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

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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)

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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,

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                               -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

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'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.,

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        -  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.

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                    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

-------
                          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).

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     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.

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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

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               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

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     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

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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.

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                   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

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                           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

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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

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               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

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                           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.

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                                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).

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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.

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                         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

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                                                                              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

-------