Superfund Record of Decision Federal Aviation Administration Technical Center (Area B Navy Fire Test Facility) Atlantic County NJ


                                    EPA/ROD/R02-96/272
                                    1996
EPA Superfund
     Record of Decision:
     FEDERAL AVIATION ADMINISTRATION TECHNICAL
     CENTER (USDOT)
     EPA ID: NJ9690510020
     OU08
     ATLANTIC COUNTY, NJ
     09/20/1996

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                     TABIiE OF CONTENTS


                                                 PAGE
DECLARATION FOR THE RECORD OF DECISION

DECISION SUMMARY FOR THE RECORD OF DECISION

I.   SITE NAME, LOCATION AND DESCRIPTION	1

II.     SITE HISTORY AND ENFORCEMENT ACTIVITIES	4
       A.   Land Use	4
       B.   Initial-Investigations	4
       C.   Environmental Investigation/Feasibility Study ..5

III.    HIGHLIGHTS OF COMMUNITY PARTICIPATION	14

IV.    SCOPE AND ROLE OF RESPONSE ACTION	14

V.     SUMMARY OF SITE CHARACTERISTICS	16

VI.    SUMMARY OF SITE RISKS	23
         A.  Human Health Risk Assessment	23
         B.  Ecological Risk Assessment	28
         C. Ri s k Summary	30

VII.    REMEDIAL ACTION OBJECTIVES	30

VIII.  DESCRIPTION OF THE ALTERNATIVES	33

IX.     SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	36

X.       SELECTED REMEDY	39

XI.      STATUTORY DETERMINATIONS	40

XII.     DOCUMENTATION OF NO SIGNIFICANT  CHANGES	48

RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION

I.       OVERVIEW	1

II.      BACKGROUND ON COMMUNITY INVOLVEMENT	1

III.     SUMMARY OF MAJOR QUESTIONS AND COMMENTS	2

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                        TABIiE OF CONTENTS
                            (Continued)
LIST OF FIGURES
     1  Site Location Map - Area B 	2
     2  Navy Fire Test Facility Site Plan - Area B 	3
     3  Phase I Investigation  (1987)  - Area B	6
     4  Phase II Investigation  (1988) - Area B 	8
     5  Supplemental Investigation (1989) - Area B 	10
     6  Hydropunch Sampling Point Locations and Area B
        Historical Site Use	11
     7  Geoprobe Investigation Approximate Extent of
        Product Plume  (July 1993)	 13
     8  Quarterly Monitoring Well and Surface Water
        Sample Locations - Area B	15
     9  Approximate Extent of Ground Water Contamination
        Plume - Area B	21

LIST OF TABLES

     1  Constituents of Potential Concern	24
     2  Toxicity Values Used in the HHRA - Summary of
        Toxicity Values Associated with Carcinogenic
        Effects : Oral	27
     3  Summary of EHQs for Soil-Related Exposures,
        Terrestrial/Avian Receptors..          	31
     4  Summary of EHQs for Sediment Exposures	32
     5  List of Applicable or Relevant and Appropriate
        Reguirements(ARARs)Applicable to the Selected
        Remedy	42
     6  Chemical- Specific ARARs Applicable to the Selected
        Remedy	46

APPENDICES

     A  NJDEP AND KNELANDS COMMISSION LETTERS OF CONCURRENCE
     B  PUBLIC MEETING ATTENDANCE LIST
     C  PUBLIC MEETING TRANSCRIPT

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                                  DECLARATION FOR THE RECORD OF DECISION
                                  Area B - Navy Fire Test Facility
                                  FAA Technical Center
FACILITY NAME AND LOCATION
Federal Aviation Administration  (FAA) Technical Center, Atlantic County
Atlantic City International Airport, New Jersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for Area B, the Navy Fire Test
Facility, at the FAA Technical Center, Atlantic City International Airport, New Jersey. The
remedial action decision was chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA),  as amended by the Superfund Amendments and
Reauthorization Act (SARA), and,to the extent practicable, the National Contingency Plan  (NCP).
This decision is based on the administrative record for Area B.

The Commissioner of the New Jersey Department of Environmental Protection and the Pinelands
Commission concur with the selected remedy  (Appendix A).

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision  (ROD), may present an
imminent and substantial threat to public health, welfare, or the environment. Area B, the Navy
Fire Test Facility, was used for aircraft fire training in the late 1950s and 1960s which
resulted in ground water contamination due to releases of hydrocarbon products containing
hazardous substances and volatile organic compounds.

DESCRIPTION OF THE SELECTED REMEDY AND CONTINGENCY REMEDY

The selected remedy for Area B addresses the principal threat by treating contaminated
ground water. The selected remedy for Area B includes the following components:

       Installation of additional monitoring wells;

       Continued ground water and surface water monitoring;

       Installation and operation of air sparging wells,  vapor extraction wells and monitoring
       probes;

       On-site vapor treatment (if necessary); - and

       Five year reviews.

If additional subsurface investigations indicate that the selected remedy is unsuitable for
application at Area B, a contingency remedy will be employed. The contingency remedy for Area B
includes the following components:

        Installation of additional monitoring wells;

        Continued ground water and surface water monitoring;

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        Installation and operation of product/ground water extraction wells;

        Physical separation of product and off-site transport for incineration;

        On-site ground water treatment by air stripping;

        Discharge of treated water back into the shallow ground  water; and

        Five year reviews.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment (or resource recovery)  technologies to the maximum extent practicable, and it
satisfies the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.

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DECISION SUMMARY
RECORD OF DECISION
Area B - Navy Fire Test Facility
FAA Technical Center
I. SITE NAME, LOCATION AND DESCRIPTION

The FAA Technical Center encompasses an area of approximately 5,000 acres in Atlantic
County, New Jersey, eight miles northwest of Atlantic City. Among the installations on the
property are the Atlantic City International Air Terminal, the New Jersey Air National Guard
177th Fighter Interceptor Group, the Upper Atlantic City Reservoir, the Laurel Memorial Park
Cemetery and the extensive facilities of the FAA Technical Center. Atlantic City's municipal
water supply is provided by nine ground water production wells located just north of the Upper
Atlantic City Reservoir on FAA property as well as by water drawn directly from the Atlantic
City Reservoirs. The reservoirs are fed by the North and South Branches of Doughty's Mill
Stream, which traverse portions of the FAA Technical Center grounds. The public water supply
facilities on site are owned by the Atlantic City Municipal Utilities Authority (ACMUA).

The FAA Technical Center is located within the Atlantic Coastal Plain, a broad, flat plain
which encompasses the southern three-fifths of New Jersey. The area within two miles of the FAA
Technical Center has a maximum relief of about 65 feet, ranging from an elevation of ten feet
above mean sea level (msl) at the Lower Atlantic City Reservoir to 75 feet msl to the west and
north of the airport The facility itself is relatively flat-, slopes generally range from 0 to 3
percent. Forested areas exist north, south, and east of the airport runways. These areas
comprise about 40% of the 5,000- acre FAA Technical Center property. The remaining 60% of the
site has been cleared for FAA facilities and consists of buildings and paved surfaces, grassed
lawns and native grassland and shrubs adjacent to the runways.

The area within one mile of the FAA Technical Center boundaries includes open or forested
land and commercial and residential areas. A large forested tract containing no commercial or
residential property exists west of the FAA Technical Center. To the east, the property is
bordered by the Garden State Park-way, the Lower Atlantic City Reservoir, and the forested land
surrounding the reservoir. The area north of the FAA Technical Center contains commercial
properties along the White Horse Pike (Rt 30) and a concentrated residential area, Pomona Oaks,
north of the White Horse Pike. The closest residential area south of the FAA Technical Center is
a series of three trailer parks at the intersection of Tilton Road and Deliah Road. The majority
of commercial and residential areas south of the FAA Technical Center are greater than 2,000
feet away from the FAA property, south of the Atlantic City Expressway. All residential areas in
the vicinity of FAA appear to be upgradient or otherwise isolated from the ground water flow at
the FAA Technical Center.

Area B is located near the former location of the sewage treatment plant, in the southwestern
portion of the FAA property, as indicated on Figure 1, The South Branch of Doughty's Mill Stream
flows from west to east along the southern portion of the area (Figure 2). The area is currently
grass- covered, with a wooded area in the southern portion of the site along the stream. An
unnamed road traverses the central portion of the site.

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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use

The first significant development of what is now FAA property came during the 1930s when the
Upper Atlantic City Reservoir was created by damming the South Branch of Doughty's Mill Stream.
Prior to 1942, the entire property was wooded, except for the presence of large borrow pits near
the present-day Research and Development (R&D) facilities. On a 1940 aerial photograph, several
dirt roads and what appears to be a railroad right-of-way traverse the property. In the early
1940s, a Naval Air Base and the Atlantic City Municipal Airport, including most of the existing
runways, were constructed over much of the eastern two-thirds of the property. Many of the
buildings in the western built-up area were also constructed at this time. In 1958, the Navy
transferred its interests to the Airways Modernization Board (AMB).

The FAA took over the operations of the AMB in November 1958. The development of most of the R&D
portion of the facility south of the Upper Atlantic City Reservoir occurred in the early 1960s
The FAA's large Technical/Administrative Building was constructed in 1979. The New Jersey Air
National Guard has maintained their facilities at the northern ~nd of the built-up area since
1973.

Area B, referred to as the Navy Fire Test Facility, was used during the late 1950s and early
1960s for aircraft fire training. A review of historical aerial photographs indicates that the
highest level of activity occurred between 1957 and 1962. During this time frame, aircraft and
sections of aircraft were located throughout the area and portions of the area's ground surface
exhibited dark-colored stains. By 1965, the area had been graded over. A portion of the area
was later used for General Services Administration (GSA) motor pool parking. The portions of the
site used for fire training and GSA motor pool parking are indicated in Figure 2.

The FAA Technical Center was listed on the National Priorities List (NPL) on August 30,1990, 55
FR 3 5502, with an effective date of October 1, 1990. The FAA entered into an Interagency
Agreement (IAG) with the EPA on May 17, 1993. The IAG is a legally enforceable document that
memorializes FAA's commitment to remediate the site and defines the role of EPA in the cleanup
process.

B. Initial Investigations

In 1983, the New Jersey Department of Environmental Protection (NJDEP) directed Roy F. Weston
(Weston) to conduct an assessment of potential pollution sources that could impact the
then-proposed Atlantic City well field. The assessment included a review of all data on possible
contaminant sources in the area, limited field investigation of these sources, and soil and
ground water sampling at five areas considered most threatening to ground water supplies in the
area. The entire FAA Technical Center was included in the Weston Study, and the five areas
identified by Weston were all located on the FAA property. Weston's report led the FAA to
initiate the present Environmental Investigation/Feasibility Study (EI/FS) of the five sites as
well as additional areas identified by the FAA.

C. Environmental Investigation/Feasibility Study

The Area B El included six phases of Investigation conducted between December 1986 and
July 1993. The scope of these investigations is described below.

Phase I

Site investigation activities conducted during the Phase I El included a soil gas survey,

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geophysical survey, surface soil sampling, subsurface soil sampling, ground water sampling, and
a hydrogeological investigation, A facility-wide surface water and sediment investigation which
included the collection of a surface water sample and sediment sample from the South Branch of
Doughty's Mill Stream adjacent to Area B was also conducted during the Phase I El. Each of these
Phase I El components is discussed briefly below. Figure 3 provides the Phase I El sampling
locations.

• A soil gas survey was conducted on a 100-foot grid of the area to identify potentially
contaminated sods or contaminant plumes through the presence of elevated levels of
volatile organic compounds (VOCs) within the soil's pore space. One small anomaly was
identified in the northern comer of the site. Organic vapor concentrations in this area
were only slightly elevated, ranging from 38 ppm to 260 ppm.

• A geophysical survey (EM-31 and EM-34) and resistivity profiling to detect buried metal
objects were also conducted during the Phase I investigation. The data were strongly
influenced by cultural features, particularly the presence of power lines. All anomalies
were found to be related to the presence of utilities.

• Five surface soil samples (B-SSI to B-SS5) were collected at Area B including one
background sample (B-SSI). Sample B-SS-3 was collected from the center of the soil gas
anomaly. Three samples, including the background sample and the one collected from the
soil gas anomaly were analyzed for priority pollutants plus 40 additional peaks (PP+40).
The remaining two samples were analyzed for total petroleum hydrocarbons (TPH). No
priority pollutant VOCs or semi-volatile organic compounds (SVOCs) were detected in the
samples analyzed for PP+40, although the pesticide 4,4'-DDT and inorganics were detected
in the samples. The two samples analyzed for TPH each exhibited the presence of TPH
compounds.

• Four 30-foot deep sod borings were drilled to define the vertical extent of contamination
and site geology. One subsurface soil sample was collected from each boring location. The
sample from one boring, B-B3, was analyzed for PP+40, while the remaining three samples
were analyzed for TPH. Polychlorinatcd biphenyls (PCBs) and inorganics were detected in
the sample analyzed for PP+40. Low levels of TPH were detected in the other subsurface
samples.

• Three shallow monitoring wells were also installed during the Phase I El to obtain
stratigraphic, hydrogeologic and ground water guality data. One well (B-MWIS) was located
upgradient of the site to serve as a background well and two wells (B-MW2S and B-MW3S)
were located in the downgradient portion of the site, between the suspected fire fighting
area and the South Branch of Doughty's Mill Stream. All ground water samples were
submitted for PP+40 analysis. Ethylbenzene and 4,4'-DDT were the only priority pollutant
organics detected, both in well B-MW3S. Inorganics (chromium, copper, mercury, lead, and
zinc) were also detected in varying concentrations in the ground water samples. Subseguent
to the completion of the Phase I studies, the presence of an 8-inch thick floating
hydrocarbon product layer (hereinafter referred to as "floating product" or "product") was
identified in well B-MW3S.

• One surface water sample and one sediment sample were collected during the Phase I El from
the South Branch of Doughty's MH Stream adjacent to Area B and were analyzed for PP+40.
No priority pollutant compounds were detected in the surface water sample.
Tetrachloroethene, trichloroethene, 4,4'-DDT, and inorganics including chromium, lead,
zinc and mercury were detected in the sediment sample.

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• Hydrogeologic investigations indicated that the top 30 feet of soils at Area B are
dominated by fine to medium sands with only minor amounts of silt and clay. At B-MWIS,
north and upgradient of the area, the soils consist of fine to very fine sands with a
substantial percentage of silt. Based on the boring log for production well FAA-5, located
1000 feet northwest of Area B, the Upper Cohansey Clay is absent, with the first
substantial confining layer being the thirty-foot-thick Middle Cohansey Clay layer
encountered at a depth of 95 feet. The water table at Area B was encountered at depths of
4 feet to 17 feet during the Phase I El. Ground water flow at the site is roughly
south-southwest toward the South Branch of Doughty's Mill Stream.

Phase II

During the Phase II investigation conducted in late 1988, twelve soil borings were drilled to
further investigate the extent and chemical nature of the floating product detected in well
B-MW3S. Figure 4 provides the Phase II El sampling locations. Eleven 10- to 12-foot deep soil
borings were drilled within 50 to 75 feet of well B-MW3S to define the extent of subsurface
contamination on the basis of field headspace measurements. An additional boring was drilled
upgradient of well B-MW3S to investigate upgradient subsurface soil quality. A soil sample was
collected for PP+40 and TPH analyses. Floating product was sampled for PP+40 analysis, gas
chromatograph (GC) fingerprinting, and physical parameters. A ground water sample was also
collected from beneath the floating product layer in B-MW3 S for priority pollutant VOC
analysis.

• The areal extent of the subsurface contamination associated with the floating product was
defined by plotting the locations of elevated subsurface soil headspace readings for the
soil samples collected from the twelve soil borings, as indicated in Figure 4. The
subsurface area of elevated headspace readings measured approximately 30 feet by 50 feet.
No upgradient source area was identified through the chemical analysis of a subsurface
soil sample collected from an upgradient soil boring.

• The product sample exhibited an odor characteristic of a mixture of gasoline and kerosene.
Chemical analysis of a floating product sample indicated that its chromatogram most
closely resembles that of gasoline, Xylene, chlorobenzene, and ethylbenzene were
identified as the main components in the priority pollutant analysis of the product
sample.

• Ethylbenzene was the only priority pollutant VOC detected in the ground water sample from
beneath the product layer in well B-MW3S.

Supplemental Investigation

A Supplemental Investigation was conducted in September 1989 at Area B to further define
subsurface soil quality in the area of the floating product, since no subsurface soil samples
were collected from the floating product area for priority pollutant chemical analysis during
previous investigations. The scope of the Supplemental Investigation included the drilling of
two soil borings and the collection of three subsurface soil samples for priority pollutant
analysis. One boring, B-B17, was drilled within 6 feet of existing monitoring well B-MW3S, with
soil samples collected at the water table (8- to 10-foot interval) and in the zone 2- to 4- feet
above the water table (4- to 6-foot interval ). The second boring, B-B 18, was drilled 13 feet
southeast of B-MW3, with a soil sample collected at the water table (8- to 10-foot interval).
The supplemental soil boring locations are presented in Figure 5. Analysis of the subsurface

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soil samples identified the presence of di-n-butylphthalate, both VOC and SVOC tentatively
identified compounds (TICs), 4,4-DDT, chromium, and lead.

Although monitoring well B-MW3S was not resampled during the Supplemental Investigation, the
product thickness was monitored prior to and during the investigation period. In June 1989, a
product thickness of 0.5 inches was measured in the well. In November 1989, no measurable
thickness of product could be identified in the well. Due to the relatively thin layer of
product measured in the well and the documented tendency for floating product to accumulate in
wells to thicknesses greater than are present in the surrounding aguifer, seasonal variations in
water level could account for the product's periodic absence from the well during this period.

Additional Investigations

In August 1992, additional investigations were conducted to determine if the stained soils or
aircraft areas visible in the historic aerial photographs, as indicated in Figure 6, could be a
potential source of contamination at Area B. A Hydropunch sampling system, which consists of a
patented drive tube and sampler capable of collecting a ground wat er sample without the
installation of a monitoring well, was used. Ten shallow ground water samples were collected for
drinking water VOC analysis Chloroform, benzene, tetrachloroethene, 1,2,4-trimethylbenzene and
1,2-dichlorobenzene were detected at five of the ten locations at trace to low levels. However,
no consistent pattern of contamination was noted and no potential source of the floating product
was identified. Approximately 3 inches of floating product were measured in well B-MW3S during
this investigation.

To further define the nature and extent of dissolved ground water contamination, two
additional monitoring wells (B-MW4S and B-MWSS) were installed downgradient of B-MW3S, adjacent
to the South Branch of Doughty's Mill Stream during January 1993. Ground water samples were
collected from the new wells and existing well B-MW3 S for organic and inorganic analyses.

The locations of the new wells are provided in Figure 6. During this investigation, a product
thickness of approximately 2 inches was measured in well B-MW3S. The ground water sample
collected from beneath the product layer in well B-N1W3S exhibited the presence of aromatic
hydrocarbons, 4-methylphenol, naphthalene, VOC and SVOC TICs, arsenic, zinc and phenol.
The presence of 4,4'-DDT ih the ground water at this location, as indicated by the Phase I El
results, was not confirmed. In the two newly installed downgradient wells, several chlorinated
hydrocarbons, including 1,1-dichloroetliene, trichloroethene, and tetrachloroethene, SVOC TICs,
heptachlor epoxide, arsenic, and mercury were detected.

In May 1993, wells B-MW4S and B-MW5S were resampled and three surface water samples
were collected from the South Branch of Doughty's Mill Stream for VOC analysis. The analysis of
ground water samples from wells B-MW4S and B-N4W5S confirmed the presence of chlorinated
hydrocarbons at levels similar to those detected during the January 1993 investigation. No VOCs
were detected in the surface water samples at levels above laboratory detection limits.

A Geoprobe ground water investigation was subseguently conducted in July 1993 to further define
the extent of the floating product plume as well as the nature and extent of the dissolved
ground water contamination upgradlent and downgradient of B-N4W3S. Similar to the Hydropunch
investigation system, the Geoprobe sampling system allows for the collection of ground water
samples without the installation of monitoring wells. A total of 26 Geoprobe locations were
sampled in the area near and between B-MW3S and the South Branch of Doughty's Mill Stream
Geoprobe locations are indicated in Figure 7. While aromatic and chlorinated hydrocarbon

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compounds were detected at varying levels within the Geoprobe  ground water samples, there was
no consistent pattern of contamination apparent in the sample results, with the exception of the
detection of aromatic hydrocarbons and the identification of a thin product layer at Geoprobe,
location GP-15 Based on the Geoprobe' results, the estimated product area was plotted as shown
in Figure 7.

Immediately following the Geoprobe  investigation, two monitoring wells  (B-MW7S and
B-MW9S) were installed near Geoprobe  locations which exhibited elevated VOC levels, a third
monitoring well  (B-MW8S) was installed upgradient of B-MW3S, and a fourth monitoring well
(B-MW6S) was installed on the south side of the South Branch of Doughty's Mill Stream. The
locations of these wells are indicated in Figure 7. Concurrent with monitoring well
installation, five subsurface soil samples (including one duplicate sample) were collected and
analyzed for priority pollutant VOCs but exhibited no detectable contamination. In August 1993,
the four new wells and existing wells B-MW4S and B-MW5S were sampled and three surface water
samples were collected from the South Branch. No upgradient source of contamination was
identified and no VOCs were detected in the surface water samples, Xylene was the only aromatic
hydrocarbon detected and was present only in well B-MW4S. Chlorinated VOCs were detected in
wells B-MW4S, B-MWSS, B-MW6S and B-MW7S. The presence of chlorinated hydrocarbons at low levels
of 2 parts per billion  (ppb) or less was detected in well B-MMS, located south of the South
Branch. Its presence may be attributable to residues of contaminant migration which occurred
prior to channelization of the stream. The South Branch was channelized north of its natural
location sometime between 1957 and 1961, based on a review of historic aerial photographs. Based
on ground water and surface water elevations measured during site investigations, the South
Branch is considered to be a "gaining" stream, that is, ground water discharges to the stream.
If contamination was present before the channelization of the stream, contaminants may have
migrated toward the stream's original location.  It is possible that the presence of VOCs in
well B-MW6S reflects the remnants of residual dissolved ground water contamination that may have
migrated to this location prior to the diversion of the stream flow. This hypothesis is
supported by the fact that the area surrounding B-MW6S is undeveloped and wooded, with no other
potential sources of such contamination evident.



Quarterly ground water sampling of the monitoring wells and surface water sampling
locations indicated in Figure 8, which has been conducted since December 1993, has verified the
results of the site investigations described above.

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

A newspaper notification of the availability of the Proposed Plan for Area B was published in
the Atlantic Citv Press on April 11, 1996. The notice invited the public to comment on the EI/FS
and Proposed Plan. The public comment period was held from April 11 through May 10, 1996. The
Proposed Plan and EI/FS Reports were placed in the administrative record maintained at the
Atlantic County Library.

A public meeting was held on May 2, 1996 at the Atlantic County Library. At the meeting,
representatives from the FAA, FAA's environmental consultant (TRC Environmental Corporation),
U-S Environmental Protect ion Agency  (EPA) ,  and New Jersey Department of Environmental
Protection (NJDEP) were available to answer questions about Area B. The attendance list from
the meeting is attached (see Appendix B). No comments on the Proposed Plan were received during
the public comment period, as noted in the Responsiveness Summary, which follows this Decision
Summary.

This decision document presents the selected remedial action alternative for Area B of the FAA

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Technical Center in Atlantic County, New Jersey, chosen in accordance with CERCLA, as
amended by SARA and, to the extent practicable, the NCP. The decision for Area B is based on
the administrative record.

IV. SCOPE AND ROIiE OF RESPONSE ACTION

Area B poses a principal threat to human health and the environment according to NJDEP's
risk criteria. Risk assessment findings, the presence of ground water contaminants at levels
which exceed state drinking water and ground water guality standards, hydrogeologic conditions
and the presence of floating product layer containing hazardous substances provide the basis for
the selected ground water remedial action. Surface water and sediment guality within the South
Branch of Doughty's Mill Stream will be addressed witMn a separate operable unit, as necessary.

It should be noted that Area B represents only one of more than 20 areas of potential
environ.mental concern identified at the FAA Technical Center. This document addresses only
Area B, and is not intended to address the entire FAA property. The other areas of concern at
the FAA Technical Center will be subject to separate response action decisions.

V. SUMMARY OF SITE CHARACTERISTICS

The El identified the presence of constituents in soils and ground water at Area B which
appear to be mainly attributable to contarruination in the vicinity of monitoring well B-MW3S,
where free product was detected. The samples collected and analyzed during the field
investigations provide an overview of contaminant types and distributions.

For each environmental medium or potential contaminant source (e.g., soil, ground water,
product, surface water and sediment) sampled, detected concentrations of contaminants are
summarized and evaluated against appropriate chemical-specific applicable or relevant and
appropriate reguirements (ARARs) and to-be-considered criteria.(TBCs) below.

Soil

During the El activities at Area B, five surface soil samples and twelve subsurface soil
samples were collected for chemical analysis. The only volatile organic priority pollutants
detected were methylene chloride in surface soil samples and methylene chloride, toluene and
trichlorofluoromethane in subsurface soil samples. Methylene chloride, considered by the EPA as
a common laboratory contaminant, was also detected in blank samples associated with the
subsurface soil samples at levels which exceeded 10% of the highest level detected in the
subsurface soil samples. Therefore, methylene chloride was eliminated from the set of subsurface
soil sample results. The maximum detected concentrations of methylene chloride in surface soils
and toluene and trichiorofluoromethane in subsurface soils ranged from 0.002 ppm to 0.014 ppm.
Total VOC concentrations, including VOC TICs, ranged from a maximum of 0.06 ppm in surface soils
to 1.2 ppm in subsurface soils. VOC TICS detected in surface soil samples included 1, 1,
2-trichloro-l,2,2-trifluoroethane (which was also present in the field blank) while VOC TICs
detected in subsurface soils included acetone and unknown eicosyne, ethanol, and cyclohexane.

SVOC priority pollutant compounds detected in soils at Area B include 1,2,4-
trichlorobenzene, di-n-butylphthalate, naphthalene, di-n-octylphthalate, bis (2-ethylhexyl)
phthalate and butylbenzylphthalate. 1,2,4-Trichlorobenzene and di-n-butylphthalate were each
detected in only one surface soil sample at estimated concentrations of 0.30 ppm and 0.042 ppm,
respectively. Di-n-butylphthalate was also detected in one Phase II El subsurface soil sample at
a concentration of 0. 050 ppm and in three Supplemental Investigation subsurface soil samples at

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concentrations ranging from 0.38 ppm to2.6 ppm. However, the presence of di-n-butylphthalate in
a Supplemental Investigation method blank at a concentration of 1.6 ppm allows for the
elimination of di-n-butylphthalate from the Supplemental Investigation subsurface soil data set.
Naphthalene, di-n-octylphthalate and butylbenzylphthalate were each detected in a single
subsurface soil sample at concentrations of 0.053 ppm, 0,062 ppm, and 0.31 ppm, respectively.
Bis(2-ethylhexyl)phthalate was detected in two subsurface soil samples at concentrations of
0.069 ppm. and 0.40 ppm. Tentatively identified SVOC compounds were detected in surface and
subsurface soil samples collected during each of the investigations. The SVOC TICs primarily
consisted of unknowns, with alkanes, methyl-2-hexanone, hexadecanoic acid and aldol condensate.

One Phase I subsurface soil sample, B-133-5, collected at a depth of 8 to 10 feet, exhibited 0.
74 ppm of the PCB Aroclor 1242. No other soil samples collected at Area B contained any PCB
compounds. The pesticides 4,4'-DDT and 4,4'-DDE were detected in three surface soil samples and
in one subsurface soil sample at concentrations ranging firom 0.0073 pprn to 0.35 ppm.

Inorganics detected in the Area B surface and subsurface soils include arsenic, cadmium,
chromium, copper, lead, mercury, and zinc. Lead was detected in each surface and subsurface
soil sample analyzed for priority pollutants during each investigation. Concentrations of lead
ranged from 1.6 ppm to 6.8 ppm. Chromium was detected in six of eight samples while zinc was
detected in five of eight samples. Three samples contained arsenic, three samples contained
copper, two samples contained cadmium, and one sample contained mercury.

Soil contaminant levels were compared to the most stringent of NJDEP's soil cleanup criteria,
including residential soil cleanup criteria, non-residential soil cleanup criteria and impact to
ground water soil cleanup criteria. Federal guidance levels against which soil contaminant
levels were compared include the TSCA PCB Spill Cleanup Policy (Subpart G, 40 CFR 761.120
through 761.135) and the Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective
Action Facilities (OSWER Directive 9355.4-12). The PCB Spill Cleanup Policy establishes a PCB
cleanup level of 10 ppm for soils to a minimum depth of 10 inches in nonrestricted access areas.
This level is applicable to spills of materials containing PCBs at concentrations of 50 ppm or
greater which occurred afler May 4, 1987. While not applicable to Area B, this cleanup level
was considered in the evaluation of PCB levels in surface soils at the site. The Revised Interim
Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities sets forth a screening
level for lead in soil of 400 ppm, based on residential exposure. This guidance was also
considered in the evaluation of surface soil contamination at the site.

The only constituents detected in surface or subsurface soil samples at levels which exceed
state or federal guidance levels are PCBs and cadmium. The PCB Aroclor 1242 was detected in a
single subsurface soil sample at a level of 0.74 ppm, which exceeds the New Jersey residential
soil cleanup criterion of 0.49 ppm. However, based on its detection within a subsurface soil
sample collected at a depth of 8 to 10 feet, direct exposure to the soil is considered to be
highly unlikely. Therefore, PCBs in soil are not considered to represent a human health or
environmental concern. Cadmium was detected in three of four surface soil, samples at levels
exceeding the February 1994 New Jersev residential soil cleanup criterion of 1 ppm. However,
NJDEP is currently revising the cadmium residential soil cleanup criterion to a value of 39 ppm.
Therefore, cadmium in soil is not considered to represent a human health or environmental
concern.

Ground Water

Ground water samples were collected from a total of nine monitoring wells at Area B during the
Environmental Investigations or guarterly ground water sampling events. Constituents
detected in ground water at Area B include VOCs, SVOC TICs, and inorganics. Floating product was
also identified in monitoring well B-MW3S, located in the southern portion of the site. High

-------
levels of VOCs and SVOC TICs were detected in a sample of the product. These results are
discussed in more detail by chemical class in the following sections.

During the Phase I investigation, priority pollutant volatile organics detected in the ground
water samples collected from wells B-MW1S, B-MW2S and B-MW3S included methylene chloride,
chloroform, 1,1,1-trichloroethane, and ethylbenzene. Methylene chloride was detected in each of
the three ground water samples but was also detected in associated blank samples. Based on the
blank concentrations, methylene chloride was eliminated from the set of sample results.
Chloroform and 1, 1, 1 -trichloroethane were each detected in monitoring well B-MW2S at
estimated concentrations of 1 ppb. During the Phase II El, following the identification of
floating product in well B-MW3S, the ground water sample collected from beneath the floating
product layer exhibited ethylbenzene at 550 ppb, methylene chloride at 2,500 ppb, and total
xylenes at 3,700 ppb. Additional investigations involving the installation of six additional
monitoring wells and guarterly ground water sampling identified the presence of additional
priority pollutant volatile organic compounds in the ground water at Area B. In these
investigations,  monitoring wells B-MW1S and B-MW2S were not resampled. Monitoring well B-MW3S,
sampled only in February 1993, exhibited total xylenes at 2,300 ppb, ethylbenzene at 340 ppb and
toluene at 26 ppb. Monitoring well B-MW8S, located upgradient of B-MW3 S, and monitoring well
B-MW9S, located sidegradient of B-MW3S, exhibited no analytically valid VOC constituents. Wells
B-MW4S, B-MW5S and B-MW7S,  located downgradient of well B-MW3S, did not exhibit the presence of
aromatic hydrocarbons, with the exception of xylene and ethylbenzene, both detected during the
May 1993 sampling round in well B-MW4S. Wells B-MW4S, B-MW5S and B-MW6S have, however, exhibited
the presence of other compounds  (primanily chlorinated compounds),  including the following
constituents detected at the ranges noted.
           Acetone
           Carbon disulfide
           1, 1 -Dichloroethene
           1, 1 -Dichloroethane
           cis- 1,2-Dichloroethene
           Chloroform
           1, 1, 1 -Trichloroethane
           Trichloroethene
            Tetrachloroethene
            1,2-Dichloropropane
            1,2-Dichloropropene
             VOC TICs
Not detected (ND)  to 12 ppb
ND to 0.2 ppb
ND to 16 ppb
ND to 22 ppb
ND to 2 ppb
ND to 0.9 ppb
ND to 6 ppb
ND to 4 ppb
ND to 45 ppb
ND to 0.7 ppb
ND to 0.6 ppb
ND to 114 ppb
Trace levels of several chlorinated compounds have also been detected in well B-MW6S, which is
located on the south side of the South Branch of Doughty's NEII Stream,  at the following
levels:
             Chloroform
             Bromochloromethane
             1,1,1 -Trichloroethane
             Trichloroethene
             Tetrachloroethene
ND to I ppb
ND to 0.6 ppb
ND to 0.8 ppb
0.5 to 2 ppb
ND to 0.9 ppb
To try to identify the source of ground water contamination, single-event ground water samples
were also collected for VOC analysis during the Hydropunch investigation in areas of the site
upgradient of well B-MW3S which were historically used for fire training. The detection of trace
to low levels of VOCs at 5 of 10 sampling locations was generally inconsistent with respect to
types of contaminants and locations relative to past site activities. Single-event ground water
samples collected for VOC analysis in the immediate vicinity of B-MW3 S during the Geoprobe

-------
investigation further delineated the extent of product in the area immediately surrounding
B-MW3S. In general, a source of the aromatic and chlorinated hydrocarbon contamination detected
in the ground water at Area B was not identified by the extensive site investigations, although
the extent of contamination was delineated.

VOC analysis of the product sample collected during the Phase II El identified the presence
of high levels of xylene (1.1%), ethylbenzene (0.16%), chlorobenzene (0.093%), toluene (0.01%)
and TICs (20 2%), consisting of cycloalkanes, alkanes and unknowns, within the product.

SVOC, pesticide/PCB and inorganic analyses of ground water samples were only conducted during
the Phase I El at wells B-MW1S, B-MW2S and B-MW3S and during the sampling of wells B-MW3S,
B-MW4S and B-MW5S in February 1993. For SVOCs, naphthalene (5 ppb), 2-methylnaphthalene (2 ppb),
and tentatively identified SVOC compounds (220 ppb) consisting of hydrocarbons and unknowns were
detected in monitoring well B-MW3S during the Phase I El. Phenol was detected in each of B-MW1S,
B-MW2S and B-MW3S at concentrations ranging from 16 to 24 ppb. During the February 1993 sampling
event, well B-MW3S exhibited 4-methylphenol at 12 ppb, naphthalene at 130 ppb, and tentatively
identified SVOC compounds at 3,100 ppb. The SVOC TICs consisted of C2, C3, and C4 benzenes, and
alkane. Tentatively identified SVOC compounds were also present in a sample and duplicate sample
collected from monitoring well B-MW5S at concentrations of 54 ppb and 2 ppb, respectively.
Bis(2-ethylhexyl)phthalate was also detected in each sample, but its presence in the laboratory
blank resulted in the elimination of the compound from the data set.

SVOC analysis of the product sample collected during the Phase II El identified the presence of
high concentrations of naphthalene (0.086%) and tentatively identified SVOC compounds (9.7%)
consisting of C3 and C4 benzenes, alkanes, and unknowns.

Low concentrations of the pesticides 4,4'-DDE and 4,4'-DDT were present in ground water samples
collected at Area B during the Phase I El. 4,4'-DDT was detected in monitoring wells B-MW1S,
B-MW2S, and B-MW3S at concentrations of 0.03 ppb, 0.1 ppb, and 0.3 ppb, respectively. 4-4'-DDE
was only detected in monitoring well B-MW2 S at a concentration of 0.01 ppb. Monitoring well
B-MW3S was resampled for pesticides/PCBs, along with monitoring wells B-MW4S and B-MW5S in
February 1993. These results did not confirm the presence of 4,4'-DDT in monitoring well B-M.W3S
as detected during Phase I. Heptachlor epoxide was detected in a sample and a duplicate sample
from well B-MW4S at concentrations of 0.11 ppb and 0.14 ppb, respectively. Aldrin was also
detected in the duplicate sample only at a concentration of 0.091 ppb. No PCBs were detected in
the ground water at Area B.

Pesticide/PCB analysis of the product sample collected during the Phase II El identified the
presence of 4,4'-DDD and 4,4'-DDT, each at a concentration of 100 ppb.

Of the inorganics detected in wells B-MW1S, B-MW2S and B-MW3S, lead and zinc were detected in
all three monitoring wells at concentrations ranging from 5.2 ppb to 25 ppb, and 25.1 ppb to
64.5 ppb, respectively. While lead was detected in each of the monitoring wells, the highest
level of lead was detected in background well B-MW1S. Chromium and mercury were detected in
monitoring wells B-MW1S and B-MW2S at concentrations ranging from 15 ppb to 21.5 ppb and 0. 6
ppb to 0.65 ppb, respectively. Copper was detected only in well B-MW1S at a level of 27.4 ppb,
During the February 1993 sampling event, zinc was the only inorganic analyte detected in each of
monitoring wells B-MW3S, B-MW4S and B-MW5S at concentrations ranging from 11.0 ppb to 19.2 ppb.
Mercury was detected in samples from wells B-MW4S and B-MW5S, including a duplicate sample from
well B-MW4S, at concentrations ranging from 0.19 ppb to 2.2 ppb. Arsenic was detected in B-MW3S
and in a duplicate sample from B-MW4S at concentrations of 3.7 ppb and 2.3 ppb, respectively.

Inorganics detected in the product sample collected from monitoring well B-MW3S included
mercury at 0.55 ppb and zinc at 92.8 ppb.

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Promulgated state and federal standards (i.e., federal and state Maximum Contaminant Levels
and Ground Water Quality Standards) were used to evaluate ground water contamination. The New
Jersey Ground Water Quality Standards state that for Class I-Pineland (Protection Area) ground
water, as in the case of Area B, the ground water guality standard shall be the background water
guality. Where a constituent standard (i.e., background) is of a lower concentration than the
practical guantitation level (PQL), a discharge is not considered to contravene the standard as
long as the ground water concentration is less than the PQL. Therefore, in the following
discussions contaminant levels are compared to Maximum Contaminant Levels (MCLs), background
ground water guality as defined by well B-MW1S, and PQLs.

Of the contaminants detected in the Area B ground water, eight volatile organics (ethylbenzene,
methylene chloride, toluene, xylene (total), 1,1-dichloroethene, 1, 1, 1-trichloroethane,
trichloroethene, and tetrachloroethene), two pesticides (4,4'-DDT and aldrin), and one inorganic
(mercury) were detected at concentrations exceeding the federal or state MCLs, background ground
water guality or PQLs. Ground water in the southern portion of the site exhibited VOCs (at
monitoring wells B-MW3S, B-MW5S, B-MW6S and B-MW7S), 4,4'-DDT (at B-MW3S), aldrin (at B-MW4S)
and mercury (B-MW5S) at levels exceeding these standards. The approximate contaminant plume area
is indicated in Figure 9. At monitoring well B-MW6S, located on the south side of the South
Branch, trichloroethene was detected at a level (2 ppb) which exceeds the 1 ppb PQL in only one
of nine sampling rounds. Therefore, ground water to the south of the South Branch was not
included in the estimated ground water plume area. Inorganics were detected in upgradjent
(background) monitoring well B-MW1S and monitoring well B-MW2S, located to the east of the
approximate plume area, at concentrations exceeding relevant standards during the Phase I El;
however, based on the presence of inorganics in the upgradient monitoring well, it is
anticipated that site-related contamination is generally not responsible for the elevated
inorganic levels at these two locations. Therefore, these wells were not included in the
estimated ground water plume area.

Within the identified ground water plume area, aldrin, 4,4'-DDT and mercury were the only
non-VOC contaminants which were detected at levels exceeding the MCLs, PQLs or background
levels. Each compound was detected in a single ground water sample. 4,4'-DDT was present in
well B-MW3S during the Phase I El at a level of 0.3 ppb but was not detected when the well was
resampled (beneath the product layer) following the Hydropunch investigations. Aldrin was
detected at a level (0.091 ppb) which exceeds the PQL of 0.04 ppb, in only one of two samples.
(regular sample and a duplicate sample) collected simultaneously from well B-MW4S; aldrin was
not detected within the other sample. Mercury was detected in a single sample from well B-MW5S
at a level of 2.2 ppb.

Of the VOCs detected in the ground water plume area at levels exceeding MCLs or PQLs aromatic
VOCs (total xylene, ethylbenzene and toluene) and methylene chloride were detected in well
B-MW3S, where floating product has also been detected. Total xylene was also detected in
downgradient well B-MW4S at a level which exceeds the PQL. Chlorinated VOCs were detected at
levels exceeding PQLs in samples collected from monitoring wells B-MW5S and B-MW7S, located in
the southern portion of the site. The PQLs for 1,1-dichloroethene, 1,1,1-trichloroethane
trichloroethene, and tetrachloroethene were exceeded in well B-MW5S, and the PQL for
tetrachloroethene was exceeded in well B-MW7S.

Sediment and Surface Water

During the Phase I El, one sediment sample (SD-2) was collected from the South Branch just
downgradient of Area B. Priority pollutant VOCs present in the sediment sample but not in the
associated blank samples include trichloroethene at 0.007 ppm and tetrachloroethene at 0.002

-------
ppm, VOC TICs, comprised of unknown hydrocarbons, were also detected at a total concentration of
0.029 ppm in the sample, but not in the associated blank. SVOC compounds detected in the Phase
I sediment sample included several polynuclear aromatic hydrocarbons (PAHs). A total PAH
concentration of 1.11 ppm was detected in the sample. SVOC TICs, comprised of unknown,
hydrocarbons and organics, were also detected at a total concentration of 37.5 ppm in the
sample. The pesticide 4,4'-DDT was detected at a concentration of 0.16 ppm. No PCBs were
detected in the sample. Inorganics detected in the Phase I sediment sample include chromium (3.4
ppm), mercury (0.98 ppm), lead (5.2 ppm), and zinc (9.6 ppm).

A comparison of the contaminant levels detected in the single sediment sample to sediment
criteria values at which risks to benthic fauna are minimal was conducted within the
environmental risk evaluation and is discussed further within the presentation of that effort in
Section VI(B).

One surface water sample was collected for PP+40 analysis from the South Branch at the
same location at which the Phase I El sample was collected. Surface water sampling has also
been conducted on a quarterly basis since May 1993 at three locations along the South Branch at
Area B, with the quarterly surface water samples analyzed for priority pollutant VOCs only.
During the Phase I El, no priority pollutant VOCs were detected in the surface water sample
although an unknown VOC TIC was present at a concentration of 8 ppb. Only one priority pollutant
VOC, acetone, has been detected in the quarterly surface water samples. During the May 1993
sampling round, acetone was detected in surface water sample B-SW2 at a concentration of 9 ppb.
No priority pollutant SVOC, pesticide, PCB or inorganic analytes were detected in the surface
water sample collected during the Phase I El, with the exception of inorganic phenol, detected
at 5.6 ppb. A tentatively identified SVOC compound consisting of an unknown organic was also
present at a concentration of 4 ppb.

In summary, contaminants detected in surface water samples have been limited to acetone,
present in one sample at a level of 9 ppb, inorganic phenol at 5.6 ppb, one tentatively
identified VOC at 8 ppb and one tentatively identified SVOC at 4 ppb. No chemical-specific
ARARs/TBCs were identified as being applicable to these contaminants; therefore, no formal
comparison is made herein.

Additional characterization of the South Branch in the vicinity of Area B is being conducted
under a study managed by the U S Fish and Wildlife Service, as described in Section VI(B).

VI. SUMMARY OF SITE RISKS

A baseline risk assessment was conducted based upon the results of the El for Area B to
estimate the potential risks associated with current and future land uses. The baseline risk
assessment estimates the human health and ecological risks which could result from contamination
at the site if no remedial action was taken. A summary of the Human Health Risk Assessment
(HHRA) and Ecological Risk Assessment (ERA) is presented below. A more complete description can
be found in the Draft Final Risk Assessment, Area B, Navy Fire Test Facility (TRC, October
1994).

A. Human Health Risk Assessment

The HHRA consisted of a four-step process to assess the potential site-related human health
risks under both current and potential future exposure scenarios. The four-step process included
hazard identification, exposure assessment, toxicity assessment, and risk characterization and
is summarized below. Constituent release mechanisms from the environmental media, based on
relevant hydrologic and hydrogeologic information (fate and transport and other pertinent
site-specific information), were also presented in the HHRA.

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Hazard Identification

The hazard idenlification involved the selection of the constituents of concern (COCs),  the
detected constituents which have inherent toxic/carcinogenic effects that are likely to pose the
greatest concern with respect to the protection of human health. The COCs for Area B were
chosen for the media of interest (surface soil, subsurface soil and ground water)  based upon the
detection freguency of the constituents and, for inorganics in soil only, based upon a
comparison to background data. The COCs selected in the Area B HHRA are listed in Table 1.
Sediment data were not included in the HHRA due to the low concentrations detected and the low
potential for FAA workers to come into contact with the sediments.

Exposure Assessment

The exposure assessment identified the potential pathways and routes for COCs to reach
potential receptors, estimated the constituent concentrations at the points of exposure,  and
characterized the extent of the potential exposures.

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                                                       TABLE 1
                                   CONSTITUENTS OF POTENTIAL CONCERN
                                        AREA B - NAVY FIRE TEST FACILITY
                                                 FAA TECHNICAL CENTER
10  SURFACE SOIL
                                 14  SUBSURFACE SOIL
                                                                             27  GROUND WATER
      INORGANICS
       Arsenic
       Cadmium
       Chromium
       Copper
        Lead
        Zinc
INORGANICS
 Arsenic
 Chromium
 Copper
 Lead
 Mercury
 Zinc
6  INORGANICS
    Arsenic
    Chromium
    Copper
    Lead
    Mercury
    Zinc
      SEMIVOLATILES
       Di- n- butyl phthaiate
       Trichlorobenzene,  1,2,4-

      PESTICIDES
       DDE,  4,4'-
       DDT,  4,4'-
   1 VOLATILES
      Toluene

  4 SEMIVOLATILIES
   Bis(2-ethylhexyl)phthaiate
   Butylbenzylphthaiate
   Di-n-octylphthalate
   Naphthalene

   2  PESTICIDES
      DDE,  4,4'-
      DDT,  4,4'-

   1  PCBs
      Aroclor 1242
      14  VOLATILES
          Acetone
          Bromochloromethane
          Chloroform
          Dichloroethane,  1,1-
          Dichloroethene,  1,1-
          Dichloroethene,  l,2-(cis)
          Dichloropropane,  1,2-
          Ethylbenzene
          Methylene chloride
          Tetrachloroethene
          Toluene
          Trichloroethane,  1,1,1-
          Trichloroethene
          Xylene (total)

       4  SEMIVOLATILES
          Methylnaphthalene,2-
          Methylphenol, 4-
          Naphthalene
          Phenol
                                                                                3  PESTICIDES
                                                                                   DDE, 4,4'
                                                                                   DDT, 4,4'
                                                                                   Heptachlor epoxide

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Current and anticipated future uses of Area B were evaluated. The current and future receptor
populations were characterized as being essentially limited to government employees. Currently,
Area B is not widely used by FAA employees either for work or recreational purposes, and there
is no current use of ground water at Area B. However, incidental exposure could occur as a
result of activities such as atypical work assignments which could reguire the presence of a
person at the site. Therefore, under the current FAA worker scenario, adult government employees
were assumed to be exposed through ingestion of and dermal contact with COCs in surface soils.
Specifically, FAA employees were modeled as being exposed to surface soils for 10 days/year, as
a result of activities such as atypical work assignments which could reguire the presence of a
person at the site, over a period of 25 years (representative of career length at one location).
These exposures could potentially involve contact with soil, which is modeled by a soil
ingestion rate of 50 milligrams (mg) per day and a dermal contact rate of 500 mg per day.

Since the use of Area B is not anticipated to change in the foreseeable future, adult government
employees were also identified as one of the future receptor populations. In the future use
commercial/industrial scenario, adult workers were modeled by a soil ingestion rate of 50 mg per
day, a soil dermal contact rate of 500 mg per day, and a ground water ingestion rate of 1 liter
of ground water per day, for 250 days per year over a period of 25 years. Future construction
workers were assumed to be exposed to COCs in subsurface soil through ingestion and dermal
contact. Specifically, workers exposed to subsurface soil (at depths of two to ten feet) were
modeled as potentially ingesting 480 mg of subsurface soil per day and receiving dermal contact
with 1,000 mg of subsurface soil per day for 250 days over a period of one year.

Exposure point concentrations (EPCs) were calculated for each COG based upon a statistical
method which uses a confidence interval (i.e., the 95% upper confidence limit or UCL) to
calculate a theoretical concentration from actual data, per EPA guidance. Use of this method
provides reasonable confidence that the true site average will not be underestimated. That is,
the probability that the actual average concentration on the site exceeds the calculated value
is estimated to be less than 5%. When few data points are available for statistical analysis
(e.g., less than 10 data points), the 95% UCL tends to be artificially inflated and exceeds the
maximum detected concentration. In these cases, the maximum detected value was used as the EPC
rather than the 95% UCL.

Toxicity Assessment

The toxicity assessment summarizes the types of adverse health effects associated with exposures
to each COG and the relationship between magnitude of exposure (dose) and severity of toxic
effect (response). The dose-response values used in the HHRA were obtained from the EPA's
Integrated Risk Information System (IRIS) database or EPA's Health Effects Assessment Summary
Tables (HEAST). The toxicity values used in the HHRA are summarized in Tables II 3-1, II 3-2 and
II 3-3 of the HHRA.

Cancer slope factors have been developed by EPA for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals. Slope factors, which are
expressed in units of I/(mg/kg-day) (i.e., risk per unit intake or dose), are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of
the excess lifetime cancer risk associated with exposure at that intake level. The term "upper
bound" reflects the conservative nature of the slope factor. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Slope factors generally are derived
from the results of human epidemiological studies or chronic animal bioassays.

Reference doses (RfDs) have been developed by EPA for indicating whether adverse health effects
from exposure to chemicals exhibiting noncarcinogenic effects may be of concern. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,

-------
including sensitive individuals, that are likely to be without an appreciable risk of adverse
health effects. Estimated intakes of chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs are derived
from human epidemiological studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not underestimate the potential for adverse'
noncarcinogenic effects to occur.

Risk Characterization

The risk characterization combines the estimates of exposure with the dose-response (or
toxicity) values to derive estimates of the potential cancer risks and to determine whether
non-cancer health effects may be a concern.

Excess lifetime cancer risks were determined for each COG by multiplying the estimated intake or
dose by the appropriate cancer slope factor. The resulting cancer risk estimates are expressed
as a probability (e.g., 1 x 10 -6 or one in a million) and indicate (using this example), that
an average individual is likely to have a one in a million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year lifetime under the specific
exposure conditions. Current EPA practice considers carcinogenic risks to be additive when
assessing exposure to a mixture of constituents. Thus, the COC-specific cancer risks were summed
to estimate pathway-specific cancer risks. The pathway-specific cancer risks were then summed to
estimate scenario-specific cancer risks.

The potential concern for noncarcinogenic effects of a single COG in a single medium was
determined through the use of the hazard guotient (HQ) (or the ratio of the estimated exposure
intake or dose to the RfD). The HQ is expressed in numeric form such that an HQ of 0.5, for
example, means that the estimated exposure intake or dose is half of the RfD. The HQs were then
summed across COCs and pathways to estimate pathway- and scenario-specific hazard indices (His),
respectively. In general, HQs are assumed additive for constituents with similar toxic
endpoints. The HI provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media with respect to
noncarcinogenic effects.

The estimated cancer risks and non-cancer His (Table 2) were evaluated using EPA's established
target cancer risk range of 10 -6 to 10 -4 for Superfund cleanups and the target HI value of
less than or egual to 1. The State of New Jersey's acceptable carcinogenic risk of 10 -6 was
also considered.

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                                                           TABIiE 2
                              SUMMARY OF CANCER RISKS AND NON-CANCER His FOR ALL SCENARIOS
                                              AREA B - NAVY FIRE TEST FACILITY
                                                      FAA TECHNICAL CENTER
       Pathway

Incidental ingestion of soil

Dermal contact with soil

Ingestion of ground water
                                                             CANCER RISKS
                            Totals:
                                            Scenario 1
                                            Current
                                            FAA Worker
  4 x 10 -8

        NA



4 x 10 -8
Scenario 2
Future
Constuction
      7 x 10 -7

      5 x 10 -8



     3 x 10 -7
Scenario 3
Future
Commercial/Industrial
     9 X 10 -7

         NA

       3 x 10 -5

       3 x 10 -5
     NON-CANCER His



       Pathway

Incidental ingestion of soil

Dermal contact with soil

Ingestion of ground water
Scenario 1
Current
FAA Worker
0.0003
0.000004
Scenario 2
Future
Construction
0.05
NA
                             Totals:     0.0003                             0.05

                                           = WITHIN 1 X 10-6 TO 1 X 10-4 CANCER RISK RANGE
                                     Scenario 3
                                      Future
                                     Commercial/Industrial
                                         0.006

                                         0.00009

                                           0.4

                                           0.4

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The results of the baseline risk assessment indicated that the surface soils, subsurface soils
and ground water at Area B pose an acceptable risk to human health under federal guidelines,
although the future commercial/industrial use scenario poses an unacceptable risk under state
guidelines due to the ground water ingestion pathway. The total carcinogenic risk associated
with the current use scenario for surface soil ingestion and dermal contact was estimated to be
4 x 10-8. The total carcinogenic risk associated with the future use construction scenario for
subsurface soil ingestion and dermal contact was estimated to be 8 x 10-7 . The total
carcinogenic risk associated with the future use commercial/industrial scenario for ground water
ingestion and surface soil exposures was estimated to be 3 x 10 -5, which exceeds the state's
acceptable risk guideline of 1 x 1 0-6. The risk value is attributable to the estimated risk
associated with the ingestion of ground water. Arsenic and methvlene chloride were the primary
contributors to the ingestion of ground water pathway risk. The total HI, which reflects
noncarcinogenic effects for a human receptor, was estimated to be 0.0003 for surface soil
ingestion and dermal contact under the current use scenario. Under the future use scenarios.
hazard indices were estimated to be 0.05 for subsurface soil ingestion and dermal contact
combined, and 0.4 for ground water ingestion and surface soil exposures combined.

B. Ecological Risk Assessment

The ERA consisted of a four-step process to assess site-related ecological risks- The four-step
process included problem formulation, exposure assessment, stressor-response assessment, and
risk characterization and is summarized below.

Problem Formulation

Problem formulation included relating the guantitative and spatial extent of constituents, to
key habitats to determine what receptors may be at greatest potential risk, scoping the approach
for assessing these risks, and selecting COCs for detailed analysis. Surface soils, sediments
and surface water were determined to be the media of most concern with respect to ecological
effects. Subsurface soil and ground water were not considered to be potential sources of
exposure to terrestrial receptors. Sediment data available at the time the ERA was conducted was
limited to a single sample. Additional sediment and surface water sampling being conducted as
part of a facility-wide ecological assessment by the U.S. Fish and Wildlife Service (USFWS)
under an Interagency Agreement between USFWS and the FAA will be used to further evaluate both
sediment and surface water guality. Therefore, while potential risks associated with sediments
and surface water were considered within the ERA, sediments and surface water are not
specifically addressed within this Record of Decision but will be evaluated as a separate
operable unit, as necessary, upon completion of the USFWS study.

The Area B surface soil COCs included trichlorobenzene, di-n-butylphthalate, DDT, DDE,
arsenic, cadmium chromium, copper, lead, and zinc. The sediment COCs included tetrachloroethene,
trichloroethene, benzo(a)pyrene, benzo(b)fluoranthene, chrysene, fluoranthene, phenanthrene,
pyrene, DDT, chromium mercury and zinc. Based on the lack of detection of analytes in the South
Branch surface water samples, no COCs were selected for this medium.

The respective ecological receptors (plant or animal species or habitat) modeled as potentially
being exposed to these COCs include the following:

• Deer mouse, due to its likely presence in the grassland portion of Area B, its ingestion
of insects and vegetation, and its consumption by higher order species;

• White-tailed deer, due to its documented presence at the FAA Technical Center and
herbivorous nature;

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•      Red fox,  due to its tendency to prey on small mammals and vegetation;

•      American woodcock,  due to its identification at the facility,  consumption of earthworms
       and small spatial range and its use as a surrogate for three protected species identified
       through a Natural Heritage Database Search for the immediate vicinity of Area B- the
       grasshopper sparrow (a state threatened species),  the vesper sparrow (a state endangered
       species)  and the upland sandpiper (a state threatened species);  and
•      Broad-winged hawk,  due to its consumption of small mammals,  amphibians, reptiles,  and
       occasionally young birds and its potential for experiencing biomagnification.

Exposure Assessment

The exposure assessment provides a determination of which pathways are most likely to produce
significant exposures to selected indicator species and the derivation of estimates of the daily
exposure dose indicator species would obtain from on-site COCs- Major exposure pathways that
were evaluated for the Area B indicator species included the following:

•      Deer mouse - dermal contact with soil and ingestion-of vegetation,  insects,  and soil;

•      White-tailed deer -dermal contact with soil and ingestion of vegetation and soil;

•      Red fox - dermal contact with soil and ingestion of deer mice,  vegetation,  and soil

•      American woodcock - dermal contact with soil and ingestion of earthworms and soil;

•      Broad-winged hawk - ingestion of deer mice and soil.

Stressor-Response Assessment

The stressor-response assessment reguires the development of an understanding of COG potency for
indicator species via a review of pertinent laboratory or field toxicity studies and the linking
of COG concentrations to potential effects on ecological receptors. The sensitive toxic effects
(e.g., developmental, neurological, etc.) on mammalian and avian receptors were considered for
each COG and benchmark doses were identified, typically based on the lowest observable adverse
effect level  (LOAEL) or no observable adverse effect level  (NOAEL)  pertinent to the indicator
species. For the evaluation of sediments, sediment guality criteria values at which risks to
benthic fauna are minimal were identified.

Risk Characterization

The risk characterization involves a comparison of exposure doses to benchmark doses to estimate
the potential for adverse effects. By dividing the exposure dose by the ecological benchmark
dose for a specific COG, the ecological hazard guotient  (EHQ) is calculated. An EHQ of less than
1 indicates minimal potential for ecological harm, an EHQ of between 1 and 10 indicates a low
potential for ecological effects, an EHQ of between 10 and 100 indicates a moderate potential
for ecological effects and an EHQ of greater than 100 indicates a significant potential for
ecological impacts. EHQ values are summed across COCs when exposure occurs within the same
receptor, although the assumption of additivity may not be appropriate in situations where the
type of toxic effect  (e.g., target organ) differs. The estimated EHQs for soil-related exposures
at Area B are summarized in Table 3 while the estimated EHQs for sediment exposures are
summarized in Table 4.

The results of the ERA indicate that Area B poses a generally low order of risk for terrestrial
receptors, with estimated risks below a level of concern  (EHQ of less than 1)  for deer, fox, and

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hawk, and slightly elevated above the low potential risk range (EHQ of 1 to 10) for mouse (EHQ =
12) and woodcock (EHQ = 11). Inorganics (cadmium and chromium, respectively) contributed the
most to the estimated risks for mouse and woodcock. For sediments, the risk assessment
identified a significant risk (EHQ = 170) to benthic communities due to the presence of DDT and
a low potential for ecological effects due to the presence of mercury. However, as previously
discussed, sediments will be addressed within a separate operable unit, as necessary, following
completion of USFWS studies.

C. Risk Summary

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare or the environment.

VII. REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment; they
specify the COCs, exposure route(s), receptor(s), and acceptable contaminant level(s) for each
exposure route. These objectives are based on available information and standards such as ARARs
and risk-based levels established in the risk assessment.

A Feasibility Study (FS) serves as the mechanism for the development, screening, and detailed
evaluation of remedial alternatives for all environmental media affected at a site. The FS for
Area B (TRC, 1995) established the objectives for remedial actions at Area B, as follows:

• Prevent exposure, due to ground water ingestion, to ground water contaminants which are
present at levels exceeding state and federal drinking water standards and New Jersey
Ground Water Quality Standards. Ground water remediation levels will be the more stringent
of state and federal drinking water standards and New Jersey Ground Water Quality
Standards.

• Prevent Migration and discharge of ground water contaniinants to the South Branch
of Doughty's Mill Stream and restore ground water guality; and

• Prevent exposure to and migration of free product contaminants from the vicinity of
well B-MW3S.

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                                                                   TABIiE  3
                               SUMMARY OF EHQS FOR SOIL-RELATED EXPOSURES
                                              TERRESTRIAL/AVIAN RECEPTORS
                                            AREA B - NAVY FIRE TEST  FACILITY
                                                      FAA TECHNICAL  CENTER
    COG                 Mouse

Inorganics
Arsenic                 0.82
Cadmium                 5 .5
Chromium                0.24
Copper                  2.0
 Lead                   1.3
 Zinc                   1.2

 Semi-Volatiles
 Di-n-butylphthalate    0.0042
 Tricholorobenzene      0.93
 Pesticides
 DDE                    0.045
 DDT                    0.11

 Total EHQ             12

 Bold sigruifies EHQ values > 1.
                                            Woodcock
  0.13
  2.1
  5.2
  1.0
  0.99
  0.18
 0.022
 1.6

 0.27
 0.035

11
                                                                    Deer
                        0.0098
                                                                                       Fox
                                         0.033
                                                                                                         Hawk
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
,00063
,0045
,00017
,0016
,001
,001
,0000032
,00074
,000085
,000035
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
,001
,0039
,00049
,0045
,0012
,020
,000011
,00075
,00063
,00038
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
.00072
.018
.033
.084
.0031
.50
.00022
.0055
.0057
.0036
                                                          0.66

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                                                       TABIiE 4
  Inorganics
 Chromium
 Mercury
 Zinc

 Volatile Organics
 Tetrachloroethene
 Trichloroethene

 Semi-Volatile Organics
 Benzo(a)pyrene
 Benzo(b)fluoranthene
 Chrysene
 Fluorantene
 Phenanthrene
 Pyrene

 Total PAHs

 Pesticides
 DDT
                                  SUMMARY OF EHQS FOR SEDIMENT EXPOSURES
                                            AREA B - NAVY FIRE TEST FACILITY
                                                FAA TECHNICAL CENTER

                             COG                       Sediment
                                                       Concentration A

                                                         3.4
                                                         0.98
                                                         9.6
                                                         0.002
                                                         0.007
                                                         0.11
                                                         0.22
                                                         0.14
                                                         0.31
                                                         0.16
                                                         0.17

                                                         1.11
                                                          0.16
                                                                                      SQC C
  0.15
120
0.4
4.0
16
50
47
9.0
2.6
19

4.0
                                                                                        0.001
Total Sediment EHQ

 A    Sediment concentrations expressed as mg chemical per kg sediment  (dry weight basis).

 B    Sediment guality criteria are in units of mg chemical per kg sediment  (dry weight basis)
        adjusted for the fraction organic carbon of South Branch sediments.
EHQ C

0.043
6.5
0.080
0.0050
0.28
0.0069
0.0044
0.0030
0.034
0.062
0.0090

0.28
                                                                                                         160

                                                                                                         170
C
      Bold signifies EHQ values > 1.

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VIII. DESCRIPTION OF THE ALTERNATIVES

CERCLA §121(b)(1), 42 U.S. C.§9621 (b)(1), mandates that a remedial action must be protective of
human health and the environment, be cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. Section 121(b)(1 ) also establishes a preference for remedial actions which employ,
as a principal element, treatment to permanently and significantly reduce the volume, toxicity,
or mobility of the hazardous substances, pollutants, and contaminants at a site. CERCLA §121
(d), 42 U.S.C. §9621 (d), further specifies that a remedial action must attain a level or
standard of control of the hazardous substances, pollutants, and contaminants which at least
attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA
§121(d)(4), 42 U.S.C. §9621 (d)(4).

The Area B FS (TRC, 1995) evaluated six remedial alternatives for addressing the volatile
organic ground water contamination associated with Area B. The remediation of other ground water
constituents detected at levels exceeding drinking water standards or New Jersey Ground Water
Quality Standards was not assessed within the FS due to the lack of confirmation of their actual
presence in subseguent sampling rounds or their presence in both on-site and upgradient
(background) monitoring wells. An initial screening of the six alternatives was conducted based
on the alternatives' effectiveness, implementability and cost. On the basis of the initial
screening, five alternatives were considered to provide the greatest degree of compliance with
the screening criteria and were retained for detailed analysis. Alternative 2, consisting of
well permit restrictions and capping, was eliminated because it is not effective in preventing
the migration of ground water contaminants. The remedial alternatives which were evaluated in
detail (Alternatives 1, 3, 4, 5 and 6) are described below. Included among these alternatives is
the no action alternative (Alternative 1).

Alternative 1 - No Action with Ground Water and Surface Water Monitoring

Capital Cost: $4,200
O&M Cost: $180,000
Present Worth Cost: $220,000
Construction Time: One month

The Superfund program reguires that the "no action" alternative be considered as a baseline for
comparison of other alternatives. The no action alternative involves no remedial actions to
reduce the toxicity, mobility or volume of contamination at Area B. The site would remain in its
present condition. Included in-this alternative is the installation of two additional shallow
monitoring wells on the south side of the South Branch and continued ground water and surface
water monitoring to identify, off-site migration of ground water contamination, should it occur.
Because this alternative would result in contaminants remaining on-site, CERCLA reguires that
the site be reviewed every five years. If justified by the review, remedial actions may be
implemented to remove or treat the hazardous substances.

Alternative 3 - Product/Ground Water Extraction, Product Treatment Off-Site (Incineration),
Ground Water Treatment On-Site(Air Stripping)

Capital Cost: $130,000
O&M Cost: $450,000
Present Worth Cost: $690,000
Construction Time: Eight months

Alternative 3 consists of the installation of two additional shallow monitoring wells on the
south side of the South Branch, continued ground water and surface water monitoring,

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installation and operation of product/ground water extraction wells, physical separation of
product and off-site transport for incineration, on-site ground water treatment by air
stripping, and discharge of treated water back into the shallow ground water. Because this
alternative would result in contaminants remaining on-site, CERCLA reguires that the site be
reviewed every five years. If justified by the review, remedial actions may be implemented to
remove or treat the hazardous substances.

Alternative 4 - Product/Ground Water Extraction, Product Treatment Off-Site  (Incineration),
Ground Water Treatment On-Site (LTV Oxidation)

         Capital Cost:  $310,000
         O&M Cost: $560.000
         Present Worth Cost: $1,000,000
         Construction Time: Twelve months

Alternative 4 consists of the installation of two additional shallow monitoring wells on the
south side of the South Branch, continued ground water and surface water monitoring,
installation and operation of product/ground water extraction wells, physical separation of
product and off-site transport for incineration, on-site ground water treatment by UV oxidation,
and discharge of treated water back into the shallow ground water. Because this alternative
would result in contaminants remaining on-site, CERCLA reguires that the site be reviewed every
five years. If justified by the review, remedial actions may be implemented to remove or treat
the hazardous substances.

Alternative 5 - Product/Ground Water Extractiom Product Treatment Off-Site (Incineration),
Ground Water Treatment On-Site (Cross-Flow Pervaporation)

     Capital Cost: $340,000
     O&M Cost: $730,000
     Present Worth Cost: $1,300,000
     Construction Time: Twelve to fifteen months

Alternative 5 consists of the installation of two additional shallow monitoring wells on the
south side of the South Branch, continued ground water and surface water monitoring,
installation and operation of product/ground water extraction wells, physical separation of
product and off-site transport for incineration, on-site ground water treatment by cross-flow
pervaporation, and discharge of treated water back into the shallow ground water. Based on the
innovative nature of the cross-flow pervaporation technology,  the availability of full-scale
treatment units is very limited and treatability studies would be reguired prior to
implementation. Because this alternative would result in contaminants remaining on-site, CERCLA
reguires that the site be reviewed every five years. If justified by the review, remedial
actions may be implemented to remove or treat the hazardous substances.

Alternative 6 - In Situ Treatment (Air Sparging/Vapor Extraction)

    Capital Cost: $510,000
    O&M Cost: $450,000
    Present Worth Cost: $1,200,000
    Construction Time: Twelve to fifteen months

Alternative 6 consists of the installation of two additional shallow monitoring wells on the
south side of the South Branch, continued ground water and surface water monitoring,
installation and operation of an air sparging/vapor extraction system and associated monitoring
probes, and on-site vapor treatment (if necessary).  The air sparging/vapor extraction system

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would volatilize and remove both free product contamination and dissolved ground water
contaminants, thereby providing an alternative means of product remediation. Due to the
inconsistent detection of a separate product layer observed during the El,  in situ treatment may
be more effective than separate phase extraction in removing the product from the subsurface.
Unlike pump-and-treat alternatives involving separate phase extraction where product residuals
could remain in the soil following product removal, thereby acting as a continued source of
ground water contamination and extending the operational period of a treatment system, the air
sparging/vapor extraction system would be effective in removing product residuals and therefore
could result in a shorter remedial time-frame. However, additional information on the flow
dynamics of air through the saturated and unsaturated zones would be reguired prior to the
design and implementation of an air sparging/vapor extraction system. If design studies indicate
that separate phase product recovery is feasible and would accelerate the cleanup of the
product, product extraction and off-site incineration would be incorporated as a component of
this alternative. Because this alternative would result in contaminants remaining on-site,
CERCIA reguires that the site be reviewed every five years. If justified by the review, remedial
actions may be implemented to remove or treat the hazardous substances.

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IX.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The five alternatives identified in Section VIII were initially evaluated on the basis of
technical effectiveness and feasibility, public health and environmental effects, institutional
issues, and costs, as presented in the Feasibility Study. Subsequently these alternatives were
also evaluated using the criteria derived from the National Contingency Plan (NCP) and the
Superfund Amendments and Reauthorization Act of 1986  (SARA), as presented in the Proposed Plan.
These criteria relate to the SARA amendment to Section 121 of CERCLA  [Section 121(b)(1) ]  and
Section 300.430 (e) (9) (iii) of the NCP and are as follows:

•      Overall protection, of human health and the. environment addresses whether or not a remedy
       provides adequate protection and describes how risks posed through each pathway are
       eliminated, reduced, or controlled through treatment, engineering controls, or
       institutional controls.

•      Compliance with applicable or relevant and appropriate requirements (ARARs) addresses
       whether or not a remedy will meet all of the applicable or relevant and appropriate
       requirements of other federal and state environmental statutes and requirements or provide
       grounds for invoking a waiver.

•      Long-term effectiveness and permanence refers to the ability of a remedy to maintain
       reliable protection of human health and the environment over time, once cleanup goals have
       been met.

•      Reduction of toxicity,  mobility,  or volume through treatment is the anticipated
       performance of the treatment technologies a remedy may employ.

•      Short-term effectiveness addresses the period of time needed to achieve protection and any
       adverse impacts on human health and the environment that may be posed during the
       construction and implementation period until cleanup goals are achieved.

•      Implementability is the technical and administrative feasibility of a remedy, including
       the availability of materials and services needed to implement a particular option.

•      Cost includes estimated capital and operation and maintenance costs,  and net present worth
       costs.

•      State acceptance indicates whether, based on its review of the EI/FS reports and Proposed
       Plan, the State concurs, opposes, or has no comment on the preferred alternative at the
       present time.

•      Community acceptance refers to the public's general response to the alternatives described
       in the Proposed Plan and the EI/FS reports. Factors of community acceptance to be
       discussed include support, reservation,  and opposition by the community.

A comparative analysis of these alternatives based upon the evaluation criteria noted above
follows.

Overall Protection of Human Health and the Environment

Alternatives 3, 4, 5, and 6 each provide a significant degree of protecion of human health and
the environment through their active ground water and product treatment processes. Although
subsurface soil contaminant levels do not exceed ARARs or TBCs, treatment of product residuals
in the subsurface soils is offered under Alternative 6, versus Alternatives 3,  4, and 5,  where

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product residuals may remain in the subsurface soil following product removal and could be a
continuing source of ground water contamination. Therefore, Alternative 6 provides the greatest
overall protection of human health and the environment by treating ground water and product
residuals. Of the pump-and-treat alternatives (Alternatives 3, 4, and 5), Alternative 3 provides
the greatest overall protection of human health and the environment through its demonstrated
ability to treat the ground water contaminants. Alternative 1 provides the least overall
protection of human health and the environment because it does not eliminate, reduce, or control
the contaminated media.

Compliance with ARARs

Alternatives 3, 4, 5, and 6 would each be designed and operated with the intent of meeting
volatile organic drinking water and ground water guality standards. Chemical-specific ARARs
for VOCs in ground water are considered to be achievable for Alternatives 3, 4, 5, and 6.
Alternative 3 is most likely to achieve these reguirements based on the proven nature of the air
stripping technology. A greater degree of uncertainty is associated with the ability of
Alternatives 4 and 5 to meet these reguirements due to Alternative 4's reduced effectiveness in
treating single-bonded hydrocarbons and the innovative nature of Alternative 5. A degree of
uncertainty is also associated with the ability of Alternative 6 to provide uniform treatment
throughout the aguifer, due to its in situ nature. Alternatives 3, 4, 5, and 6 would each be
designed and operated in accordance with action-specific ARARs. Alternative 1 would not attain
chemicall-specific. ARARs for contarminants detected in ground water due to the lack of
product/ground water treatment. For all of the alternatives, compliance with the appropriate
location-specific wetland and floodplain regulati6ns would be reguired.

Long-Term Effectiveness and Permanence

Alternative 6 results in the least residual, untreated hazardous substances, due to its
potential for providing treatment of product residuals in the subsurface soils and the general
lack of treatment system residuals associated with its operation, and is considered to offer the
greatest potential for long-term effectiveness and permanence. Alternatives 3, 4 and 5 are also
expected to provide good long-term effectiveness with respect to ground water treatment. The air
stripping technology of Alternative 3 offers the greatest degree of certainty with respect to
long-term effectiveness and permanence, due to the proven nature of its treatment technology and
its lack of treatment residuals. Alternative 1 offers no protection against contaminated ground
water migration and therefore is not considered to be effective in the long-term.

Reduction in Toxicity, Mobility, or Volume

Alternative 6 provides the greatest potential reduction of toxicity, mobility, or volume
through the treatment of the floating product and its residuals, and treatment of the ground
water.

Alternative 6 reduces the contaminants' mobility and toxicity through the air sparging/vapor
extraction system, and includes an off-gas treatment system if necessary to comply with ARARs,
Alternatives 3, 4 and 5 provide a reduction in contamination similar to Alternative 6, except
for the product residuals within the subsurface soils, which are not addressed. The ground water
treatment technologies reduce the toxicity and volume of contamination while product extraction
and incineration reduce the toxicity of the floating product. Alternative 1 provides no
reduction in toxicity, mobility or volume of any contaminated media through treatment.

Short-Term Effectiveness

The no action alternative can be considered to be effective in the short-term because it

-------
involves no remediation and, therefore, no disturbance of existing contamination or increased
short-term risks. However, while no increases in risk result in the short-term, remedial
response objectives are not achieved. For alternatives that involve site remediation,
Alternative 3 provides the greatest short-term effectiveness, providing a means of complying
with remedial action objectives within a short time frame with minimal risk incurred.
Alternative 4 also would be relatively effective in the short-term although LTV oxidation
treatment systems are not as widely available as air strippers and, therefore, the time reguired
for implementation could be longer. Alternatives 5 and 6 reguire the longest implementation
period, due to the need for treatability testing and additional site characterization prior to
implementation. The additional time reguired for implementation of Alternative 6 could
potentially be offset by a shorter operation and maintenance period, due is ability to treat
product residuals in the soils.

Implementability

Alternative 1 is the most implementable of the alternatives due to the very limited site
activities associated with its implementation. Ground water monitoring well installation and
ground water and surface water sampling are all easily implemented. Alternative 3 is the most
easily implemented alternative which involves remediation of the product and ground water
because it utilizes readily available and well-proven treatment technologies. Alternatives 4 and
6 would follow in terms of implementability, due to the increasingly innovative nature of the
technologies involved and more limited availability of vendors who provide the technology.
Alternative 5 would be the most difficult alternative to implement, due to the lack of readily
available full-scale treatment systems and the need for treatability studies prior to start-up.

Cost

Total present worth cost estimates for alternative implementation range from $220,000 to
$1,300,000- The lowest cost alternative is the no action alternative ($220,000) with Alternative
3 being the next costly alternative to implement ($6,90,000). Alternatives 4, 5 and 6 cost
$1,000,000, $1,300,000 and $1,200,000, respectively, to implement.

In terms of capital cost, Alternative 1 is lowest in cost, with Alternatives 3, 4, 5 and 6
following in order of increased capital costs. Capital costs range from $4,200 for Alternative 1
to $510,000 for Alternative 6. Alternative 1 also offers the lowest present worth operation and
maintenance (O&M) cost ($180,000). Alternatives 3 and 6 are comparable in terms of present
worth O&M cost, each estimated at $450,000. Alternatives 4 and 5 offer increasing higher present
worth O&M costs, at $560,000 and $730,000, respectively.

State Acceptance

The selected remedy and contingency remedy, as discussed in the following section, are
acceptable to NJDEP.

Community Acceptance

Based upon the concerns and comments received during the public comment period and public
meeting, the community accepts the preferred alternative as presented in the Proposed Plan.
Public concerns and comments are presented in the Responsiveness Summary of this ROD.

X. SEIiECTED REMEDY

Based upon an evaluation of the various alternatives, the FAA, in consultation with the EPA, has
selected Alternative 6 as the Area B ground water remedy, with Alternative 3 as a

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contingency remedy. Alternative 6 consists of the installation of two additional shallow
monitoring wells on the south side of the South Branch, continued ground water and surface water
monitoring, installation and operation of air sparging wells, vapor extraction wells, and
monitoring probes, and on-site vapor treatment (if necessary).  Additional site-specific studies
must be conducted to further define the applicability of this technology to subsurface
conditions at Area B. If pre-design studies indicate that separate phase product recovery would
be implementable in combination with air sparging/vapor extraction and would accelerate the
cleanup process, product extraction and off-site incineration would be incorporated as a
component of this alternative. Pre-design will also include the performance of two rounds of
ground water sampling at wells B-MW2S and B-MW5S for inorganic analyses to further investigate
the potential of elevated inorganics levels at these two locations and to supplement the
existing inorganic ground water data base. If pre-design studies indicate that air sparging/
vapor extraction is not suitable for implementation at the site due to subsurface conditions or
is not likely to meet ARARs, Alternative 3 is the selected contingency remedy. Alternative 3
consists of the installation of two additional shallow monitoring, wells on the south side of
the South Branch, continued ground water and surface water monitoring, installation and
operation of product/ground water extraction wells, physical separation of product and off-site
transport for incineration, on-site ground water treatment by air stripping, and discharge of
treated water back into the shallow ground water. Additional pre-design studies would be
reguired to support the design of Alternative 3 and would reguire approximately four additional
months to complete. If the additional pre-design ground water sampling indicates that inorganic
treatment is necessary to meet ARARs, it will be incorporated as a component of the contingency
remedy.

The selected alternative is protective of human health and the environment based on the active
remediation of product and ground water contamination and the ability of the treatment system to
provide treatment of any product residuals in the soil. Its treatment technologies are expected
to meet final remediation goals. Because of its potential for treating product residuals, it is
also expected to achieve remedial goals in a shorter time frame than a pump-and-treat
alternative. The alternative is also effective in the short-term, based on its use of readily
available materials. It is expected to be effective and permanent in the long-term, based on the
proven nature of the basic air stripping technology which is applied in situ in air sparging,
and based on the potential treatment of product residuals within the soil. However, until
additional site-specific studies are conducted to further define the applicability of this
technology to the subsurface conditions at Area B, there is a degree of uncertainty associated
with the alternative's long-term effectiveness in terms of its ability to provide uniform
treatment. The alternative utilizes treatment to reduce the mobility and toxicity of the product
and contaminated ground water. It also utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. While Alternative 6 is one of the more costly
alternatives, it is considered to be cost-effective based on the added degree of overall
protection of human health and the environment that it offers through its treatment of
subsurface residuals and shorter remedial time frame.

The selected alternative will provide the best balance of trade-offs among alternatives with
respect to the evaluation criteria. The FAA, in consultation with the EPA, believes the selected
alternative will be protective of human health and the environment, will comply with ARARs, will
be cost effective, and will utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable.

If Alternative 6 is determined to be unsuitable for application at Area B based on further
investigations of subsurface conditions and their effect on the implementation of an air
sparging/vapor extraction system, Alternative 3 will be employed as a contingency remedy. Since
Alternative 3 utilizes the same basic treatment technology applied ex situ rather than in situ,
it is expected to offer a similar degree of effectiveness in treating ground water contaminants.

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It is more easily implemented than the other ground water treatment technologies, better proven
in terms of its ability to treat the contaminants of concern and the most cost-effective of the
remaining treatment technologies.

The selected alternative for soil is no action. Soil contaminant levels do not exceed New
Jersey non-residential sod cleanup criteria (TBCs) and no significant human health and
environmental risks are associated with exposures to site soils. Therefore, it has been
determined that the soils are protective of human health and the environment.

XI. STATUTORY DETERMINATIONS

Under Section 121 of CERCLA and Section 300-430(f) of the NCP, selected remedies must
meet certain statutory and regulatory reguirements. These reguirements and a description of how
the selected remedy and contingency remedy satisfy each reguirement are presented below.

Protection of Human Health and the Environment

The selected remedy provides the greatest overall protection of human health and the environment
by providing in situ treatment of ground water contamination and free product. The treatment
system would be designed to comply with applicable ARARs/TBCs, would have minimal short-term
risks associated with its installation and operation, and would be effective and reliable in the
long-term although the ability of the alternative to maintain cleanup goals will only be
confirmed through long-term monitoring. Due to the innovative nature of the treatment
technology, and the variation in subsurface conditions at Area B, additional site-specific
studies will be reguired to address the present degree of uncertainty with regard to the
performance of the treatment system. The selected remedy is expected to be effective and
permanent in the long-term, based on the proven nature of the basic air stripping technology
which is applied in situ in air sparging, and based on the potential treatment of product
residuals within the soil. It is effective in the short term, utilizing a proven treatment
technology which is readily implemented. Additionally, its long-term effectiveness and
permanence are expected to be good.

If the selected remedy is determined to be unsuitable for application at Area B based on
further investigations of subsurface conditions, the contingency remedy will be employed. Since
the contingency remedy utilizes the same basic treatment technology as the selected remedy
(applied ex situ rather than in situ), it is expected to offer a similar degree of effectiveness
in treating ground water contaminants. It is more easily implemented than the other ground water
treatment technologies, better proven in terms of its ability to treat the contaminants of
concern and the most cost-effective of the remaining treatment technologies.

Compliance with ARARs

The selected remedy or the contingency remedy, if implemented, will attain the more stringent of
state and federal drinking water standards and New Jersey Ground Water Quality Standards. A
summary of applicable chemical-specific, location-specific and action-specific ARARs and TBCs is
presented in Table 5. Table 6 presents numerical chemical-specific ARAR values.

Pursuant to NJAC 7:9-6.5(d)(2), ground water at the FAA Technical Center is classified as
Class I-PL (Protection Area). Pursuant to NJAC 7:9-6.7(b)(2), the ground water guality criteria
for Class I-PL (Protection Area) shall be background water guality, as that term is defined in
NJAC 7:9-6.4. The NJDEP and Pinelands Commission recognize that technical limitations exist for
measuring compliance with such criteria. While the inorganic constituents listed in Table 6 have
been detected in the Area B background monitoring well, the nine organic constituents listed in
Table 6 have either not been detected in background ground water at the FAA Technical Center or

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have been detected at concentrations which are lower than the relevant practical quantitation
level (PQL),  as that term is defined in NJAC 7:9-6.4, for each constituent. The background water
quality for each of these constituents is, therefore, lower than the relevant PQL for each.

Pursuant to NJAC 7:9-6.9(c), where a constituent standard is of a lower concentration than
the relevant PQL,  NJDEP shall not consider a discharge to be causing a contravention of the New
Jersey Ground Water Quality Standards for that constituent so long as the concentration of the
constituent in the affected ground water is less than the relevant PQL for the constituent. The
relevant PQLs for each of the nine organic constituents in ground water of concern at the FAA
Technical Center are listed in Table 6.

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                               TABIiE 5

                APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS  (ARARs)
                      AND TO-BE-CONSIDERED CRITERIA (TBCs)
                       APPLICABLE TO THE SELECTED REMEDY
                       AREA B - NAVY FIRE TEST FACILITY
                            FAA TECHNICAL CENTER

CHEMICAL- SPECIFIC ARARS  (Also see Table 9)

•      Safe Drinking Water Act
      Maximum Contaminant Levels  (MCLs) [40 CFR 141.11-.16, and 141.60 -.63]
      Federal maximum permissible contaminant levels allowable for public water systems;
      applicable to the remediation of ground water

       NJ Safe Drinking Water Act
      NJ Maximum Contaminant Levels [NJAC 7:10-5.1-5.3]
      State maximum permissible contaminant levels allowable for public water systems;
       applicable to the remediation of ground water

       NJ Water Pollution Control Act
      NJ Ground Water Quality Standards [NJAC 7:9-6.7(c)]
      State-designated levels of constituents which, when not exceeded, will not prohibit or
      significantly impair a designated use of water.  Pursuant to NJAC 7:9-6.5(d)(2), ground
       water at the FAA Technical Center is classified as  Class I-PL (Protection Area).  Pursuant
       to NJAC 7:9-6.7(d)(2),  the ground water guality criteria  for Class I-PL (Protection
       Area)  shall be background water guality,  as that term is defined in NJAC 7:9-6.4. The
       NJDEP and Pinelands Commission recognize that technical limitations exist for measuring
       compliance with such criteria.  The nine organic constituents listed-in Table 6 have
       either not been detected in background ground water at the FAA Technical Center or have
       been detected at concentrations which are lower than the relevant practical  guantitation
       level (PQL),  as that term is identified in NJAC 7:9-6.4, for each constituent. The
       background water guality for each of these constituents is,  therefore, lower than the
       relevant PQL. Pursuant to NJAC 7:9- 6.9(c), where a constituent standard is  of a lower
       concentration than the relevant PQL, NJDEP shall not consider a discharge to be causing a
       contravention of the New Jersey Ground Water Quality Standards for that constituent so
       long as the concentration of the constituent in the affected ground water is less than the
       relevant PQL for the constituent. The relevant  PQLs for each of the nine organic
       constituents in ground water of concern at Area B of the FAA Technical Center are listed
       in Table 6.

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                                     TABIiE 5 (Continued)

                 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS  (ARARs)
                         AND TO-BE-CONSIDERED CRITERIA  (TBCs)
                          APPLICABLE TO THE SELECTED REMEDY
                          AREA B - NAVY FIRE TEST FACILITY
                                FAA TECHNICAL CENTER

LOCATION-SPECIFIC ARARS

•      Safe Drinking Water Act
      Protection of Ground Water Use for Potable Water Supply [40 CFR 149]
      Protects aquifers designated as sole source aguifers from actions by federally-funded
      programs

       Executive Order 11990
      Protection of Wetlands
      Regulates activities conducted in a wetland area to nuinimize the destruction, loss or
      degradation of the wetlands
      Wetlands Construction and Management Procedures (40 CFR 6, Appendix A)
      Sets forth EPA policy for carrying out the provisions of Executive Order 11990

       Clean Water Act
      Section 404, Prohibition of Wetland Filling
      Prohibits the discharge of dredged or fill material to a wetland without a permit issued
       by the Corps of Engineers

•      New Jersey Freshwater Wetlands Protection Act
      Regulation of Activities in and around Wetlands (NJSA 13:9B)
      Provides for the classification of freshwater wetlands and establishes permit requirements
       for activities which impact freshwater wetlands.

•      New Jersey Freshwater Wetlands Regulations (NJAC 7:7)
      Rules Governing Implementation of Wetlands Protection Act
      Regulates alteration or disturbance in and around freshwater wetland areas

       Executive Order 11998
      Flood Plains Management (40 CFR 6, Appendix A)
      Restricts types of activities which may be conducted within a floodplain to minimize harm
       and preserve natural values

•      New Jersey Flood Hazard Regulations
      General Standards and Procedures  (NJAC 7:13; 2-3)
      Standards and procedures for permitting stream encroachment activities.

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                        TABIiE 5  (Continued)

            APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS  (ARARs)
                    AND TO-BE-CONSIDERED CRITERIA  (TBCs)
                     APPLICABLE TO THE SELECTED REMEDY
                     AREA B - NAVY FIRE TEST FACILITY
                         FAA TECHNICAL CENTER

LOCATION-SPECIFIC TBCs

•      Pinelands Comprehensive Management Plan (NJAC 7:50)
      Establishes standards and requirements pursuant to  the Pinelands Protection Act designed
       to promote orderly development of the Pinelands so as to preserve and protect the
       resources of the Pinelands, including wetland, ground water and air resources, among
       others.

ACTION-SPECIFIG ARARS

       Clean Air Act
      New Source Performance Standards  (40 CFR 50)
      Requires Best Available Control Technology  (BACT) for new sources and sets emissions
      limitations

       Clean Air Act
      National Emissions Standards for Hazardous Air Pollutants  (40 CFR 6 1)
      Establishes emissions limitations for hazardous air pollutants

•      New Jersey Air Pollution Control Regulations
      Permits and Emissions Limitations for VOCs  (NJAC 7:27-16)
      Requires sources which emit VOCs be registered and permitted with the NJDEP and meet
      maximum allowable emissions rates and design specifications.

•      NJ Water Supply Management Act
      Well Drilling Permits [NJSA 58:4A-14]
      Well Certification Forms  [NJAC 7:8-3.11]
      State regulations governing the drilling and construction of new wells

•      New Jersey Water Pollution Control Act
      New Jersey Pollutant Discharge Elimination System Permit/Discharge Requirements  [NJAC
      7:14A-2.1]
      State standards for discharges to ground water  (applicable to contingency remedy only)

•      Resource Conservation and Recovery Act (RCRA)
      Identification and Listing of Hazardous Waste  [40 CFR 261]
      Waste classification procedures applicable to the characterization of any waste materials
      generated as a result of vapor treatment,  if determined to be necessary

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                           TABLE 5  (Continued)

      APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS  (ARARs)
                 AND TO-BE-CONSIDERED CRITERIA  (TBCs)
                  APPLICABLE TO THE SELECTED REMEDY
                  AREA B - NAVY FIRE TEST FACILITY
                        FAA TECHNICAL CENTER

 RCRA
Standards Applicable to Generators of Hazardous Waste  [40 CFR 262]
Requirements for manifesting, marking and reporting applicable to generators of hazardous
waste; applicable if vapor treatment wastes are generated, determined to be hazardous and
transported off-site

 RCRA
Standards Applicable to Transporters of Hazardous Waste  [40 CFR 263]
Procedures for off-site shipment of hazardous materials or wastes; applicable if vapor
treatment wastes are generated, determined to be hazardous and transported off-site

 Hazardous Materials Transportation Act
Rules for Transportation of Hazardous Materials [49 CFR 171 through 179]
Procedures for off-site shipment of hazardous materials or wastes; applicable if vapor
treatment wastes are generated, determined to be hazardous and transported off-site

 NJ Solid Waste Management Act
NJ Hazardous Waste Regulations [NJAC 7:26-8.5]
Waste classification procedures applicable to the characterization of any waste materials
generated as a result of vapor treatment, if determined to be necessary

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                                                                TABIiE  6
                                                 CHEMICAL-SPECIFIC ARARS APPLICABIiE  TO
                                                           THE SELECTED REMEDY
                                                    AREA B - NAVY FIRE TEST FACILITY
                                                           FAA TECHNICAL CENTER

                                                          Federal
                                                        ARARS  (ppb)
                                                  State
                                       ARARS  (ppb)
        Ground Water
         Parameter

     Chlorobenzene
     1, 1 -Dichloroethene
     Ethylbenzene
     Methylene Chloride
     Toluene
     Tetrachloroethene
     1, 1, 1 -Trichloroethane
     Trichloroethene
     Xylene  (total)

     Chromium
     Lead
     Mercury
     Zinc
MCL  (1)
      7
    700

  1,000
      5
     20
      5
 10,000

    100
     15
      2
NJMCL (2) Background[PQL]
        1
       26
        1
       44
                                                         GWQS  (3)
[2]
[2]
[5]
[2]
[5]
[1]
[1]
[1]
[2]

21.5
25
 0.6
64.5
     (1) MCL - Maximum Contaminant Level. National Primary Drinking Water  Regulations,  Final  Rule

     (2)  Maximum Contaminant Level for Drinking Water; NJ Safe Drinking Water Act,  NJAC  7:10-16.7

     (3)  Ground Water Quality Standards; based on Class I-PL(Protection Area),  ground  water  quality criteria shall be the background ground
water quality. Values without brackets represent background groundwater quality as  defined by well  B-MW1S.  As discussed in the associated text,
when the background water quality is lower than the Practical Quantiltation  Level  (PQL),  a discharge will  not contravene the standard so long
as the concentration of the constituent is less than the relevant PQL. Therefore for constituents which have not been detected in background
ground water or which were detected at concentrations which are lower  than the  POL, the  POL   is listed in  brackets.

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The regulations established under the Clean Air Act, the New Jersey Air Pollution Control
Regulations and the New Jersey Water Supply Management Act will apply to the implementation
of this alternative. If the contingency remedy is employed, compliance with the Clean Water Act
and the New Jersey Pollutant Discharge Elimination System regulations will also be maintained.
Resource Conservation and Recovery Act regulations and New Jersey regulations regarding the
identification, generation, transportation and, management of hazardous waste have been included
as ARARs to address potential waste matenials which could be generated as a result of vapor
treatment, if determined to be necessary. Under both the selected remedy and the contingency
remedy, compliance with the Pinelands Protection Act, including the Pinelands Comprehensive
Management Plan, a TBC, and the appropriate federal and state location-specific wetland and
floodplain regulations will be reguired due to the location of the facility within the Pinelands
and the presence of delineated wetland areas and the 100-year floodplain in the vicinity of the
South Branch of Doughty's Mill Stream.

Cost-Effectiveness

While the selected remedy is one of the more costly alternatives, it is considered to be
cost-effective based on the added degree of overall protection of human health and the
environment that it offers through its potential treatment of subsurface product residuals and
shorter remedial time frame. Due to the relatively innovative nature of air sparging/vacuum
extraction, published treatment costs are not widely available. However, costs can be estimated
based on the previously provided assumptions. If, based on the completion of pilot-scale
studies, design parameters change from those assumed above, the estimated cost could also vary.

The contingency remedy is also cost-effective, providing effective treatment at a slightly
lower cost than the other alternatives considered.

Utilization of Permanent Solutions and Alternative Treatment Technologies

The FAA, in cooperation with the EPA, has determined that the selected remedy and the
contingency remedy utilize permanent solutions and treatment technologies to the maximum extent
practicable, This determination was made based on the comparative evaluation of alternatives
with respect to long-term effectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, short-term effectiveness, implementability, and cost, as well as the
statutory preference for treatment as a principal element and state and community acceptance.

The main difference between the remedial alternatives which underwent evaluation is
associated with the type of product/ground water treatment utilized. The selected alternative
provides in situ treatment of product/ground water and offers potential in situ treatment of
product residuals. Therefore, it is expected to result in the achievement of remedial goals in a
shorter time frame than a pump-and-treat alternative in which no residual treatment would occur.
The removal of subsurface contamination is permanent. Therefore, the selected remedy's
anticipated long-term effectiveness, reduction of toxicity, mobility or volume through treatment
and short-term effectiveness were the most decisive factors in its selection. However, until
additional site-specific studies are conducted to further define the applicability of this
technology to the subsurface conditions at Area B, there is a degree of uncertainty associated
with the alternative's long-term effectiveness in terms of its ability to provide uniform
treatment, thereby warranting the consideration of a contingency remedy.

The contingency remedy, should it be employed, offers the best combination of long-term
effectiveness, short-term effectiveness, implementability and cost of the remaining alternatives
considered. The air stnipping technology included within the contingency remedy is well-proven
and easily implemented while also being cost-effective. The alternative utilizes treatment to
reduce the mobility and toxicity of the product and contaminated ground water. It also utilizes

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permanent solutions and alternative treatment technologies to the maximum extent practicable.

Preference for Treatment as a Principal Element

The selected remedy and the contingency remedy address the principal threat which is
associated with the presence of hydrocarbon product containing hazardous substances and
contaminants in the ground water at levels which present unacceptable risks to human health
under NJDEP risk criteria. Through the active remediation of product and ground water
contamination, the remedies are expected to meet final remediation goals.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Proposed Plan for Area B was released for public comment on April 11, 1996. The
Proposed Plan identified Alternative 6, In Situ Treatment (Air Sparging/Vapor Extraction)  as the
preferred remedy for Area B ground water. Alternative 3, Product/Ground Water Extraction,
Product Treatment Off Site (Incineration), and Ground Water Treatment On Site  (Air Stripping)
was selected as a contingency remedy. The FAA received no written or verbal comments on the
Proposed Plan, either during the public meeting or the subsequent 30-day comment period.
Conseguently, it has been determined that no significant changes to the remedy, as originally
identified in the Proposed Plan, are necessary.

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                               RESPONSIVENESS SUMMARY
                                 RECORD OF DECISION
                          Area B - Navy Fire Test Facility
                                FAA Technical Center

The purpose of this Responsiveness Summary is to review public response to the Proposed Plan
for Area B.  It also documents the FAA.'s consideration of such comments during the decision-
making process and provides answers to any major comments raised during the public comment
period.

The Responsiveness Summary is divided into the following sections:

•      Overview - This section briefly describes the selected remedy and any changes to the
       remedy from that included in the Proposed Plan for Area B.

•      Background on Community Development - This section provides a summary of community
       interest in Area B and identifies key public issues.  It also describes community relations
       activities conducted with respect to this area of concern.

•      Summary of Major Questions and Comments - This section summarizes verbal and written
       comments received during the public meeting and public comment period.

I .   OVERVIEW

The FAA Technical Center is located at the Atlantic City International Airport in Atlantic
County, New Jersey. Area B is located near the former sewage treatment plant location at the
south end of the built-up area in the western portion of the FAA property. This Responsiveness
Summary addresses public response to the Proposed Plan for Area B only. The Proposed Plan and
other supporting information for Area B are available for public review at the Atlantic County
Library, 2 South Farragut Avenue, Mays Landing, New Jersey.

II.   BACKGROUND ON COMMUNITY INVOLVEMENT

This section provides a brief history of community participation in the Environmental
Investigation/Feasibility Study  (EI/FS) activities conducted at Area B.

Throughout the investigation period, the EPA, NJDEP, Atlantic County Department of Health  and
the Pinelands Commission have been directly involved through proposal and project review and
comments. Periodic meetings have been held to maintain open lines of communication and to keep
all parties abreast of current activities.

On April 11, 1996, a newspaper notification was published in theAtlantic City Press inviting the
public to comment on the EI/FS process and Proposed Plan. The announcement also identified the
time and location of a public meeting to be held to discuss the proposed remedial action, the
location of the information repository, the length of the public comment period, and the address
to which written comments could be sent. Public comments were accepted from April 11 through May
10,  1996.

A public meeting was held on May 2, 1996 at the Atlantic County Library in Mays Landing, New
Jersey. The Area B EI/FS results were discussed. FAA representatives included Keith C. Buch,
Program Manager, Howard Kimpton, Super-visor, Environmental Section, and Gary E. Poulsen,
Manager, Facility Engineering and Operations Division. Betsy Donovan, Remedial Project Manager,
Federal Facilities Section represented the EPA Emergency and Remedial Response Division, and Ian
Curtis, Case Manager, represented the NJDEP Bureau of Federal Case Management Sean Clancy

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represented the Atlantic County Health Department. TRC Environmental Corporation, FAA's
environmental contractor, also attended. The complete attendance list is provided as Appendix
to this Record of Decision. A transcript of the public meeting is provided as Appendix C.

III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS

No questions or comments with regard to the Proposed Plan for Area B were raised at the
public meeting held on May 2, 1996. In addition, no written comments were received during the
thirty-day public comment period following the public meeting.

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APPENDIX A

NJDEP AND PINELANDS COMMISSION
IiETTERS OF CONCUBEENCE

September 6, 1995
Mr. Keith Buch, COTR
FAA Technical Center
Environmental Programs Branch
Building 270, Room A117
Atlantic City International Airport, NJ 08405

Please Always Refer To
This Application Number

RE: App. No. 87-1058.17
Block 3A, Lot 2
Area B
FAA Technical Center
Egg Harbor Township

The commission has received and reviewed a copy of the Revised Draft Final Proposed Plan
regarding the remediation of soils and groundwater for Area B at the FAA Technical Center. The
proposed alternative for soils is no action. The proposed remedial alternative (identified as
Alternative 6) for groundwater involves the installation of two additional monitoring wells on
the south side of the South Branch, continued ground water and surface water monitoring,
installation and operation of air sparging wells, vapor extraction wells, and monitoring probes,
and on-site vapor treatment. The proposed plan indicates that the effectiveness of the proposed
system will be assessed after it is operational and if necessary, an alternate remedial action
will be implemented. The final plan or the ROD should specify the criteria that will be
considered to determine whether on alternate remedial action is needed. Those criteria must
include compliance with the standards of the Pinelands Comprehensive Management Plan.

The Proposed Plan does not raise any significant issues regarding compliance with the minimum
standards of the Pinelands Comprehensive Management Plan. The remedial design must also comply
with the applicable reguirements of the CMP. The following information should be provided in
order for the Pinelands Commission to determine whether the remedial design will comply with the
applicable standards of the CMP:

1. A completed Pinelands Application (form enclosed) for the proposed groundwater
remediation.

2. Provide a plan indicating the final remedial design, limits of disturbance, and the
limits of wetlands on and within 300 feet of the project area.

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     3.  Any linear development in wetlands or wetland buffers must meet the criteria outlined
         in N.J.A.C. 7:50-6.13 (enclosed).  Linear devalcpment would include access roads or
         piping necessary for the remedial  design. If any other development will be located in
         wetlands or wetland buffers,  or if groundwater pumping will significantly alter the
         water table in the wetlands,  it must be demonstrated that the proposal will be consis-
         tent with the standards of the Pinelands CMP relating to a Waiver of Strict Compliance
         based on a compelling public need  (N.J.A.C.  7:50-4.64 et seg).  These standards will
         reguire a determination that no better alternatives to the proposed exist and a
         determination that the proposal, when evaluated in its entirety,  will result in an
         overall improvement of the Pinelands Area.

     4.  If the proposed remedial design will result in the disturbance of any fresh water
         wetlands it will be necessary to obtain a State Fresh Water Wetlands Permit. The
         Pinelands Commission is authorizing Statewide General Permits on behalf of the NJDEP in
         the Pinelands Area. If it is determined that the proposed project will reguire a Permit
         we will advise you of the reguirements to complete a General Permit Application.

If you have any guestions,  please contact our development review staff.

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April 30, 1996

Ian Curtis
NJDEP, Bureau of Federal Case Management
CN 028
401 East State Street
Trenton, NJ 08625-0028

Please Always Refer To
This Application Number

RE: App. No. 87-1058.17
Block 3A, Lot 2
Area B
FAA Technical Center
Egg Harbor Township

Dear Mr. Curtis:

The Commission staff has received and reviewed the April, 1996 Superfund Proposed Plan regarding
the remediation of soils and groundwater for Area B at the FAA Technical Center.

The plan identifies the preferred alternative as alternative 6 and indicates that the
effectiveness of this alternative will be re-assessed after the system is operational. As our
previous letters have indicated, the criteria for assessing the effectiveness should be
specified in the Final Plan or Record of Decision ROD). Those criteria must include compliance
with the standards of the Pinelands Comprehensive Management Plan.

The remedial design must also comply with the applicable standards of the Pinelands
Comprehensive Management Plan. Please refer to our September 6,1995 letter (enclosed) regarding
Commission application reguirements for the proposed remedial design.

If you have any guestions, please contact our development review staff.

Encl(l): September 6, 1995 letter

cc: Keith Buch
Jean Oliva (with enclosure)

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                                   APPENDIX B
                          PUBLIC MEETING ATTENDANCE LIST

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                                    APPENDIX C
                           PUBLIC MEETING TRANSCRIPT

                                                                                     Page 2
1                                                                                    INDEX

2   Opening Remarks and Introductions                                                Page 3
      Keith C. Buch, Program Manager
3    FAA Technical Center

4    Environmental Investigation                                                     Page 5
      Overview (Areas 29 and K)
5    Larry Butlien, Project Hydrogeologist
      TRC Environmental Corporation
6
       Risk Evaluation and Feasibility                                               Page 12
7     Study Overview and Presentations
       of Proposed Plan (Areas 29 and K)
8     Jean M. Oliva,.P.E., Project Engineer
       TRC Environmental Corporation
9

10    Environmental Investigation                                                    Page 15
        Overview  (Area B)
11     Larry Butlien

12     Risk Evaluation and Feasibility                                               Page 22
         Study Overview and Presentation
13     of  Proposed Plan  (Area B)
         Jean M.  Oliva, P.E.
14
         Final Remarks                                                               Page 26
15     Keith C. Buch

16     Questions and Answers                                                         None

17

18

19

20

21

22

23

24

25

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1   Tape #CP-4-96,  Index #0025 at 2:00 p.m.)

2                   MR.  BUCK:  Hello.  My name is Keith Buch.  I'm the

3   FAA-Superfund Program Manager,  and welcome to today's public

4     hearing for Area 29 and Area B. The public hearing was duly

5     advertised in the Press of Atlantic City as requirea by the

6     Superfund regulations.  We expect that after today's public

7     hearing to have a finalized rod within -- how many days,

8     Jean?

9                    MS. OLIVA:   About ninety to a hundred and twenty.

10                  MR.  BUCH:   Okay.   And at that point we'll proceed

11   with the final designs for the cleanup of both Area 29 and

12   both Area B. I'd like at this point to turn the meeting over

13   to our technical experts from TRC who have been here at the

14   FAA Tech Center since 1986 performing all the necessary

15   remedial investigations  and feasibility studies and designs

16   that are reguired to effectuate a proper Superfund Cleanup.

17   I'd like to introduce Jean Oliva from TRC and Larry Butlien

18   from there. I'll let Larry explain the hydrogeological

19   background of the Area 29 and K Superfund Cleanup. Larry,

20   would you please.

21   MR. BUTLIEN: Certainly.  As Keith mentioned,  my

22    name is Larry Butlien and I'm the Project Hydrogeologist from

23    TRC for the FAA project. I'd first like to very briefly

24    present a history of how the Tech Center became involved in

25    environmental investigation.

   5-2-96

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                         Page 4
1         In 1980 and 1981 contamination was found at the

2   Price's Pit Landfill.  This contamination also affected the

3   Atlantic City well field which was located adjacent to

4   Price's Pit. Price's Pit is a Superfund site which is

5   located about three to four miles east-southeast of the

6   Technical Center. In 1981 the New Jersey Department of

7   Environmental Protection (NJDEP)  and the Atlantic City

8   Municipal Utility Authority (ACMUA)  hired Roy F. Weston to

9   conduct a study to relocate the well field.  As a result of

10  this study the Technical Center was-selected as the best

11  location for the new Atlantic City well field. Between 1983

12  and 1984, Weston, through the New Jersey DEP, identified five

13  areas within the Technical Center boundaries which might

14  present a potential pollution impact to the new well field.

15  Weston confirmed the presence of the pollutants and the New

16  Jersey DEP issued a consent order to the Technical Center to

17  perform the remedial investigation/feasibility study. In

18 1986 the FAA contracted with TRC Environmental Corporation

19  to perform a remedial investigation/feasibility study of the

20  Technical Center grounds. As part of the contract a complete

21  background investigation of the Technical Center was

22  reguired. A total of twenty-five areas of concern have been

23  identified by the FAA and the U.S. Environmental Protection

24 Agency (USEPA) that reguire evaluation.

25 All the work that TRC has performed has been in

  5-2-96

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                        Page 5
1    accordance with all applicable federal and state

2    environmental laws, statutes and regulations.  The FAA has

3    worked closely with USEPA,  the New Jersey DEP,  Atlantic

4    County Health Department, and the Pinelands Commission. Each

5     step of the investigative process has been reviewed and

6     approved by these organizations and no work has been

7     conducted until all necessary approvals were received.

8                                (SLIDE PRESENTATION)

9            The meeting this afternoon will focus on the

10    proposed plan for three areas: Area 29, the Fire Training

11    Area; Area K, the Storage Area near Area 29;  and Area B, the

12    Navy Fire Test Facility. Each area will be discussed

13    separately; Areas 29 and K will be discussed initially

14    followed by Area B. I will discuss the background

15    information and the results of the remedial investigation for

16    each area, while Jean Oliva will discuss the risk evaluations

17    conducted for each area and then will summarize the remedial

18    alternatives for each area.

19         Area 29 is located northeast of the Atlantic City

20    International Airport runways, with Area K located adjacent

21    to Area 29. This slide also shows the locations of Area B

22    and other areas of concern at the Technical Center.

23    Area 25 -- excuse me. Area 29 is referred to as

24    the Fire Training Area. This area was constructed in the

25    early 1970's and was used to train airport fire fighting

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                        Page 6
1      personnel.  The area contains a 150 foot-diameter burn pad

2      and a smaller concrete burn pad where test burns were

3      conducted.  The area also contained two underground storage

4       tanks for the collection of run-off from the burn pads and

5       two above ground tanks located on a small hill. The two

6       underground tanks were emptied,  removed,  and disposed of

7       off-site in an environmentally acceptable manner in December

8        of 1988.   Area K, referred to as the Storage Area near Area

9        29, is located across the dirt road from the burn areas at

10      Area 29.  This area was used for the storage of drums and

11      tanks and it was reported that the drums were removed off-

12      site in an environmentally acceptable manner from the area by

13      the Fall of 1986.

14           This next slide shows the general layout of Areas

15       29 and K. Area 29's . boundaries are generally outlined by the

16        triangular shaped dirt roads in the area.  As you can see, at

17        the center of Area 29 is the circular burn pad with the

18        smaller concrete burn pad located to the north. The two

19        former underground storage tanks that collected the burn pad

20        run-off were located to the east of the small burn pad. The

21        two above ground -- the two above ground tanks located on the

22        small hill is in the western.portion of the site. Area K is

23        located northwest of Area 29 on the northwest side of the

24        northeast-southwest trending dirt road.

25                       This is a photo -- this is a photograph taken

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                        Page 7
1     recently from the small hill looking northeast along the

2     dirt road.   The small concrete burn pad is in the center of

3      the photograph and Area X is located on the far left-hand

4      side of the photo.

5                 This is a photograph taken recently from the small

6      hill looking east toward the large circular burn pad,  and

7      note the current conditions showing standing water in the

8      middle of the burn pad.

9                  This is an older photograph taken in 1988 that

10    shows the small concrete burn pad.

11                This photo was also taken in 1988 showing one of

12     the underground storage tanks used for the collection of the

13     burn pad run-off. This particular tank collected the burn

14     pad (sic)  from the large circular burn pad and had a ten

15     thousand gallon capacity. As you can see, this tank was

16     open-ended on the top.

17                This is a photograph taken in December of 1988

18     immediately after the ten thousand gallon tank was removed

19     from the ground.

20                This final photograph shows the above ground tanks

21     located on the small hill. The photo was taken on the west

22     side of the hill looking toward the east.

23                The goal of the environmental investigations at

24     Areas 29 and K was to determine if past site activities

25     resulted in contamination of the site's soils and/or ground

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                        Page 8
1      water. The initial investigation was conducted by Roy F.

2      Weston in 1983 as part of the Atlantic City well field

3      relocation study. During this initial investigation,  Weston

4      installed and sampled three ground water monitoring wells of

5      which one exhibited significant levels of organic compounds.

6                 TRC's Phase I investigation at Areas 29 and K

7      during 1987 included preliminary investigations including a

8      a soil gas and a geophysical investigation. In addition,  a

9      total of sixteen surface soil samples were collected, four

10    soil borings were drilled, two monitoring wells were

11    installed, and a total of five ground water samples

12    collected. Phase I analytical results indicated significant

13    levels of organic compounds in the soils and perched ground

14    water at the site. Specifically, polychlorinated biphenyls

15    (PCBs) and total petroleum hydrocarbons (TPH)  were identified

16    in the soils while volatile organic compounds (VOCs)  were

17    detected in the perched water table aguifer.

18               This next slide shows the locations of all the

19    Phase I sampling locations including the surface soil

20    samples, soil borings and monitoring well locations.

21               During 1988 TRC conducted a Phase II investigation

22    of Areas 29 and K. The purpose of this investigation was to

23    further define the lateral extent of PCB contamination in the

24    surface soils and to determine if contamination existed

25    beneath the two underground storage tanks. These goals were

  5-2-96

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                        Page 9
1      accomplished by collecting a total of seven surface soil

2      samples and eight subsurface soil samples at the base of the

3      tank excavations. As mentioned earlier,  the two underground

4      tanks were removed during the Phase II investigation. The

5      Phase II results further defined the lateral extent of PCB

6      contamination in the surface soils while elevated levels of

7      TPH were detected in the soils beneath the ten thousand

8       gallon storage tank.

9                 This next slide shows the locations of the Phase II

10     surface soil samples. Four subsurface soil samples were

11     collected from the base of each of the two underground tanks.

12               Additional ground water monitoring at Area 29 was

13     conducted in December of 1991 and a program of guarterly

14     ground water monitoring was implemented at the site starting

15     in May 1993 and is still ongoing today.  The purpose of the

16     additional ground water monitoring was to determine if

17     perched ground water contamination has migrated into the

18     underlying true water table aquifer.

19               The results of the various investigations at Areas

20     29 and K have identified a zone of perched ground water

21     across the site, in addition, soil and ground water

22     contamination has been identified at levels greater than

23     current soil cleanup criteria and ground water gual.ity

24     standards. Specifically, PCB contamination has been detected

25     in the site's surface and subsurface soils. TPH

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                        Page 10
1       contamination was also identified in the subsurface soils.

2       And finally,  VOC contamination has been identified in the

3       perched ground water aguifer above ground water guality

4       standards. Results from the guarterly ground water sampling

5       program have not identified contaminated ground water within

6       the true water table aguifer at levels above ground water

7       guality standards.

8                This slide shows locations of soil contamina --

9       where soil contamination exceeds the current soil cleanup

10     criteria. Specifically, the areas include surface soils

11     contaminated with PCBs in the immediate vicinity of Area K,

12     the area surrounding the small concrete burn pad, and within

13     the large circular burn pad. The maximum PCB level detected

14     in the surface soils was thirty parts per million (ppm).  TI

15     NJDEP soil cleanup criteria for PCBs is two parts per

16     million.  The other area of soil contamination is at the

17     location of the former ten thousand gallon underground

18     storage tank.  At this location the maximum level of TPH

19     contamination was fourteen thousand ppm. The NJDEP soil

20     cleanup criteria for total or ganics is ten thousand ppm.

21             As mentioned earlier, during the environmental

22     investigations at Area 29, a zone of perched ground water was

23     identified across the site. This perched zone was identified

24     as underlying a significant portion of Area 29 including the

25     circular and concrete burn pads. This slide represents a

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                        Page 11
1       schematic geologic cross-section of Area 29 showing the

2       relationship between the perched and true water table

3       aguifers. As you can see,  the perched water table is

4       situated above the true water table and is relatively limited

5       in lateral and vertical extent.  The perched ground water is

6       formed where the soil in the unsaturated zone is locally

7       saturated because it overlies a low-permeability silty clay

8       or clayey silt zone situated above the true water table.

9       During the investigation the clay unit was identified as

10     being variable in thickness ranging between two and sixteen

11     feet thick with the surface of the clay unit found at a depth

12     of ten to fourteen feet below the ground surface. While

13     ground water flow in the regional true water table aguifer

14     was determined to be toward the east-southeast,  the flow of

15     perched ground water was estimated to be much more variable

16     due to localized changes in the slope of the surface of the

17     clay unit.

18             This slide represents an approximation of the

19     aerial extent of ground water contamination in the perched

20     zone where ground water guality standards have been exceeded.

21     Ground water results from monitoring well 29-MW2S have

22     consistently exhibited VOCs above ground water guality

23     standards, while exceedances of ground water gualities

24     standards have been more sporadic and periodic in monitoring

25     well 29-MW3S.

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                        Page 12
1               This slide represents a contour map and ground

2       water flow direction of the true'water table aguifer.  As

3       stated earlier,  the ground water flow direction in the true

4       water table aguifer is toward the east-southeast direction as

5       represented by contouring the water level elevations in the

6       wells screened in the true water table aguifer.

7               I would now like to turn the presentation over to

8       Jean Oliva of TRC. She will summarize the risk evaluation

9       and the remedial action objectives associated with Areas 29

10     and Area K.

11             MS. OLIVA: Thank you,  Larry. As Larry mentioned,

12     my name is Jean Oliva and I'm a project engineer with TRC

13     Environmental Corporation and I have been involved in

14     feasibility study activities at the FAA Technical Center

15     since 1989.

16                              (SLIDE PRESENTATION CONTINUED)

17             Based on the results of the site investigations,  a

18     human health risk assessment was conducted to evaluate

19     potential   risks associated with exposures to soil and ground

20     water. Ground water ingestion was evaluated even though

21     there is no drinking water well currently located at Areas 29

22     or K. The risk estimated for ground water ingestion was

23     above acceptable limits indicating that a remedial response

24     is appropriate. A gualitative assessment of ecological risks

25     also identified a potential risk to wildlife.

   5-2-96

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                        Page 13
1               Based on the results of the risk assessment and the

2       site investigation,  objectives were developed for a remedial

3       response as listed here.  In general these objectives include

4       preventing exposures to contaminants in soil and ground water

5       and minimizing the potential migration of these contaminants.

6       Based on these objectives,  a feasibility study was conducted.

7               This slide highlights the elements of a feasibility

8       study.  Initially,  remedial  technologies are identified and

9       screened to determine which technologies are most appropriate

10     for use at the site.  The selected technologies are then used

11     to develop remedial alternatives which are evaluated based on

12     nine criteria defined in the federal regulations.

13             The alternatives that were developed for Areas 29

14             and K include a no-action alternative which must

15             be considered based  on federal regulations. The

16             second alternative involves the placement of a cap

17             over contaminated soils which would address

18             potential exposures  to the soils but would not

19             address ground water contamination. The next two

20             alternatives involve ground water extraction and

21             treatment in combination with soil excavation and

22             off-site disposal. The first of the two

23             alternatives involves air stripping in which ground

24             water contaminants are transferred to the vapor

25             phase. The second of the two alternatives involves

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                        Page 14
1               carbon adsorption in which the ground water

2               contaminants are transferred to a carbon filter

3               media. The last two remedial alternatives employ

4               in situ,  or in-place, remedial actions which do not

5               involve ground water extraction.  They would also

6               be combined with soil excavation and off-site

7               disposal.  The first of the two in situ remedial

8               alternatives uses processes similar to air

9               stripping but applies them below ground to remove

10             contaminants from the ground water.  The second

11             alternative uses microbes to break down the ground

12             water contamination.

13             Each of the remedial alternatives underwent a

14     detailed evaluation based on the nine criteria listed here.

15     The alternatives and their evaluations are described in more

16     detail in the proposed plan. Compliance with the last

17     criterion community acceptance will be determined based on

18     is public comments which I'll discuss in more detail later in

19     this presentation.

20             Based on the detailed analysis of the remedial

21     alternatives, a preferred remedy was selected for Areas 29 and

22     K. The preferred remedy consists of ground water extraction

23     and treatment using carbon adsorption in combination with

24     soil excavation and off-site disposal as well as the

25     establishment of a Declaration of Environmental Restrictions

  5-2-96

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                       Page 15
1       to ensure that future residential site development does not

2       occur.   This alternative offers the greatest overall

3       protection of human health in the environment through its

4       off-site disposal of contaminated soils and its ability to

5       treat the ground water contaminants.  It is also cost-

6       effective and meets regulatory reguirements.

7                     I will now turn the presentation back to Larry

8       Butlien of TRC who will describe the investigations that

9       were conducted at Area B,  the Navy Fire Test Facility.

10     Larry.

11                   MR. BUTLIEN:  Thanks, Jean.

12                                (SLIDE PRESENTATION CONTINUED)

13                   First I want to just talk briefly about the

14     background information and the results of the remedial

15     investigation at Area B.

16                   Area B is located in the southwestern portion of

17     the FAA Technical Center property. The South Branch of

18     Doughty's Mill Stream is located along the southern portion

19     of the area. Area B is located approximately forty-five

20     hundred feet upstream of the Upper Atlantic City Reservoir.

21     This slide also shows the locations of Area 29 and K, and

22     other areas of concern relative to Area B.

23                   Area B is referred to as the Navy Fire Test

24     Facility. The area was used during the late 1950's and early

25     1960's for aircraft fire training. A review of historical

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                        Page 16
1       aerial photographs indicates that the highest level of

2       activity occurred between 1957 and 1962.  During this time

3       frame aircraft and sections of aircraft were located

4       throughout the area and portions of the area's ground

5       exhibited dark-colored stains. By 1965 the area had been

6       grassed over.  A portion of the area was later used for GSA

7       motor pool parking. Today a majority of Area B is grass-

8       covered with a heavily wooded area in the souther portion of

9       the site along the stream.

10             This next slide shows the general layout of Area B.

11     Shown are the approximate limits of the Navy Fire Test Area

12    and then the smaller area showing the GSA Motor Pool parking

13    location. Also note the South Branch of Doughty's Mill

14    Stream along the southern portion of the area and that the

15    and also the location of the former wastewater treatment

16    plant which was closed and demolished in 1992.

17             This photo was taken in 1988. It shows the

18    southern portion of the site. I'm sorry. This photo was

19    taken in 1987 from the northern portion of Area B looking

20    southwest toward the wastewater treatment facility. Note the

21    dirt road which essentially separates Area B into the

22    northern and southern halves, and also note that the area is

23    generally an open grassy field.

24             This next photo was taken in 1988 and shows the

25    southern portion of the site. The South Branch of Doughty's

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                        Page 17
1      Mill Stream is located immediately behind the front edge of

2      the wooded area.  Also note one of the site's monitoring

3      wells which is located adjacent to the stream.

4               The goal of the environmental investigations at

5      Area B was to determine if past site activities resulted in

6      contamination of the site's soils and ground water. TRC has

7      conducted a number of environmental investigations that are

8      at Area B dating back to 1987. TRC's Phase I investigation

9      at Area B included preliminary investigations such as soil

10    gas surveys and a geophysical investigations. In addition,  a

11     total of five surface soil samples,  four soil borings,  and

12    four subsurface soil samples were collected.  In addition,

13    one stream sediment and surface water sample  was collected

14    from the South Branch and three monitoring wells were

15    installed at the site.

16             The next slide shows locations of all the Phase I

17    sampling locations including surface soil samples, soil

18    borings and the one sediment/surface water sampling.

19             During 1988, TRC conducted a Phase II investigation

20    of Area B. The purpose of this investigation  was to further

21    define the lateral extent and chemical nature of a floating

22    product layer which had been identified in monitoring well

23    B-MW3S following the Phase I investigation. These goals were

24    accomplished by drilling a total of twelve soil borings

25    within seventy-five feet of the well. Organic vapor

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                        Page 18
1      headspace readings were measured in the soil samples

2      collected from each soil boring. Elevated readings were

3      plotted to determine the lateral extent of the subsurface

4      contamination associated with the floating product. In

5      addition, a sample of the floating product was collected and

6      was determined to be similar to gasoline. Finally, a sample

7      of ground water beneath the floating product was collected

8      and analyzed and it determined to exhibit elevated levels of

9      VOCS.

10             This next slide shows the locations of the Phase II

11    soil borings drilled in the vicinity of well MW3S.  It also

12    shows the approximate extent of the floating product based on

13    the elevated headspace readings. Also note the direction of

14    shallow ground water flow toward the southeast, which is

15    is toward the South Branch.

16             During 1989 TRC conducted a supplemental

17    investigation. The purpo se of this investigation was to

18    further define the subsurface soil guality in the area of the

19    floating product. This was accomplished by drilling two soil

20    borings and collecting three subsurface soil samples for

21    chemical analysis. The results of the soil testing did not

22    indicate any exceedance of federal or state soil standards.

23             This next slide shows the locations of the

24    supplemental investigation soil borings drilled adjacent to

25    well MW3S.

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                        Page 19
1               A number of additional investigations were

2      conducted at Area B to determine the source of the

3      contamination and to further delineate the nature and extent

4      of ground water contamination at the site. During August of

5      1992 a HydroPunch study was conducted and focused on areas of

6      stained soils and aircraft staging areas that were visible in

7      the historical aerial photographs. A total of ten HydroPunch

8      locations were sampled in which shallow ground water was

9      collected. The results of this study did not identify a

10    source of the floating product.

11             The next investigation occurred in January of 1993

12    and included the installation of two additional monitoring

13    wells, downgrading of well MW3S to further define the nature

14    and extent of dissolved ground water contamination. These

15    wells were sampled during February and May of 1993 and

16    determined to contain several chlorinated VOCs at levels

17    above federal and state ground water guality standards.

18             During July of 1993 a Geoprobe investigation was

19    conducted to further define the extent of the floating

20    product as well as the nature and extent of dissolved ground

21    water contamination up gradient and down gradient of well

22    MW3S. A total of twenty-six Geoprobe ground water samples

23    were collected during this investigation. The results of the

24    Geoprobe samples resulted in the installation of four addi-

25    tional monitoring wells,  one located up gradient, one side

   5-2-96

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                        Page 20
1      gradient,  and two down gradient of well 3S.  In addition,  one

2      subsurface soil sample was collected and analyzed from each

3      of the new monitoring well soil borings. The results of this

4      investigation further defined the extent of the floating

5      product and the nature and extent of the dissolved ground

6      water contamination plume.

7               Lastly,  a program of guarterly ground water and

8      surface water monitoring was implemented at Area B starting

9      in February of 1993 and is still ongoing. The purpose of the

10    monitoring was to determine trends in the dissolved ground

11    water contamination, evaluate the South Branch surface water

12    guality adjacent to the site, and to measure the product

13    thickness in well MW3S.

14                                        (POSTER BOARD)

15             I would like to now direct your attention to the

16    poster board -- I'll move it a little closer. This poster

17    board basically shows the colored areas which represent the

18    historical ground scars and stained soils that were

19    indicated from the aerial the historical aerial

20    photographs. Shown on this poster are all the environmental

21    investigations that have been conducted during the Phase I

22    and Phase II supplemental in the HydroPunch investigation.

23    The HydroPunch investigation focused on areas within or down

24    gradient of the stained soil area as represented by these

25    black symbols here, and this generally just gives you kind of

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                        Page 21
1      a general overview of the historical site use with -- like I

2      said,  of the ground stains and stars,  and also shows airplane

3      fuselage locations relative to the various investigation

4      sampling locations.

5                         (SLIDE PRESENTATION CONTINUED)

6               This next slide shows the locations of the twenty-

7     six Geoprobe ground water samples and the four new monitoring

8     wells associated with the investigation.  Also shown is the

9     updated approximation of the lateral extent of the floating

10   product plume in the vicinity of MW3S.

11             This next slide identifies the locations of the

12   three wells and the three surface water sampling stations

13   sampled during the ongoing guarterly ground water sampling

14   areas.

15             The results of the various investigations at Area B

16   have identified a zone of contaminated ground water at levels

17   exceeding federal and state ground water guality standards.

18   in addition,  a plume of floating product has been identified

19   in the southern portion of the site. The floating product

20   has been identified as being similar to gasoline and as

21   measured in MW3S has ranged in thickness between zero and

22   eight inches. The aerial dimensions of the product plume are

23   approximately sixty feet long by twenty-five feet wide. The

24   major dissolved ground wdter contaminants exceeding the

25   ground water guality standards include aromatic and

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                        Page 22
1     chlorinated VOCs.  However,  no specific contaminant source

2     area or areas have been identified during the various

3     investigations at Area B.

4               This shows the aerial extent of ground water

5     contamination where the ground water guality standards have

6     been exceeded. As you can see, this area is in the southern

7     portion of the site immediately north of the stream.

8               I would now like to turn the presentation back over

9     to Jean who will summarize the risks associated with the

10   contamination found at Area B, and also summarize the

11   remedial action objectives associated with the site.

12             MS. OLIVA: Based on the results of the site

13   investigations at Area B, a human health risk assessment was

14   conducted to evaluate potential risks associated with

15   exposures to the soil and ground water. Again, ground water

16   ingestion was evaluated even though a drinking water well

17   does not exist at Area B. The risk estimated for ground

18   water ingestion was above acceptable limits, indicating a

19   remedial response is appropriate. A guantitative assessment

20   of ecological risks also identified a potential risk to

21  wildlife.

22             Remedial objectives were developed for a remedial

23  response as listed here. The objectives include preventing

24  exposures to both the floating product and the ground water

25  contamination and minimizing the potential migration of these

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                        Page 23
1    contaminants.  Based on these objectives a feasibility study

2    was conducted.

3               The Area B Feasibility Study used the same

4    technology evaluation and alternative development process

5    which was used for the Areas 29 and K Feasibility Study.

6               The remedial actions developed for Area B include

7               the no action alternative; there are three

8               alternatives in which floating product and ground

9               water -- and ground water would both be extracted

10             with the product treated off-site and the ground

11             water treated on-site using various technologies.

12             As I mentioned for Areas 29 and K,  the air

13             stripping alternative, which is the first of these

14             three alternatives, utilizes a technology which

15             transfers ground water contaminants to the vapor

16             phase.  The second of the three alternatives uses

17             ultraviolet, or UV, oxidation where contaminants

18             are destroyed by exposing them to ultraviolet light

19             in the presence of oxidizers. The last of the

20             three alternatives includes cross-flow

21             pervaporation, a technology which uses a selective

22             membrane that allows certain organic compounds  to

23             pass through the membrane and be separated from the

24             water phase. The last remedial alternative

25             involves in situ treatment in which the floating

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                        Page 24
1               product and ground water would be treated without

2               being extracted from the ground.  The air

3               sparging/vapor extraction technology uses processes

4               similar to air stripping but applies them below

5               ground to remove the contaminants.

6               Each of the remedial alternatives underwent a

7    detailed evaluation based on the nine Superfund criteria

8    and,  again,  public comments will provide the basis for

9    determining compliance with the last criterion community

10  acceptance.

11             Based on the detailed analysis of the remedial

12  alternatives,  no action is the preferred remedy for Area B

13  soils. For ground water at Area B,  a preferred remedy and a

14  contingency remedy were selected. The preferred ground water

15  remedy consists of in situ treatment to the ground water

16  using air sparging and vapor extraction.

17             I wanted to describe the-air sparging treatment

18  system. In air sparging treatment,  air is injected beneath

19  the water table using an air sparging well. As the air

20  bubbles move upward to the soil, ground water and any

21  floating product which may be present, they strip away the

22  volatile contaminants. The air with the contaminants is then

23  extracted using a vapor extraction well and,  if necessary, is

24  treated before being released. Additional testing needs to

25  be conducted at Area B to ensure that the subsurface

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                        Page 25
1    conditions are appropriate for the use of this technology.

2               In the event that this preferred alternative is  not

3    appropriate for use at Area B, then the contingency remedy

4    will be employed. And the contingency remedy consists of

5    floating products and ground water extraction with off-site

6    incineration of the floating product and air stripping of the

7    contaminated ground water.

8               In an air stripping system the extracted ground

9    water is allowed to flow down over packing material to a

10  stripping tower as air is blown countercurrent to the

11  direction of the water flow. As the air passes over the

12  water it strips away the volatile contaminants and they're

13  released through the top of the air stripper.

14             Both the preferred ground water remedy and the

15  contingency remedy are protective of human health in the

16  environment because they both treat the floating product and

17  the ground water contaminants. Since the contingency remedy

18  utilizes the same basic treatment processes as the cross-flow

19  — I'm sorry -- as the air sparging vapor extraction, they

20  offer -- both alternatives offer a similar degree of

21  effectiveness.

22             And this last slide shows the process that will be

23  used to determine the final remedial actions at Areas 29 and

24  K, and Area B. Through this meeting as well as an ongoing

25  thirty-day public comment period, the FAA is soliciting

   5-2-96

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                        Page 26
1    public comments on the Proposed Plans.  We're right in this

2    area here. Written comments will be accepted through May

3   10th and verbal comments will be accepted here this afternoon

4    following these presentations. Based on the Proposed Plan

5    and the public comments, a Records of Decision will be

6    prepared for each, Areas 29, K and Area B.  The Records of

7    Decision will include Responsiveness Summaries which will

8    address all public comments which will  be received during the

9    public comment period. Upon finalization of the Records of

10  Decision, a notice will be printed in the Press and a copy of

11  the Records of Decision will be placed in the Administrative

12  Record which is maintained in the reference section here at

13  the Library.

14             I will now turn the presentation back to Keith Buch

15  of the FAA Technical Center. Keith.

16             MR. BUCH: Well, thank you, Jean and Larry. I'd

17  just like to state for the record that all practices that led

18  to the contamination of ground water and soil that we have

19  previously viewed have been eliminated at the FAA Technical

20  Center, and that the FAA is currently in compliance with all

21  federal, state, and local regulations respecting the handling

22  storage and disposal of hazardous waste  and materials.

23             At this point we will end the formal presentation

24  and will open the floor up to interested members of the

25  public that may have guestions regarding what they've seen

   5-2-96

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                        Page 27
1    for the past forty minutes.  If you do have a question,

2    please state your name, affiliation,  and address for the

3    record. Seeing that.there's  no members from the public in

4    the audience and there are no guestions, I will now close

5    this public meeting.  Thank you for coming and please come to

6    our next meeting.

7    (Ended at Index #1329 at 2:45 P.M.)
9

10                                     CERTIFICATION

11        I,  CAROL PLATT,  agent for GCI TRANSCRIPTION AND

12   RECORDING SERVICES,  a Notary Public and State- and Federal-

13   ly-Approved Sound Recording operator and transcriber,  do

14   hereby certify that the foregoing is a true and accurate

15   transcript of the TRC Public Meeting taken by electronic

16   sound recording at the time, place, and on the date herein-

17   before set forth.

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                        5-2-96

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