a waste
treatment facility are not required. However, NJDEP and EPA*
technical requirements for these permits will be established and
met during the performance of this action.
-------
4.3 REDUCTION OF MOBILITY. TOXICITY. OR VOLUME
The plannned interim remedial action will be effective in reducing
the mobility, toxicity, and volume of contaminated groundwater.
Approximately 144,000 - 216,000 gallons of water will be pumped and
treated daily.
4.4 COST-EFFECTIVENESS OF PLANNED ACTION
This action has been determined to be cost-effective for the
objectives of the action. Cost data cannot be provided at this
time, however, since USAGE is preparing to offer a competitive bid
contract for the performance of the action, to include final
design, installation, and operation and maintenance of the system.
4.5 USE OF ALTERNATIVE TECHNOLOGIES AND PERMANENT SOLUTIONS
Use of alternative or innovative technologies were not applicable
to this interim action, since time constraints dictated that proven
and dependable technologies be employed. While this action is not
in itself permanent solution, it will likely be continued, with or
without modification, to become part of the permanent solution.
-------
5.0 SUMMARY AND CONCLUSIONS
5.1 SUMMARY
5.1.1 Environmental Impacts
A discussion of probable and potential (possible) environmental
impacts, both adverse and beneficial, is provided in the
Environmental Assessment (EA) Report issued under separate cover
concurrently with this ROD. This EA was performed in accordance
with regulations promulgated by the President's Council of
Environmental Quality (CEQ) at 40 CFR 1500-1508, and by the USAGE
at 32 CFR 651 (U.S. Army Regulation 200-2).
5.1.1.1 Groundvater Impacts
Impact on groundwater will be beneficial., since contaminants will
be removed much faster than they would be by natural flushing, and
practically all VOCs removed will be trapped for proper disposal.
Other process wastes will be analyzed and managed as hazardous or
nonhazardous solid wastes, as appropriate.
5.1.1.2 Surface Water Impacts
The very high quality effluent (treated groundwater) from the
system will have little, if any, effect of surface water quality.
The maximum discharge rate of approximately 150 gpm is a small
percentage of base flow for Green Pond Brook, and the water will
be well-oxygenated (air stripper) and of equal (or better) purity.
Discharge temperature will be approximately ambient. Effluent pH
will met NJPDES requirements for point source discharge to surface
water.
-------
5.1.1.3 Air Quality Impact
*
Air quality impact will be negligible with or without GAC air
filtration. Peak VOC discharge from the air stripper will be
approximately one pound per day, with an expected average of 1/2
to 2/3 pounds per day. A GAC air filtration system will trap 99%
or more of the VOCs. "'•
5.1.1.4 Waste Generation
Generated wastes will consist of the following:
o pretreatment system sludge containing metals and solids from
the groundwater
o expended GAC from the effluent polishing filter
o expended GAC from the air filter
The pretreatment system sludge will be similar to that generated
in the Arsenal's drinking water system. The sludge will be
presumed to be hazardous, and tested to determine actual
constituents and characteristics. The expended GAC will be shipped
off site for disposal as a hazardous waste or regenerated for reuse
by the supplier. The VOCs managed as a hazardous waste under RCRA
rules. Heavy metals characteristic of plating shop wastes are
present at elevated levels in groundwater in the vicinity of
Building 24; however, it is unlikely that these metals will be
present at higher than back ground levels in the groundwater
withdrawal area.
5.1.2 Public Health Effects
There will be no adverse public health effects as a consequence of
this action. Use of water from the area as a drinking water source
was discontinued in 1985. Use of the groundwater will continue to
be restricted by the US Army.
-------
5.2 CONCLUSIONS
k
USAGE has determined that the selection and implementation of this
selected interim remedial action alternative meets all regulatory
requirements of the CEQ and the US Army. It will provide for
public health and environmental protection in a cost-effective
manner, and will not in any"way adversely effect plans for long-
term remediation at the Arsenal.
Signed:
Deputy Assistant Secretary of
the Army
Environmental, Safety and
Occupational Health
-------
REFERENCES
EPA, 1986, Superfund Remedial Design and Remedial Action Guidanrg
^Revised). OSWER Directive 9355.0-4A (NTIS: PB 88-
107529), Office of Solid Waste and Emergency Reponse, US
Environmental Protection Agency, Washington, DC, June
1986.
EPA, 1986, Superfund Public Health Evaluation Manual. OSWER
Directive 9285.4-1 '*(EPA/540/l-86/060) , Office of
Emergency and Remedial Response, US Environmental
Protection Agency, Washington, DC, October 1986.
EPA, 1987, RCRA Corrective Action Interim Measures. OSWER
Directive 9902.4, Office of Solid Waste and Emergency
Response, US Environmental Protection Agency, Washington,
DC, 10 June 1987.
EPA, 1987, Interim Guidance on Compliance with Applicable or
Relevant and Appropriate Requirements. OSWER Directive
9234.0-05, Office of Solid Waste and Emergency Response,
US Environmental Protection Agency, Washington, DC, 9
July 1987.
EPA, 1988, Guidance for Conducting Remedial Investigation and
Feasibility Studies Under CERCLA. (Draft), OSWER
Directive 9335.3-01, Office of Solid Waste and Emergency
Response, US Environmental Protection Agency, Washington,
DC, March 1988.
EPA, 1988, Superfund Exposure Assessment Manual. EPA/540/1-88-001,
OSWER Directive 9285.5-1, Office of Remedial Reponse, US
Environmental Protection Agency, Washington, DC April
1988.
EPA, 1989, Guidance on Remedial Actions for Contaminated
Groundwater at Superfund Sites. (interim final).
EPA/540/G-88/003, OSWER Directive 9283.1-2, Office of
Emergency and Remedial Response, US Environmental
Protection Agency, Washington, DC, February 1989.
ETAI, 1989, "Develop Documentation/Prepare Remedial Action Concept
Plan for Building 24 Contamination Plume at Picatinny
Arsenal-Final Report", Prepared for the US Army Toxic and
Hazardous Materials Agency, Aberdeen Proving Grounds,
Maryland, by Engineering Technologies Associates, Inc.,
3548 Ellicott Center Drive, Ellicott City, Maryland
21043, 17 April 1989.
NJDEP, 1988, Regulations Implementing the New Jersey Water
Pollution Control Act. (N.J.S.A. 58:10A), New Jersey
Department of Environmental Protection, Trenton, New
Jersey, March 1988.
-------
USAGE, 1989a, "Engineering Report - Evaluation of Groundwater
Withdrawal and Treatment at Picatinny Arsenal, New
Jersey", prepared by ERG Environmental and Energy
Services Company, Knoxville, Tennessee, for the US Army
Corps of Engineers, Huntsville Division, Huntsville,
Alabama, April 1989.
USAGE, 1989b, "Environmental Assessment Report - Interim
Groundwater Remediation Plan, Building 24 Study Area,
Picatinny Arsenal, New Jersey", prepared by ERC
Environmental and'Energy Services Company, Knoxville,
Tennessee, for the US Army Corps of Engineers, Huntsville
Division, Huntsville, Alabama, May 1989.
USGS, 1986a, "Groundwater Quality Data for Picatinny Arsenal, New
Jersey, 1958-85", US Geological Survey Open-File Report
86-58, Trenton, New Jersey, 1986.
USGS, 1986b, "Determination of Geohydrological Framework and Extent
of Groundwater Contamination Using Surface Geophysical
Techniques at Picatinny Arsenal, New Jersey", US
Geological Survey Water-Resources Investigations Report
86-5051, Trenton, New Jersey, 1986.
USGS, 1986c, "Description and Results of Test-Drilling Program at"
Picatinny Arsenal, New Jersey", US Geological Survey
Open-File Report 96-316, Trenton, New Jersey, 1986.
USGS, 1988, "Groundwater Contamination in the Area of Building 24,
Picatinny Arsenal, New Jersey (Draft), Us Geological
Survey Water-Resources Investigations Report 88-xx,
Trenton, New Jersey, 1988.
AR 200-2, 1989, US Army Regulation 200-2, Department of the Army,
Washington, DC, 1989 (32 CFR 651).
40 CFR 1500-1508, Code of Federal Regulations, Washington, DC.
-------
APPENDIX A
DETAILED EVALUATION OF REMEDIAL ACTION ALTERNATIVES
-------
DETAILED ANALYSIS OF INTERIM REMEDIAL ACTION ALTERNATIVES
1.1 INTRODUCTION
The detailed analysis of alternatives is the analyses and
presentation of the relevant information needed to allow
decisionmakers to select-,a site remedy: it is not the
decisionmaking process itself. Each alternative has been assessed
against the nine evaluation criteria described below (Section
1.1.3). The results of this assessment are arrayed such that
comparisons can be made among alternatives and the key tradeoffs
among alternatives can be identified. This approach to analyzing
alternatives provides decisionmakers with sufficient information
to adequately compare the alternatives, select the most appropriate
remedy for a site (in this case an interim action) , and demonstrate
that the goals of the Record of Decision (ROD) have been met.
1.1.1 Requirements to be Addressed
The specific CERCLA requirements that must be addressed in the ROD
and supported by the Feasibility Study (FS) report for a permanent
solution are listed below:
o Be protective of human health and the environment.
o Attain ARARs (or provide grounds for requesting a waiver).
o Be cost-effective.
o Use permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable. (not applicable to this
interim remedial action).
o Satisfy the preference for treatment that reduces
toxicity, mobility, or volume as a principal element (or
provide an explanation in the ROD as to why it does not) .
However, for this interim remedial action, these considerations
must be viewed from the prespective of improving the groundwater
situation while complying with environmental regulations. This
-------
interim remedial action must not result in significant degradation
*of other media (air, soil, surface water).
1.1.2 Considerations for Long-term Effectiveness
Because this project is an interim remedial action being
voluntarily implemented wftile a formal RI/FS is performed,
considerations of long-term effectiveness are not applicable.
1.1.3 Evaluative Criteria for Remedial Action Alternative
Nine evaluation criteria have been developed to address the CERCLA
requirements and considerations listed above as well as additional
technical and policy considerations that have proven to be
important for selecting a remedial action from among remedial
alternatives. These evaluation criteria serve as the basis for
conducting the detailed analyses during the FS and for the
subsequent selection of an appropriate remedial action. The
evaluation criteria and associated considerations are:
o Short-term effectiveness
o Long-term effectiveness and permanence
o Reduction of toxicity, mobility, or volume
o Implementability
o Cost
o Compliance with ARARs
o Overall protection of human health and the environment
o State acceptance
o Community acceptance
For this interim remedial action, short-term effectiveness,
implementability, cost, and compliance with ARARs are the primary
considerations. The other criteria, while still important, will
be more fully addressed in the formal RI/FS to be performed at a
later date.
-------
The detailed analysis of alternatives consists of the following:
o Further definition of each alternative with respect to
the volumes or areas of contaminated media to be
addressed, the technologies to be used, and any
performance requirements associated with those
technologies *"*
o An assessment and a summary of each alternative against
the nine evaluation criteria
o A comparative analysis among the alternatives to assess
the relative performance of each alternative with respect
to each evaluation criterion
Figure 1 illustrates the steps in the detailed analysis process..
Figure 2 is a presentation of criteria for the detailed analysis
of alternatives.
1.1.4 Summary of Key Environmental Protection Permits
Table 1 is a summary of key environmental protection permits that
would be required for each alternative retained for detailed
analysis.
1.2 ANALYSIS OF ALTERNATIVES
The evaluation of the alternatives that passed the FS preliminary
screening is presented in this subsection. Each alternative was
evaluated on the basis of the nine criteria discussed in Subsection
1.1.
-------
DETAILED ANALYSIS OF ALTERNATIVES
Development/
Screening of
Alternatives
Results of
Tre stability
Investigations
if Conducted
Further Definition
of Alternatives as
Necessary
Individual Analysis
of Alternatives
Against Evaluation
Criteria
Comparative Analysis of
Alternatives Against
Evaluation Criteria
Issuance of
Feasibility Study Report
Figure 1. Detailed Analysis of Alternatives
-------
CRITERIA FOR DETAILED ANALYSIS OF ALTERNATIVES
SHORT-TERM
EFFECTIVENESS
• ProdueBon el Community
During Remedial Acaons
• Prot»e»on ol Workers
Dunng Remedial Acsora
i Envi
maJ Impaca
• Tim* Uml Remedial
ACJOO Objecsves An
Acrueved
LONG-TERM
EFFECTIVENESS
• Magniajde of
Residual Risk
• Adequacy of
CorwoU
• Relia&ilify of
Coiwols
REDUCTION OF Toxcrry.
M06IUTY, AND VOLUkC
• Treasnent Prceeis Used and
Materials Treated
• Amount of Htardous
Mucnalt Dticoyvd or
Tniud
• 0*gr»* of
Rvdjeoni in Toxicty,
Mo»ii(y, and Voium*
• Ot?'M a Whiefi
TrMvrwni It Imfvvrsibt*
• Type tnd Ouanety of
RtJis.ui Remaining After
Trtiment
(MPLEMENTABlLfTY
> Ability to Corutruct and
Cp«rai* O» Ttcnnology
i R«(i«ailir)r of tm
T«einologjr
> Eu« of Undcnaking
Addifional Htm»<3nj
Acaon*. if N*aiuiy
' Abilify a Monitor Efl««v»-
nets ol Rtmeoy
> Ability to Osam
App'ovaii Prom Oner
Agencies
• Coordination Wiin Oner
Agenoe*
> Avsilaeility of OKiite
Tr*arn*nt. Siamge. and
Disposal S«rvcc»i and
Ctpaoty
> Availability of Necessary
Eauipmem and
Sp*aaiists
• Timing of New Technology
Under Consideration
• Ooerasng and
Maintenance Cos:
• Present Worn
Cost
PROTECTION O? HUMAN HEALTH
AND TH= ENVIRONV€NT
How Altemaove Provides Human
Healtn and Envronmenal Proiecson
COMPUANCE WITH ARARs
• Compliance Win Conaminant-Speofie
ARARs
• Compliance Win Anon-Specific ARARs
• Compliance Witn Loeason-Specftc ARARa
• Compliance Win Oner Critena. Advisories.
and Guidances
STATE
ACCEPTANCE
COKMJNfTY
ACCEPTANCE
Figure 2. Criteria for Detailed
Analysis of Altp.•»*•
-------
Table 1. Summary of Major Permits or Approvals Required for each
Remedial Action Alternative
Approvals/Permits Required
iternative
No.
Groundwater
Quality Waiver
Air
Emission
Discharge
Industrial
(NJDPES)
Wastewater
Water Well
Installation
Point Source Non-Point
Source
1
3A
3B
3C
3D
3G
X
(X)
(X)
(X)
(X)
(X)
—
X
X
X
X
X
—
X
X
X
—
X
—
.
—
—
—
—
—
X
X
X
X
X
) Indicates questionable requirement
-------
Table l. (continued)
Alternative
No.
Discharge to
Sewage Treat-
ment
Public Drinking
Water System
Hazardous Waste
Generation No.
(Possibly—Pre-
treatment Sludge)
Hazardous Waste
Storage (Possibly-
.Pretreatment
t Sludge)
1
3A
3B
3C
3D — X
3G — X
—
—
X
X
X
X
—
—
X
X
X
X
-------
For all action alternatives, the following are key considerations
'for comparative evaluations:
o pumping rate: 100 gpm (plan); 150 gpm (maximum)
o Estimated VOC concentrations at treatment units: 750
ppb maximum; 500 ppb average
o VOC quantity stripped from water per day: Approx. 0.37
kilogram per day (p.81 pounds per day) at 750 ppb; 1/3
less at 500 ppb
o single stripping tower removal efficiency: 99%; residual
effluent concentration. 7.5 ppb for 750 ppb influent
o two stripping towers in series: 99.9% removal; residual
effluent concentrations less than 1 ppb (ideally)
o GAC polishing filter — polish effluent from one
stripping tower to less than 1 ppb; also removes metals
and other organics that may not be removed efficiently
by air stripping. Also capable of operating without air
stripper, with more frequent GAC replacement.
o costs similar for second air stripper and GAC polishing
filter
The following discussions of the alternatives analysis uses the
above facts as the basis for technical evaluation.
1.2.1 Alternative 1 Analysis
Alternative 1, the No Action alternative, is presented as the
baseline case for comparison of all remedial action alternatives.
This alternative was ruled out when the US Army decided to
implement this interim groundwater remediation project while plans
are being made for an arsenal-wide RI/FS under the Def-ense
Environmental Restoration Program (DERP).
-------
1.2.1.1 Short-term Effectiveness
Not applicable for the No Action Alternative.
1.2.1.1 Long-term Effectiveness and Permanence
Not applicable for the No Action Alternative.
1.2.1.3 Reduction of Toxicity, Mobility, or Volume
No Action would result in the slow decrease in VOC and toxic metals
concentration with time. VOC concentration would decrease
primarily as a result of dilution and dispersion. Some decrease
in groundwater VOC concentration may result from microbial activity
and volatilization into the vadose zone, and then to the
atmosphere. However, these later two mechanisms would probably be
of minor consequence especially for the chlorinated organics.
Reduction in toxic metals concentrations present at levels above
background would occur as a result of dilution and dispersion, as
well as precipitation after natural geochemical conversion to less
soluble forms.
1.2.1.4 Implementability
Not applicable to the No Action Alternative.
1.2.1.5 Cost
Costs would consist of continued groundwater monitoring until
implementation of a final remedial action after the completion of
the planned Arsenal-wide RI/FS.
-------
1.2.1.6 Compliance with ARARs
Consideration of ARARs is not applicable in this case, since the
planned action is being voluntarily performed as an interim action
while the formal RI/FS is being planned.
1.2.1.7 Overall Protectibrt
The situation does not constitute a threat to human-health, since
the use of groundwater is being controlled at the Arsenal and no
water is being drawn from the contaminated area. Presence in Green
Pond Brook of contaminants from the plume are near detection levels
(less than 5 ppb) , and the water from the brook is not used
directly as a drinking water source. The brook discharges into the
Rockaway River, which discharges to Boonton Reservior, a drinking
water source.
1.2.1.8 State of New Jersey Acceptance
Since this interim action was initiated by the U.S. Army as an
interim measure, State of New Jersey acceptance of the No Action
Alternative is not an issue.
1.2.1.9 Community Acceptance
The community is the military personnel assigned to the Arsenal
the dependents of these who reside on the Arsenal; the civilian
workers who are employed by the Arsenal; and others living in the
vicinity of the Arsenal who may be affected by the action. All
real property on the Arsenal is federally owned (land, buildings,
etc.).
-------
1.2.2 Alternative 3A Analysis
Alternative 3A consists of groundwater extraction, pretreatment,
and removal of VOCs by means of a countercurrent airflow packed
column stripping tower. There would be no control over air
emissions; treated water would be discharged to surface water
without final "polishing". "'•
1.2.2.1 Short-term Effectiveness
The short-term effectiveness of this would be high for removal of
contaminants from groundwater.
1.2.2.2 Long-term Effectiveness and Permanence
Long-term effectiveness and permanence is not an issue for thisj
interim action.
1.2.2.3 Reduction of Toxicity, Mobility, and Volume
Toxicitv
Reduction of toxicity of groundwater would be achieved by removal
of contaminated groundwater.
Mobility
Reduction of mobility (contaminant plume spread) would be achieved
by groundwater withdrawal at a rate of 100 gpm from the designated
locations.
Volume
Volume reduction is not applicable to this alternative.
-------
1.2.2.4 Implementabilitv
This alternative would be technically simple to implement.
Institutional considerations are concerned with air emissions (voc-
contaminated air from the stripping tower) and discharge of the
"stripped" water to surface water. These issues will have to be
discussed with the respective NJDEP representatives, since they are
site specific issues.
1.2.2.5 Cost
Cost information is presented in the Cost Estimate Report for this
project.
1.2.2.6 Compliance with ARARs
Compliance with ARARs would be determined by negotiation with NJDEP
representatives.
1.2.2.7 Overall Protection
This alternative would be protective of human-health and the
environment.
1.2.2.8 State of New Jersey Acceptance
NJDEP Approval would be required for discharge of VOCs to air and
discharge of the treated effluent to surface waters.
1.2.2.9 Community Acceptance
Community acceptance will probably not be an issue for this action.
12
-------
RESPONSE TO EPA REGION II COMMENTS ON DRAFT RECORD OF DECISION (ROD)
Comment
p. 2-1 "These constituents are of Interest because of their
potential effect ..."
p. 2-2 The following comments refer to Table 2-1:
a) Which shallow wells were used to collect contaminant
concentration data? A map showing well locations
may be a good Idean. I assume, from looking at the
FS Table 1-3, that these wells are the ones marked
(s). This should be clarified in the ROD.
b) The range of concentration shown 1n Table 2-1 1s
incorrect. For example, in 1983, TCE was found
from groundwater samples at well #270094 to be as
high as 25,200 ppb. Freon-113 certainly has higher
than "trace" concentrations in well #270094.
c)
p. 3-1 a)
Why is the average TCE concentration for the 9
shallow wells in Table A-l of the FS (834.7 ppb)
differenct than the average shown 1n Table 2-1
of the draft ROD (854.3 ppb)?
Five "basic actions" are listed as Integral parts
of the remedial action alternatives initially
considered. Shouldn't pretreatment and a
combination of the listed actions be included
as well.
b) The last sentence states ".. employing a ground
water withdrawal system, a groundwater treatment
system, and an air stripper." Isn't an air stripper
part of the treatment system? The sentence should
state"., a groundwater treatment system which would
jcclude different combinations of the following
•Its: air stripper, off-gas filter, polishing
Tilter".etc.
Response
Corrected.
a) List of the nine shallow wells
added as note to Table 2-1. Figure and Table
from the FS addded to show well locations
and well data.
b) Table 2-1 reproofed. TCE concentration range
to read "ND-25,200". The 6241 ppb number, the
"average" concentration for the 1983-1985 well
No. 290094 data, was entered In error. The
1986 USGS report, "Groundwater Quality data for
Picatinny Arsenal, New Jersey, 1958-85", shows
Freon-113 concentration in well No. 270093 to
be ND for reading was 6 ppb (28 July 1981).
c) Table 2-1 of the FS Included data for 16
wells in the study area. Table 2-1 of the ROD
included only the nine shallow wells.
Groundwater pretreatment was a component of
several remedial action alternatives.
Combination of actions is not a basic action.
1) "air stripper" corrected to "air filter"
2) suggested rewrite of last sentence would be
inaccurate, since not all units are included
in each remedial action alternative.
-------
RESPONSE TO EPA REGION II COMMENTS ON DRAFT RECORD OF DECISION (ROD)
(continued)
Comment
Response
The advantages column for Alternatives 3C and 3D should
state "meets all ARARs for discharge to air and surface
water".
More details should be given to the discussion of
alternative 3C, especially since we know what the
rate of withdrawal will be as well as removal
efficiency targets. Tying these numbers into
specific ARARs would be helpful.
The 9 criteria have not sufficiently been addressed
for the proposed alternative, 3C. The criteria
Include:
Overall protectlveness of human health
and the environment.
Compliance with ARARs (with some detail)
Long-term effectiveness and performance
Reduction of toxlcity, mobility, and volume
Implementability
Cost
State acceptance
Community acceptance
The last paragraph should state
groundwater".
use of water from
2ral comments:
a) Maps should be included in the ROD to show site
locations, sampling locations, plume location,
source area, etc..
b) A flow diagram of the treatment train used in the
proposed alternative 3C would be helpful. Arrows
showing discharge should also show compliance with
surface water or air emission ARARs.
Clause added as suggested. ERCE Is awaiting
a statement from EPA and/or NJDEP as to what
requirements will be considered ARARs for this
Interim action.
Discussion expanded. Specific ARARs for this
interim action have not yet been provided.
A new Table 4-1 has been developed to provide
an abbreviated discussion of the nine criteria.
ERCE was not aware that the nine criteria were
statuatory requirements. The items discussed
were the five statuatory requirements described
in Appendix C (Documenting an Interim Action)
of EPA's "Guidance or Remedial Actions for
Contaminated Groundwater at Superfund sites",
OSWER Directive 9283.1-2, February 1989.
The document was provided for this project
by Ms. Anne DeCicco of NJDEP. New Appendix
A added with expanded discussion on
alternatives.
Corrected.
a) Maps added to ROD.
b) Flow diagram added.
-------
RESPONSE TO EPA REGION II COMMENTS ON DRAFT RECORD OF DECISION (ROD)
(continued)
Comment
c) The comparative analysis of alternatives presented
1n the FS (pages 4-7 throught 4-19) should also be
Included In the ROD. While Table 3-2 Is helpful,
alone, 1t Is not sufficient to explain the Army's
reasons for supporting a particular remedy.
Response
c) Comparative analysis table from FS added.
FS text added to ROD as New Appendix A.
-------
RESPONSE TO NJDEP COMMENTS ON DRAFT ROD FOR PICATINNY ARSENAL INTERIM REMEDIAL ACTION
Comment
1. Page 4-1, Section 4.2. Permits and Approvals
According to representative from DWR, Bureau of Industrial
Discharge Permits, the need for a surface water discharge
permit for the interim remedial action (IRA) is unresolved.
A NJDEP permit may be required even though EPA has indicated
that it could be waived (providing that permit requirements
are met).
2. Page 4-2, Section 4.5, Alternative Technologies and Permanent
Solutions
Change "alternative" to "Innovative" In section title and
discussion.
Page 5-2. Section 5.1.2, Public Health Effects
Clarification of 2nd sentence Is needed. ("... use of water
from the air ..."?)
Response
Noted.
Action deferred. The title was taken from
Appendix C (Documenting an Interim Action)
of EPA's "Guidance on Remedial Actions for
Contaminated Groundwater at Superfund Site.
This document was provided for project use
by Ms. Anne DeCicco of NJDEP. Please
clarify which guidance is to be used.
Sentence corrected.
-------
DIVISION MUNtSVlTtt
jESION REVIEW COMMENTS
fl
PROJECT
AMC Environmental - Bldg.
Interim Remedial Action,
24 CORPS Of ENGINEERS
DF |S-8, S:10 May 1989
SITE OEV A GEO TECH
ENVIH PHOT & UTIL
ARCHITECTURAL
STRUCTURAL
O MECHANICAL
O MFC TECHNOLOGY
O ELECTRICAL
D SAFETY
O ADV TECH
O ESTIMATING
O SYSTEMS ENQ
D VALUE ENG
O OTHER
REVIEW .Draff Rerord of .Derision.
DATE _10 Hav 1989
IYPE
DRAWING NO.'
OR REFERENCE
D INSTR & CONTROLS O SPECIFICATIONS
NAME K. llealy/bjr/5170
COMMENT
ACTION
Section
1.3, Para
2
Section
2.1
Table 2.1
Section
3.1, Para
1
In lines 7 and 8, change "part" to
"have."
•past" and "has" to
The decision to proceed with an IRA at this site was made
by Arsenal personnel and USATHAHA. The reference here to
USAGE is inaccurate. Additionally, in line 3, change
"the primary..." to "A potential...".
Correct the spelling of "naturally" in the title.
Additionally, on page 2-3, the average concentration of
zinc is listed as higher than the range of concentrations
found.
An attempt is made to present a general overview of basic
actions involved in all interim remedial action
alternatives; yet specific actions (e.g. withdrawal for
treatment by carbon absorption) are listed, implying that
all alternatives employed this treatment. This is not
the case. Reword items 2 through 4 as follows:
Item 2 Groundwater withdrawal for treatment either
directly, or following pre-treatment.
Item 3 Groundwater treatment by air-stripping,
carbon absorption, or spray irrigation.
Item 4 Groundwater discharge (following treatment)
to existing surface water courses, water
treatment facilities, the surrounding ground
area, or the existing sewage treatment
facilities.
Item 5 Delete.
ACTION CODES:
A — ACCEPTED/CONCUR
D — ACTION DEF.EflRED.
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Done.
A. Changed to USATHAMA, per USATHAMA.
Line 3 change made.
A. Corrected.
corrected.
A. Done.
average cone
-------
S. ARMY iMGINEfl DIVISION HUNTSVIIU
SIGN REVIEW COMMENTS
AMC Environmental - Bldg. 24
PROJECT Interim Remedial Action, DF 15-8. S;10 May 1989
CORPS DF ENGINEERS
p SITE DEV & GEO TECH
\4 ENVIH PHOT A UTIL
U ARCHITECTURAL
O STRUCTURAL
Q MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INSTR & CONTROLS
D SAFETY D SYSTEMS ENQ
D AOV TECH D VALUE ENQ
D ESTIMATING D OTHER
D SPECIFICATIONS
HEVIEWJ)raft_Recnrri. of Decision.
DATE 10 Hay 1989 ^
NAME K. Healy/bjr/5170 ;
IYPF
DRAWING NO.'
OR REFERENCE
COMMENT
ACTION
Section
3.1, Para
2
Table 3-1
Section
3.2
Section
4.0
Section
4.1, Para
2
Section
5.1.1.4,
Para 2
In the third sentence, change "treatment*
"pre-treatraent."
to
For the advantages of Alternative 3A, change
cost" to "reasonable cost."
'reassure
In the first sentence, verify that the decision to
implement the IRA Alternative 3C was made by USAGE.
Under item 3 of the primary considerations, change
"immplementability" to "implementability." Under item 7,
change "probability" to "possibility." Additionally, in
the final sentence, change "will responsible" to "with
responsible," and verify that USAGE was responsible for
the subject determination.
In line 4, change "hydraulicly" to "hydraulically." In
the last sentence, verify that "care has been taken...
for effective waste management," is true.
In line 6, change "this remedial action" to
remedial action."
'this interim
Second sentence, clarify that "the expended GAC will be
regenerated for reuse" since it was previously stated
that the design for this IRA does not assume on-site
regeneration and reuse. Finally, in line 6, change "that
background" to "than background."
ACTION CODES:
A — ACCEPTED/CONCUR
O — ACTION DEFERRED
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Done.
A. Done.
1) A. Changed to Arsenal Commander.
2) A. Spelling corrected.
3) A. Change made.
4) A. Corrected.
5) A. "USACE" replaced by Arsenal
Commander.
1) A. Spelling corrected.
2) A. True statement (GAC air filter,
GAC polishing filter;
identification of waste streams)
A. Change made.
1) A. Wording changed to reflect
USACE decision (4 May meeting)
to require return to supplier
for management.
2) A. Corrected.
ORM 7
-------
I.S. ARMY inGINEER DIVISION HUNTSVILIC
1ESIGN REVIEW COMMENTS
AHC Environmental - Bldg.
PROJECT Interim Remedial Action,
24 CORPS OF
DF 15-8, 5:10 May 1989
XX SITE OEV & GEO TECH D MECHANICAL ° SAFETY O SYSTEMS ENG
tl ENVIR ROOT & UTIL. D MFC TECHNOLOGY O AOV TECH Q VALUE ENG
U ARCHITECTURAL D ELECTRICAL ° ESTIMATING Q OTHER
n STRUCTURAL O INSTR A CONTROLS O SPECIFICATIONS
RtvlEW. Draft Record of Decision
DAII 10 Hay 1989 _
1YPI
NAME K. Healy/bjr/5170
No.
OH REFERENCE
COMMENT
ACTION
Section
5.1.2,
Line 2
Section
5.2
Section
1.3.2
Page 1-10,
Para 1
Section
2.1, Line
4
Section
2.3, Para
3
Table 3.1
General
Change "from the air" to "from the area."
In line 1, define the "this" that was "selected."
Draft Environmental Assessment
The discussion presented is not in chronological order.
The paragraphs should be re-edited. In paragraph 2, line
7, remove "and nuclear" as per discussions at Picatinny
Arsenal meeting on 4 Hay.
In line 6, correct the spelling of volatilization. In
line 7, change "is of minor importance" to "is minor."
Change "the primary source" to "A potential source."
Verify that "(Bound Brook)" should be "(Green Pond
Brook)".
Under "Annual Volume" of "Treated Groundwater," change
"ing" to "million gallons" to avoid confusion.
Final Engineering Feasibility Study
Prior comments to the draft have been satisfactorily
addressed. No.additional comments are required.
ACTION CODES: W — WITHDRAWN
A — ACCEPTED/CONCUR N — NON-CONCUR
D — ACTION DEFERRED VE — VE POTENTIAL/VEK AI I AUriED
A. Corrected.
A. "Selected" deleted; replaced with
Interim remedial action alternative.
1) A. Paragraphs reedlted.
2) A. "Conventional and Nuclear" removed
per 4 May meeting direction.
1) A. Corrected.
2) A. Done.
A. Changed.
A. Corrected (Author had a flash back
to prior project).
A. Done.
.A. Noted.
-------
U.S. AR/,n tNGINEER DIVISION HUNTSVIUE
DESIGN REVIEW COMMENTS
PROJECT
No. PA-024, Interim Remedial
Action, Picatinny Arsenal, 15-8, S: 5 Hay
CORPS Of ENGINEERS
U SITE DEV A GEO TECH O MECHANICAL
XXENV/IR PHOT & UTIL O MFG TECHNOLOGY
U ARCHITECTURAL Q ELECTRICAL
n STRUCTURAL rj INSTR & CONTROLS
O SAFETY O SYSTEMS ENG
O ADV TECH O VALUE ENG
D ESTIMATING Q OTHER
O SPECIFICATIONS
REVIEW.
DATE .
NAME _
Draft ROD & EA. Final Feas. Rpt
5 Hay 1989 ,i •
Gary
ITEM
DRAWING NO
OH REFERENCE
COMMENT
ACTION
2
3
4
5
6
Table 2-1
Par
5.1.1.2
Par 5.2
Table 1-1
Par 3.1.2
Par 3.1.3
General
Draft ROD "
The contaminant levels in this table are different from
those listed in Tables 1-2 and 1-3 of the draft
specifications and work statements report. Explain.
Clearly state that the treatment system will remove VOCs
to negligible levels before discharge to the brook.
A word is missing in the second sentence.
Draft EA
See Item 1 ;
See Item 2
State that air quality impact would be negligible with or
without the GAC air filter.
Draft ROD and EA
Both reports are directed toward use of alternative 3C.
State whether the ROD and EA would change if 3G is
selected later. State what those changes would be and
what delays would occur in the cleanup process if, after
6 months, we move to 3G. System performance for this
"off-the-shelf" technology should be well defined.
State whether levels below 5 ppb for VOCs are always
attainable. Define "system performance. If the State
accepts 3c, it will be on the definite performance of the
3C system. No doubt should be cast on its ability to
ACTION COOES:
A — ACCEPTED/CONCUR
D — ACTION DEFERRED
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Tables 1-2 and 1-3 of draft ROD
reflect unconflned aquifer wells only.
Change will be made to Section C
document.
A. Wording changed.
A. "Selected" deleted; "Interim remedial
action alternative" added.
A. As noted above.
A. As above.
A. Done.
ERCE has been informed that the
Arsenal Commander has ruled out
possible use of treated water In
drinking water system; hence,
discussion of 3G in the ROD would
lead to confusion.
Comments on system performance
addressed. Properly maintained and
operated% there should be no
problem.
-------
U S. ARMY tNGINEER DIVISION HUNTSVIIU
DESIGN REVIEW COMMENTS
PROIECT
No. PA-024, Interim Remedial
Action, Picatinny Arsenal, 15-8, S: 5 Nay
CORPS Of ENGINEERS
SITE OEV A GEO TECH O MECHANICAL
O SAFETY
O SYSTEMS ENG
fDENV/IR PHOT & UTIL . O
U ARCHITECTURAL a
D STRUCTURAL Q
MFG TECHNOLOGY
ELECTRICAL
INSTR A CONTROLS
O AOV TECH O
Q ESTIMATING D
0 SPECIFICATIONS
VALUE ENG
OTHER
REVIEW.
DATE _
NAME _
Draft ROD & EA, Final Feas. Rpt
5 May 1989
1YPF
Gary Holden
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
(Cont'd)
General
General
clean groundvater to specified levels. Modify report
based on the above. Do not see the reasoning for holding
on to 3G.
It is the responsibility of the AE to thoroughly
proofread the draft.
Final Feasibility Study
No comments.
Reason for holding on to 3G: direction
provided to ERCE in 13 April review
meeting. :
A. Agreed.
Noted.
ACTION CODES:
A — ACCEPTED/CONCUR
D —ACTION DEFERRED
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VW ATTACHED
-------
Comment
RESPONSE TO ARDEC COMMENTS OF DRAFT RECORD OF DECISION
Response
Corrected.
p. 1-2 3rd paragraph, 5th line. Armaments should not be
plural.
p. 1-2 3rd paragraph, 7th line, Plcatlnny does not produce
nuclear munitions, but may develop certain components
that go Into nuclear munitions.
p. 1-2 3rd paragraph, 7th line, the word past should be
substituted for the word part.
p. 2-1 Top of page, to prevent contaminated groundwater from
entering Green Pond Brook should also be stated as a
remedial objective.
p. 2-2 Table 2-1, what are the nine shallow wells being used
for this table?
"Conventional and Nuclear" deleted, per 4 May
meeting discussion.
Corrected.
ERCE is unaware that the Brook 1s In need of
remediation. A statement was added to indicate
that an objective 1s the prevention or
minimization of water quality deterioration.
Table modified to show well Information.
added to Table 2-1 to list well numbers.
Note
p. 2-2 The listed range for Trichloroethylene does not seen
correct, well 9B (0270094) during the stated time
frame 1983-85, has quite a few readings over 6241 ppb.
p. 2-3 Table 2-1, The Arsenal favors 3C not 3D.
p. 3-3 Table 3-1, No. Title/Description Description of 6A is
the same as 3G.
p. 2-1 , 1st paragraph last sentence. An additional source
could be Building 24 itself, or the closed waste oil
tank at Building 31.
p. 5-2 The pretreatment sludge will have to be handled as
a hazardous waste.
Corrected. The 6241 ppb number, the "average"
reading for well 270094 from 1982-1985, was
erroneously listed.
Comments not understood. Table 2-1 does not
mention alternatives.
Alternative 6A description corrected.
Please provide 1) information on Building 31
waste oil tank, and 2) information on how
Building 24 itself could be a source. This
Information was not previously provided.
Handling of the pretreatment sludge should be
determined based on waste characteristics.
Currently, pretreatment sludge from the
Arsenal's drinking water plant is not handled
-------
RESPONSE TO ARDEC COMMENTS OF DRAFT RECORD OF DECISION
(continued)
Comment
p. 5-2 2nd to last sentence, missing stripper after air.
Response
as a hazardous waste, although the water source
is contaminated with VOCs. NJDEP or EPA has
not yet provided specific guidance on this
issue.
Corrected.
-------
PICATINNY ARSENAL
RESPONSIVENESS SUMMARY
A. OVERVIEW
The U.S. Army has elected to pump and treat the contaminated groundwater
plume emanating from the Building 24 area. The contaminant of concern,
trichloroethylene (TCE), results from past plating operations in this area.
TCE, a volatile organic compound which is easily removed by exposure to air, is
a decreasing agent commonly used in the metal working industry to remove
residual oils and grease prior to plating. It is also used in the dry cleaning
industry and as a solvent in chemical and pharmaceutical manufacturing.
The chosen alternative consists of intercepting the plume through five (5)
withdrawal wells to be installed between Building 24 and Green Pond Brook. The
contaminated water will pass through a three stage process where it will be
treated for removal of heavy metals, passed through an air stripper to remove
the volatile constituents (outfitted with a granulated activated carbon (GAC)
air filter for off-gases), and finally through two -(2) GAC units to remove any
residual volatile contaminants prior to release to Green Pond Brook.
Based on the public response during the comment period, opposition to the
chosen alternative will not be of concern.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
In 1985, Picatinny Arsenal held a detailed press conference to announce
that significant levels of volatile organics and heavy metals had been found
near Building 24 at Picatinny Arsenal and that cleanup plans would be prepared
later in the year. This announcement generated little public and community
interest at the time.
Community interest in the contaminated site began to increase in 1987,
particularly among on-post residents and employees, when a local newspaper, the
"Daily Record", published an in-depth series of articles about the
installation's RCRA and CERCLA problems. The series focused attention on this
and other sites as well as the possibility that the contamination could migrate
beyond the installation's boundaries. In spite of assurances from Army and
U.S. Geological Survey officials that the contamination was confined to the
Arsenal, community officials from the six municipalities surrounding Picatinny
expressed concern and interest in being given more information about the site.
In May 1988, a survey of the community was conducted by the U.S. Army Toxic
and Hazardous Material Agency (USATHAMA). The purpose of the community
interviews was to identify attitudes and concerns in regard to the
environmental studies at Picatinny Arsenal. The interviews included on-post
residents and employees as well as installation neighbors, local officials and
public health administrators. The main concern involved the quality of
drinking water. All questions and concerns were addressed at the time of the
interview or immediately after. An overview of the concerns is presented below.
-------
Ql: Picatinny Arsenal residents expressed concern and in some cases
believed that the installation's drinking water supply is contaminated.
Al: To meet stricter state standards and to alleviate any possibility of
future contamination of the water supply, Picatinny built a new water
treatment plant that removes volatile organics and heavy metals.
Additionally, in the early 1980's, the installation began holding
quarterly town meetings to answer questions and complaints and provide
bi-weekly water sampling results to residents. These meetings continue
today.
Q2: Municipal officials and representatives expressed concern that
contamination was migrating beyond the installation boundary.
A2: In July 1989, Picatinny provided water sampling results taken at the
boundary to municipal health officials. The results are currently
being confirmed. The arsenal also tested 13 off-post residential wells
in June 1988 and 1989 and provided the results to the municipal health
official in which the wells are located. No contamination was found in
either sampling event. Additionally, the site was discussed in-depth
by the Technical Review Committee in April 1989.
Comments received at the September 25, 1989 meeting are included as an addendum.
C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
The proposed remedial action plan (PRAP) was published in several
newspapers on July 12, 1989. The public comment period expired on August 14,
1989; comments are addressed below.
Ql: What is the contaminant in Green Pond Brook?
Al: Trichloroethylene (TCE) is the contaminant of concern in Green Pond
Brook. Although usually not detected during sampling, investigations
have occasionally detected TCE below the National primary drinking
water standard, maximum contaminant level (MCL) of 5 ppb, generally
between 1 and 3 ppb.
Q2: Can it get into Mt. Hope Pond?
A2: No, because Mt. Hope Pond is about 300 feet higher in elevation than
Green Pond Brook and Mt. Hope Pond is not in the same aquifer or
watershed. Groundwater flow is not in the direction of Mt. Hope Pond,
rather it discharges towards Green Pond Brook which is approximately 2
miles from Mt. Hope Pond.
-------
Q3: How will it affect the mine shafts below Mt. Hope quarry?
A3: No effect is possible in the mine shafts because the Pre-Cambrian rock
in which the shafts occur is not connected to the glacial aquifer in
which the contamination on the Arsenal is found. The mine shafts are
approximately 3 miles uphill from the discharge area.
Q4: Excerpt from letter dated July 25, 1989: "Whereas "alternatives four
through six" are stated as being expected to meet all the discharge
limitations set by EPA and DEP, the fact that Green Pond Brook is a
source of potable water leads to concern should the treated water be
discharged into Green Pond Brook.
We believe that a more prudent arrangement would be to implement a
variation of "alternative five" but utilizing the treated water as
"gray water", of which considerable quantities are used in your
facilities, instead of utilizing the treated water as a raw water
source for the drinking water treatment system."
A4: The treated water being discharged into Green Pond Brook will have
passed through three stages: a filtration system to remove metals, an
air stripper to remove the TCE and other volatile organic compounds
(VOCs) and two activated carbon filters to remove any residual VOCs
before being discharged into the brook. The discharge water will be
of higher quality than what is presently flowing through the Brook.
Q5: GAC vendors should be informed of RCRA hazardous waste regulations
that must be followed. Picatinny Arsenal should specify how the
sludge and stripper wastes are to be stored. If storage will be in
containers, a short description of the storage area and estimated
frequency of waste removal (and other information relating to waste
handling) should be included.
A5: Sludge and stripper waste will be stored at the site at either a
90-day RCRA (Resource Conservation and Recovery Act) storage area or a
State approved interim storage area. All waste shall be removed from
the 90-day storage area as soon as possible and in compliance with
ARDEC 420-47 (Hazardous Waste Management Plan). This Plan is in
conformance with all RCRA hazardous waste regulations. All waste will
be disposed of in accordance with RCRA hazardous waste regulations.
Q6: A 500 year floodplain and wetlands as defined by FEMA exist in the
area at or near the proposed ground water extraction and treatment
system. Pursuant to Executive Order 11990 (OSWER Directive #9280.0-2)
and Executive Order 11988 (OSWER Directive #9280.0-2) a wetlands and
floodplains assessment (which can be combined) must be conducted to
evaluate the effects of the proposed remedial action. The wetlands
issue may not be pertinent if the extraction and treatment system will
be located at the golf course. The purpose of the floodplains
assessment is essentially to make Picatinny aware that precautions
should be made if construction of a treatment system will be in an
area prone to flooding. These issues may be addressed -during the
Record of Decision stage or the Remedial Design/Remedial Action, stage
(RD/RA).
-------
RESPONSE TO EPA REGION II COMMENTS ON DRAFT RECORD OF DECISION (ROD)
(continued)
Comment
c) The comparative analysis of alternatives presented
1n the FS (pages 4-7 throught 4-19) should also be
Included In the ROD. While Table 3-2 Is helpful,
alone. It Is not sufficient to explain the Army's
reasons for supporting a particular remedy.
Response
c) Comparative analysis table from FS added.
FS text added to ROD as New Appendix A.
-------
RESPONSE TO NJDEP COMMENTS ON DRAFT ROD FOR PICATINNY ARSENAL INTERIM REMEDIAL ACTION
Comment
Page 4-1, Section 4.2, Permits and Approvals
According to representative from DWR, Bureau of Industrial
Discharge Permits, the need for a surface water discharge
permit for the interim remedial action (IRA) is unresolved.
A NJDEP permit may be required even though EPA has indicated
that it could be waived (providing that permit requirements
are met).
Page 4-2. Section 4.5, Alternative Technologies and Permanent
Solutions"
Change "alternative" to "Innovative" 1n section title and
discussion.
Page 5-2. Section 5.1.2, Public Health Effects
Clarification of 2nd sentence Is needed. ("... use of water
from the air ..."?)
Response
Noted.
Action deferred. The title was taken from
Appendix C (Documenting an Interim Action)
of EPA's "Guidance on Remedial Actions for
Contaminated Groundwater at Superfund Site.
This document was provided for project use
by Ms. Anne DeCicco of NJDEP. Please
clarify which guidance is to be used.
Sentence corrected.
-------
U.S. ARMY iNGINEER DIVISION HUNTSVIUE
DESIGN REVIEW COMMENTS
AMC Environmental - Bldg.
PROJECT Interim Remedial Action,
24 CORPS 01 ENGINEERS
DF 15-8. S;10 May 1989
J\ SITE OEV & GEO TECH
1l ENVIR PHOT & UTIL
O ARCHITECTURAL
O STRUCTURAL
O MECHANICAL
Q MFG TECHNOLOGY
O ELECTRICAL
D INSTR & CONTROLS
D SAFETY D SYSTEMS ENO
O ADV TECH D VALUE ENG
O ESTIMATING O OTHER
O SPECIFICATIONS
Rernrri nf
DATE 10 May 1989
IYPE
NAME K. Healy/bjr/5170
DHAwNG MO
OR REFERENCE
COMMENT
T
ACTION
Section
1.3, Para
2
Section
2.1
Table 2.1
Section
3.1, Para
1
In lines 7 and 8, change "part" to
"have."
•past" and "has" to
The decision to proceed with an IRA at this site was made
by Arsenal personnel and USATHAHA. The reference here to
USAGE is inaccurate. Additionally, in line 3, change
"the primary..." to "A potential...".
Correct the spelling of "naturally" in the title.
Additionally, on page 2-3, the average concentration of
zinc is listed as higher than the range of concentrations
found.
An attempt is made to present a general overview of basic
actions involved in all interim remedial action
alternatives; yet specific actions (e.g. withdrawal for
treatment by carbon absorption) are listed, implying that
all alternatives employed this treatment. This is not
the case. Reword items 2 through 4 as follows:
Item 2 Groundwater withdrawal for treatment either
directly, or following pre-treatment.
Item 3 Groundwater treatment by air-stripping,
carbon absorption, or spray irrigation.
Item 4 Groundwater discharge (following treatment)
to existing surface water courses, water
treatment facilities, the surrounding ground
area, or the existing sewage treatment
facilities.
Item 5 Delete.
ACTION CODES:
A — ACCEPTED/CONCUR
D — ACTION DEf ERBEB
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Done.
A. Changed to USATHAMA, per USATHAMA.
Line 3 change made.
A. Corrected. Zinc average cone.
corrected.
A. Done.
-------
S. ARM* iNGlWR DIVISION HUNTSVILLC
DESIGN REVIEW COMMENTS
AHC Environmental - Bldg. 24
PROJECT ^Interim Remedial Action, DF J5-8, S;10 Hay 1989
CORPS Of ENGINEERS
IT SITE DEV A GEO TECH
0* ENVIR PROT A UTIL
U ARCHITECTURAL
n STRUCTURAL
O MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
Q INSTR A CONTROLS
O SAFETY D SYSTEMS ENQ
O AOV TECH O VALUE ENO
O ESTIMATING D OTHER
D SPECIFICATIONS
RtviEwjr.aft-RRcnrd. of-Decision.
DATE 10 Hay 1989
NAME K. Healy/bjr/5170
IVPF
OH REFERENCE
COMMENT
ACTION
Section
3.1, Para
2
Table 3-1
Section
3.2
Section
4.0
Section
4.1, Para
2
Section
5.1.1.4,
Para 2
In the third sentence, change "treatment" to
"pre-treatment."
For the advantages of Alternative 3A, change "reassure
cost" to "reasonable cost."
In the first sentence, verify that the decision to
implement the IRA Alternative 3C was made by USACE.
Under item 3 of the primary considerations, change
"immplementability" to "implementability." Under item 7,
change "probability" to "possibility." Additionally, in
the final sentence, change "will responsible" to "with
responsible," and verify that USACE was responsible for
the subject determination.
In line 4, change "hydraulicly" to "hydraulically." In
the last sentence, verify that "care has been taken...
for effective waste management," is true.
In line 6, change "this remedial action" to "this interim
remedial action."
Second sentence, clarify that "the expended GAG will be
regenerated for reuse" since it was previously stated
that the design for this IRA does not assume on-site
regeneration and reuse. Finally, in line 6, change "that
background" to "than background."
ACTION CODES.
A — ACCEPTED/CONCUR
D — ACTION DEFERRED
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Done.
A. Done.
1) A. Changed to Arsenal Commander.
2) A. Spelling corrected.
3) A. Change made.
4) A. Corrected.
5) A. "USACE" replaced by Arsenal
Commander.
1) A. Spelling corrected.
2) A. True statement (GAC air filter,
GAC polishing filter;
identification of waste streams)
A. ChaRye made.
1) A. Wording changed to reflect
USACE decision (4 May meeting)
to require return to supplier
for management.
2) A. Corrected.
FORM 1
-------
i.S. ARMY inGINKR DIVISION IIUHTSVILU
lESIGN REVIEW COMMENTS
AHC Environmental - Bldg.
PROJECT Interim Remedial Action,
24 CORPS Of trtGIN[[RS
DP 15-8, 5:10 May 1989
XX SITE OEV 4 GEO TECH Q MECHANICAL ° SAFETY D SYSTEMS ENQ
t) ENVIR PROT 4 UTIL D MFG TECHNOLOGY ° ADV TECH ° VALUE ENG
U ARCHITECTURAL D ELECTRICAL D ESTIMATING D OTHER
n STRUCTURAL D INSTR & CONTROLS O SPECIFICATIONS
REVIEW Draft Record of Degision.
DATE 10 Hay 1989 [
IYPI
NAM£ K. Healy/bjr/5170
NO.
OH REFERENCE
COMMENT
ACTION
Section
5.1.2,
Line 2
Section
5.2
Section
1.3.2
Page 1-10,
Para 1
Section
2.1, Line
4
Section
2.3, Para
3
Table 3.1
General
Change "from the air" to "from the area."
In line 1, define the "this" that was "selected."
Draft Environmental Assessment
The discussion presented is not in chronological order.
The paragraphs should be re-edited. In paragraph 2, line
7, remove "and nuclear" as per discussions at Picatinny
Arsenal meeting on 4 May.
In line 6, correct the spelling of volatilization. In
line 7, change "is of minor importance" to "is minor."
Change "the primary source" to "A potential source."
Verify that "(Bound Brook)" should be "(Green Pond
Brook)".
Under "Annual Volume" of "Treated Groundwater," change
"ing" to "million gallons" to avoid confusion.
Final Engineering Feasibility Study
Prior comments to the draft have been satisfactorily
addressed. No.additional comments are required.
ACTION COOES: W — WITHDRAWN
A — ACCEPTED/CONCUR N — NON-CONCUR
D — ACTION DEFERflED VE — VE POTENTIAL/VEP ATTACHED
A. Corrected.
A. "Selected" deleted; replaced with
Interim remedial action alternative.
1) A. Paragraphs reedlted.
2) A. "Conventional and Nuclear" removed.
per 4 May meeting direction.
1) A. Corrected.
2) A. Done.
A. Changed.
A. Corrected (Author had a flash back
to prior project).
A. Done.
A. Noted.
-------
.S. AfiMN) iNGINEER DIVISION HUNTSVILLE
ESIGN REVIEW COMMENTS
PROJECT
No. PA-024, Interim Remedial
Action, Picatinny Arsenal, 15-8, S: 5 May
CORPS OF ENGINEERS
P SITE DEV & GEO TECH O MECHANICAL ° SAFETY Q SYSTEMS ENQ
XKENVIH PHOT & UTIU O MFC TECHNOLOGY O ADV TECH O VALUE ENQ
U ARCHITECTURAL Q ELECTRICAL D ESTIMATING D OTHER
n STRUCTURAL Q INSTR & CONTROLS Q SPECIFICATIONS
REVIEW.
DATE .
NAME .
Draft ROD & EA. Final Feas. Rpt
5 May 1989 // /
Gary Holden $v)r MftW
EM
DRAMNG NO.
OR REFERENCE
COMMENT
ACTION
Table 2-1
Par
5.1.1.2
Par 5.2
Table 1-1
Par 3.1.2
Par 3.1.3
General
Draft ROD "
The contaminant levels in this table are different from
those listed in Tables 1-2 and 1-3 of the draft
specifications and work statements report. Explain.
Clearly state that the treatment system will remove VOCs
to negligible levels before discharge to the brook.
A word is missing in the second sentence.
Draft EA
See Item 1 :
See Item 2
State that air quality impact would be negligible with or
without the GAC air filter.
Draft ROD and EA
Both reports are directed toward use of alternative 3C.
State whether the ROD and EA would change if 3G is
selected later. State what those changes would be and
what delays would occur in the cleanup process if, after
6 months, we move to 3G. System performance for this
"off-the-shelf" technology should be well defined.
State whether levels below 5 ppb for VOCs are always
attainable. Define "system performance. If the State
accepts 3c, it will be on the definite performance of the
3C system. No doubt should be cast on its ability to
ACTION CODES:
A — ACCEPTED/CONCUR
D — ACTION DEFERRED
W — WITHDRAWN
N — NON-CONCUR
VE — VE POTENTIAL/VEP ATTACHED
A. Tables 1-2 and 1-3 of draft ROD
reflect unconfined aquifer wells only.
Change will be made to Section C
document.
A. Wording changed.
A. "Selected" deleted; "Interim remedial
action alternative" added.
A. As noted above.
A. As above.
A. Done.
D. ERCE has been informed that the
Arsenal Commander has ruled out
possible use of treated water in
drinking water system; hence,
discussion of 3G in the ROD would
lead to confusion.
A. Comments on system performance
addressed. Properly maintained and
operatedt there should be no
problem.
FORM 7
-------
U.S. ARMY tNGINEER DIVISION HUNTSVILU
DESIGN REVIEW COMMENTS
PROJECT
No. PA-024, Interim Remedial
Action, Picatinny Arsenal, 15-8, S: 5 Hay
CORPS OF ENGINEERS
P SITE OEV & GEO TECH D MECHANICAL
QCJENVIR PROT & UTIU
U ARCHITECTURAL
O STRUCTURAL
D MFC TECHNOLOGY
O ELECTRICAL
D INSTR & CONTROLS
O SAFETY O SYSTEMS ENG
D AOV TECH O VALUE ENG
O ESTIMATING Q OTHER
O SPECIFICATIONS
REVIEW.
DATE _
NAME _
Draft ROD & EA, Final Teas. Rpt
5 Hay 1989 IYP~
Gary Holden
ITEM
DRAWING NOT^
OR REFERENCE
COMMENT
ACTION
(Cont'd)
General
General
clean groundwater to
based on the above.
on to 3G.
specified levels. Modify report
Do not see the reasoning for holding
It is the responsibility of the AE to thoroughly
proofread the draft.
Final Feasibility Study
No comments.
Reason for holding on to 3G: direction
provided to ERCE in 13 April review
meeting. :
A. Agreed.
Noted.
ACTION COOES: W — WITHDRAWN
A — ACCEPTED/CONCUR N — NON-CONCUR
D — ACTION. DEFERRED VE — VE POTENTIAL/VETATTACHED
-------
Comment
RESPONSE TO ARDEC COMMENTS OF DRAFT RECORD OF DECISION
Response
Corrected.
p. 1-2 3rd paragraph, 5th line. Armaments should not be
plural.
p. 1-2 3rd paragraph, 7th line, Plcatlnny does not produce
nuclear munitions, but may develop certain components
that go Into nuclear munitions.
p. 1-2 3rd paragraph, 7th line, the word past should be
substituted for the word part.
p. 2-1 Top of page, to prevent contaminated groundwater from
entering Green Pond Brook should also be stated as a
remedial objective.
p. 2-2 Table 2-1, what are the nine shallow wells being used
for this table?
"Conventional and Nuclear" deleted, per 4 May
meeting discussion.
Corrected.
ERCE is unaware that the Brook 1s 1n need of
remediation. A statement was added to Indicate
that an objective 1s the prevention or
minimization of water quality deterioration.
Table modified to show well Information.
added to Table 2-1 to list well numbers.
Note
p. 2-2 The listed range for Trichloroethylene does not seen
correct, well 9B (#270094) during the stated time
frame 1983-85, has quite a few readings over 6241 ppb.
p. 2-3 Table 2-1, The Arsenal favors 3C not 3D.
p. 3-3 Table 3-1, No. Title/Description Description of 6A 1s
the same as 3G.
p. 2-1 , 1st paragraph last sentence. An additional source
could be Building 24 itself, or the closed waste oil
tank at Building 31.
p. 5-2 The pretreatment sludge will have to be handled as
a hazardous waste.
Corrected. The 6241 .ppb number, the "average"
reading for well 270094 from 1982-1985, was
erroneously listed.
Comments not understood.
mention alternatives.
Table 2-1 does not
Alternative 6A description corrected.
Please provide 1) information on Building 31
waste oil tank, and 2) information on how
Building 24 itself could be a source. This
Information was not previously provided.
Handling of the pretreatment sludge should be
determined based on waste characteristics.
Currently, pretreatment sludge from the
Arsenal's drinking water plant 1s not handled
-------
RESPONSE TO ARDEC COMMENTS OF DRAFT RECORD OF DECISION
(continued)
Comment
5-2 2nd to last sentence, missing stripper after air.
Response
as a hazardous waste, although the water source
is contaminated with VOCs. NJDEP or EPA has
not yet provided specific guidance on this
issue.
Corrected.
-------
PICATINNY ARSENAL
RESPONSIVENESS SUMMARY
A. OVERVIEW
The U.S. Army has elected to pump and treat the contaminated groundwater
plume emanating from the Building 24 area. The contaminant of concern,
trichloroethylene (TCE), results from past plating operations in this area.
TCE, a volatile organic compound which is easily removed by exposure to air, is
a degreasing agent commonly used in the metal working industry to remove
residual oils and grease prior to plating. It is also used in the dry cleaning
industry and as a solvent in chemical and pharmaceutical manufacturing.
The chosen alternative consists of intercepting the plume through five (5)
withdrawal wells to be installed between Building 24 and Green Pond Brook. The
contaminated water will pass through a three stage process where it will be
treated for removal of heavy metals, passed through an air stripper to remove
the volatile constituents (outfitted with a granulated activated carbon (GAC)
air filter for off-gases), and finally through two -(2) GAC units to remove any
residual volatile contaminants prior to release to Green Pond Brook.
Based on the public response during the comment period, opposition to the
chosen alternative will not be of concern.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
In 1985, Picatinny Arsenal held a detailed press conference to announce
that significant levels of volatile organics and heavy metals had been found
near Building 24 at Picatinny Arsenal and that cleanup plans would be prepared
later in the year. This announcement generated little public and community
interest at the time.
Community interest in the contaminated site began to increase in 1987,
particularly among on-post residents and employees, when a local newspaper, the
"Daily Record", published an in-depth series of articles about the
installation's RCRA and CERCLA problems. The series focused attention on this
and other sites as well as the possibility that the contamination could migrate
beyond the installation's boundaries. In spite of assurances from Army and
U.S. Geological Survey officials that the contamination was confined to the
Arsenal, community officials from the six municipalities surrounding Picatinny
expressed concern and interest in being given more information about the site.
In May 1988, a survey of the community was conducted by the U.S. Army Toxic
and Hazardous Material Agency (USATHAMA). The purpose of the community
interviews was to identify attitudes and concerns in regard to the
environmental studies at Picatinny Arsenal. The interviews included on-post
residents and employees as well as installation neighbors, local officials and
public health administrators. The main concern involved the quality of
drinking water. All questions and concerns were addressed at the time of the
Interview or immediately after. An overview of the concerns is presented below.
-------
Ql: Picatinny Arsenal residents expressed concern and in some cases
believed that the installation's drinking water supply is contaminated.
Al: To meet stricter state standards and to alleviate any possibility of
future contamination of the water supply, Picatinny built a new water
treatment plant that removes volatile organics and heavy metals.
Additionally, in the early 1980's, the installation began holding
quarterly town meetings to answer questions and complaints and provide
bi-weekly water sampling results to residents. These meetings continue
today.
Q2: Municipal officials and representatives expressed concern that
cotitamination was migrating beyond the installation boundary.
A2: In July 1989, Picatinny provided water sampling results taken at the
boundary to municipal health officials. The results are currently
being confirmed. The arsenal also tested 13 off-post residential wells
in June 1988 and 1989 and provided the results to the municipal health
official in which the wells are located. No contamination was found in
either sampling event. Additionally, the site was discussed in-depth
by the Technical Review Committee in April 1989.
Comments received at the September 25, 1989 meeting are included as an addendum.
C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
The proposed remedial action plan (PRAP) was published in several
newspapers on July 12, 1989. The public comment period expired on August 14,
1989; comments are addressed below.
Ql: What is the contaminant in Green Pond Brook?
Al: Trichloroethylene (TCE) is the contaminant of concern in Green Pond
Brook. Although usually not detected during sampling, investigations
have occasionally detected TCE below the National primary drinking
water standard, maximum contaminant level (MCL) of 5 ppb, generally
between 1 and 3 ppb.
Q2: Can it get into Mt. Hope Pond?
A2: No, because Mt. Hope Pond is about 300 feet higher in elevation than
Green Pond Brook and Mt. Hope Pond is not in the same aquifer or
watershed. Groundwater flow is not in the direction of Mt. Hope Pond,
rather it discharges towards Green Pond Brook which is approximately 2
miles from Mt. Hope Pond.
-------
Q3: How will it affect the mine shafts below Mt. Hope quarry?
A3: No effect is possible in the mine shafts because the Pre-Cambrian rock
in which the shafts occur is not connected to the glacial aquifer in
which the contamination on the Arsenal is found. The mine shafts are
approximately 3 miles uphill from the discharge area.
Q4: Excerpt from letter dated July 25, 1989: "Whereas "alternatives four
through six" are stated as being expected to meet all the discharge
limitations set by EPA and DEP, the fact that Green Pond Brook is a
source of potable water leads to concern should the treated water be
discharged into Green Pond Brook.
We believe that a more prudent arrangement would be to implement a
variation of "alternative five" but utilizing the treated water as
"gray water", of which considerable quantities are used in your
facilities, instead of utilizing the treated water as a raw water
source for the drinking water treatment system."
A4: The treated water being discharged into Green Pond Brook will have
passed through three stages: a filtration system to remove metals, an
air stripper to remove the TCE and other volatile organic compounds
(VOCs) and two activated carbon filters to remove any residual VOCs
before being discharged into the brook. The discharge water will be
of higher quality than what is presently flowing through the Brook.
Q5: GAC vendors should be informed of RCRA hazardous waste regulations
that must be followed. Picatinny Arsenal should specify how the
sludge and stripper wastes are to be stored. If storage will be in
containers, a short description of the storage area and estimated
frequency of waste removal (and other information relating to waste
handling) should be included.
A5: Sludge and stripper waste will be stored at the site at either a
90-day RCRA (Resource Conservation and Recovery Act) storage area or a
State approved interim storage area. All waste shall be removed from
the 90-day storage area as soon as possible and in compliance with
ARDEC 420-47 (Hazardous Waste Management Plan). This Plan is in
conformance with all RCRA hazardous waste regulations. All waste will
be disposed of in accordance with RCRA hazardous waste regulations.
Q6: A 500 year floodplain and wetlands as defined by FEMA exist in the
area at or near the proposed ground water extraction and treatment
system. Pursuant to Executive Order 11990 (OSWER Directive #9280.0-2)
and Executive Order 11988 (OSWER Directive #9280.0-2) a wetlands and
floodplains assessment (which can be combined) must be conducted to
evaluate the effects of the proposed remedial action. The wetlands
issue may not be pertinent if the extraction and treatment system will
be located at the golf course. The purpose of the floodplains
assessment is essentially to make Picatinny aware that precautions
should be made if construction of a treatment system will be in an
area prone to flooding. These issues may be addressed -during the
Record of Decision stage or the Remedial Design/Remedial Action, stage
(RD/RA).
-------
A6: The potential for affecting wetlands has been considered. However,
the pertinence of such a concern is questionable. The positioning of
the treatment system at the golf course will, as suggested, preclude
any effects on distant wetlands.
Potential flooding has been addressed although application of the 500
year floodplain criteria appears excessive. Picatinny Arsenal
personnel are well aware of localized flooding conditions. The
placement of the treatment unit accounts for such conditions. In
addition, we intend the treatment unit to mitigate the possible
effects of flooding. EPA and NJDEP will have the opportunity to
review and comment on these design plans. The treatment unit is
designed to be temporary.
Q7: Picatinny Arsenal should contact the U.S. Fish and Wildlife Service to
determine whether there is a possibility of encountering federal
endangered/threatened bird species in the vicinity of the Site. While
we do not expect that the proposed remedial activity will have a
detrimental impact on these species because of their transitory
nature, informal consultation should be conducted to comply with the
Endangered Species Act.
A7: Off-gases from the stripper will be treated through use of a GAC
filter. The resultant effluent will meet air discharge limits. This,
in addition to the transitory nature of species, will preclude any
detrimental impact on any bird species. The Fish and Wildlife Service
will be contacted prior to construction to confirm the above
statements.
Q8: The proposed action should be reviewed for compliance with the
National Historic Preservation Act (NHPA). Cultural resource surveys
have been prepared for Picatinny Arsenal and should be available to
help determine whether the project will impact sites on or eligible
for nomination to the National Register of Historic Places.
A8: The proposed action has been reviewed for compliance with the National
Historic Preservation Act. All historic sites located at Picatinny
Arsenal have been recorded in accordance with the Historic American
Building Survey/Historic American Engineering Record (HABS/HAER).
Building 39 and the Cannon Gates are in the vicinity where the action
will take place. Building 39 has been rated as a Category 3 and
Cannon Gates Category 2. No impact to these areas is anticipated.
-------
DEPARTMENT OF THE ARMY
US ARMY TOXIC AND HAZARDOUS MATERIALS AGENCY
ABERDEEN PROVING GROUND. MARYLAND 21010-5401
•t»LT TO
AT TINT 100 Of
CETHA-IR-B (50-6c)
8 SEP 1989
MEMORANDUM FOR Commander, U.S. Army Engineer Division, Huntsville, ATTN:
CEHND-ED-PM (Mr. Walt Perro), P.O. Box 1600, Huntsville, AL
35807-4301
SUBJECT: Picatinny Arsenal Interim Remedial Action Effluent Limitations and
Monitoring Requirements
I. Recommend the enclosed effluent limitations and monitoring requirements
provided by the New Jersey Department of Environmental Protection be issued as
an addendum to the "Record of Decision for Interim Groundwater Remediation Plan,
Picatinny Arsenal, New Jersey," prepared by ERC Environmental and Energy
Services Company, May 1989.
2. Point of contact for this Agency is Ms. Roxann Moran, AUTOVON 584-3240, or
commercial (301) 671-3240.
FOR THE COMMANDER:
Encl
ROBERT S. METZGER II
LTC, CM
Deputy
Installation Restoration Division
-------
Page 1 of 7 Pages
l.A EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
The permittee is authorized to discharge treated ground water into Green Pond Brook from the
treatment system. There shall be no discharge of floating solids or visible foam in other than
trace amounts. There shall be no visible sheen.
The abbreviation 'N/A1, in the table below denotes 'Not Applicable' while the abbreviation 'NL*,
denotes 'Mot Limited1 with both monitoring and reporting required.
Samples taken in compliance with the specified monitoring requirements shall be taken at the
discharge from the treatment system, and shall be reported monthly.
KFFLUENT CHARACTERISTIC
All units are in ug/1 Daily
unless otherwise specified Minimum
Flow (MGD) N/A
pli (Standard Units) 6.0
Total Suspended Solids, rag/I N/A
Chemical Oxygen Demand, mg/1 N/A
Oil & Grease, mg/1 N/A
Cadmium N/A
Chromium N/A
Lead N/A
Selenium N/A
Arsenic N/A
Copper N/A
Zinc N/A
Benzene N/A
Chloroform N/A
1,l7Dichloroethylene N/A
1,2-trans Dichloroethylene N/A
Methylene Chloride N/A
Tetrachloroethylene N/A
Toluene N/A
Trichloroethylene N/A
DISCHARGE LIMITATIONS *
Monthly
Average
NL
N/A
NL
NL
10
NL
NL
NL
NL
NL
NL
NL
NL
111
22
25
36
52
NL
26
Daily
Maximum
0.216
9.0
88
50
15
22
110
, 110
22
110
7.0
56
50
325
60
66
170
164
50
69
MONITORING REQUIREMENTS
Frequency Sample type
Monthly
Monthly
Monthly
Monthly
Monthly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Instantaneous
Grab
Grab
Grab
Gxetb
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
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\JL
l.A EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
rn
a.'
EFFLUENT CHARACTERISTIC
All units are in ug/1
unless otherwise specified
1,1,1-Trichloroethane
1,1-Dichloroethane
Phenols
Organic Toxic Pollutants
(Volatiles Only)
Acute Toxicity
Chronic Toxicity
Daily
Minimum
N/A
N/A
N/A
N/A
LC50*50%
DISCHARGE LIMITATIONS *
Monthly
Average
22
22
19
NL
N/A
N/A
Daily
Maximum
59
59
47
100
N/A
N/A
MONITORING REQUIREMEI
Frequency Sample tyi
Weekly
Weekly
Weekly
Weekly
Grab
Grab
Grab
Grab
See Page 3 of 7 Page
See Page 3 of 7 Page
•3
ui
•1
O'l
O
* Predicated upon discharge through a submerged high-rate diffuser. After receipt of background dat
the effluent limitations may be modified to reflect more appropriate limitations.
iM
0-
±.
•I
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