PB96-963806
EPA/ROD/R02-96/273
October 1996
EPA Superfund
Record of Decision:
Federal Aviation Administration
Technical Center (Area 29 - Fire Training
Area and Area K - Storage Area Near Area 29),
Atlantic County, NJ
9/20/1996
-------
RECORD OF DECISION
AREA 29 - FIRE TRAINING AREA
AND
AREA K - STORAGE AREA
NEAR AREA 29
FAA TECHNICAL CENTER
ATLANTIC CITY INTERNATIONAL AIRPORT
NEW JERSEY
-------
TABLE OF CONTENTS
PAGE
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY FOR THE RECORD OF DECISION
I. SITE NAME, LOCATION AND DESCRIPTION 1
H. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
A Land Use 3
B. Initial Investigations 5
C. Environmental Investigation/Feasibility Study 5
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 9
IV. SCOPE AND ROLE OF RESPONSE ACTION 11
V. SUMMARY OF SITE CHARACTERISTICS 11
VI. SUMMARY OF SITE RISKS 14
A. Human Health Risk Assessment 14
B. Environmental Risk Assessment 23
VII. REMEDIAL ACTION OBJECTIVES 23
VIII. DESCRIPTION OF THE ALTERNATIVES 24
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 27
X. SELECTED REMEDY 30
XI. STATUTORY DETERMINATIONS 31
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES . 36
RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
I. OVERVIEW 1
II. BACKGROUND ON COMMUNITY INVOLVEMENT 1
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS 2
-------
TABLE OF CONTENTS
(Continued)
LIST OF FIGURES
1 Areas 29 and K Site Location Map 2
2 Areas 29 and K Site Plan 4
3 Phase I Sampling Locations and Monitoring Wells 6
4 Presumed Ground Water Flow Direction in the True Water Table 8
5 Phase II Surface Soil Sampling Locations 10
6 Soil Contamination Areas 13
7 Approximate Extent of Perched Ground Water Contamination 15
LIST OF TABLES
1 Exposure Assessment Input Parameters Used in the Phase I and II HHRAs ...17
2 Toxicity Values Used in the Phase I and II HHRAs 19
3 Summary of Estimated Human Health Risks Based on Phase I Data 21
4 Summary of Estimated Human Health Risks Based on Phase I and II Data .... 22
5 Applicable or Relevant and Appropriate Requirements (ARARs) and To-Be-
Considered Criteria (TBCs) 32
6 Summary of Chemical-Specific ARARs and TBCs 35
APPENDICES
A NJDEP AND PINELANDS COMMISSION LETTERS OF CONCURRENCE
B PUBLIC MEETING ATTENDANCE LIST
C PUBLIC MEETING TRANSCRIPT
in
-------
DECLARATION FOR THE RECORD OF DECISION
Area 29 - Fire Training Area and
Area K - Storage Area Near Area 29
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 29, the Fire Training
Area and Area K, a former drum and tank storage area located adjacent to Area 29 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 Areas 29 and K.
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.
DESCRIPTION OF THE REMEDY
The selected remedy for Areas 29 and K addresses the principal threat by controlling the
migration of and treating dissolved chemicals in ground water. Contaminated soils will be excavated
and disposed of off site. The selected remedy for Areas 29 and K includes the following components:
Excavation of approximately 350 cubic yards of PCS contaminated soil and transport
off site for disposal at a licensed facility;
Excavation of approximately 50 cubic yards of petroleum hydrocarbon contaminated
soil and transport off site for disposal at a licensed facility;
Demolition and excavation of debris from the former circular burn area and concrete
burn pad and transport off site for disposal,
Declaration - 1
-------
Extraction of perched ground water (a zone of ground water located above a low-
permeability clay layer and above the true water table aquifer) and on-site treatment
using carbon adsorption and/or other treatment processes to remove organic
compounds. Treated ground water will be recharged to the subsurface in the vicinity
of the site
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 reduce toxicity, mobility, or volume as their principal
element.
**.
re)/
(Signature
Gary E. Poulsen, P.E., Manager
Plant Engineering & Operations Branch
FAA Technical Center
(Signature) / /%r / (Date) '
Jeanne M. Fox '
Regional Administrator
United States Environmental Protection Agency, Region II
Declaration - 2
-------
DECISION SUMMARY
RECORD OF DECISION
Area 29 - Fire Training Area and
Area K - Storage Area Near Area 29
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 Technical Center 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 often 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 Parkway, 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 Delilah Road. The majority of commercial and residential
areas south of the FAA Technical Center are greater than 2,000 feet away from the FAA Technical
Center property, south of the Atlantic City Expressway. All residential areas in the vicinity of the
FAA Technical Center appear to be upgradient or otherwise isolated from the ground water flow at
the FAA Technical Center.
Area 29, referred to as the Fire Training Area, is located northeast of the Atlantic City
International Airport runways and southwest of White Horse Pike, as indicated in Figure 1. The site
was constructed in the early 1970s for the training of airport fire fighting personnel. The facility
consisted of a circular burn area approximately 150 feet in diameter, a small concrete burn pad, two
Decision Summary - 1
-------
ATLANTIC CITY
^ - RESERVOIR t "
TnC cnwDivnofitai
5 Waterside Crossing
Windsor, Ct 06095
(203)289^631
FAA TECHNICAL CENTER
RECORD OF DECISION
Date: 1/96
FIGURE 1.
AREAS 29 AND K
SITE LOCATION MAP
I Drawing No. 01040-0010-00220^
Decision Summary - 2
-------
above ground fuel tanks on a small hill, and two underground tanks for the collection of runoff from
the burn pads (Figure 2). A more complete description of Area 29 can be found in the Phase I
Environmental Investigative/Feasibility Study (EI/FS) Report (TRC, March, 1989) at pages 11-1, 11-
2 and 11-8 to 11-16.
Area K, referred to as the Storage Area Near Area 29, is located northwest of the test burn
areas at Area 29 (Figure 2). Aerial photographs taken in 1974 and 1983 show that drums and tanks
were once stored in this area. Since this area was investigated in conjunction with Area 29, separate
detailed descriptions of Area K are not provided in the EI/FS Report (TRC, March, 1989).
n. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use
The first significant development of what is now FAA Technical Center property came during
the 1930s when the Upper Atlantic City Reservoir was created by damming the South Branch of
Doughty Mill Stream. Prior to 1942, the entire property was wooded, except for the presence of
large borrow pits near the present-day Research and Development (R&D) facilities. On a 1940 aerial
photograph, several dirt roads and what appeared to be a railroad right-of-way traversed the property.
In 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 end of the built-up area since
1973.
Area 29 was constructed in the early 1970s for the training of airport fire fighting personnel.
Full scale aircraft test burns were conducted on the large circular burn area, while smaller fuel fires
were extinguished on the concrete pad. An underground drain system was used to collect runoff from
the circular burn area and to divert it to a 10,000-gallon underground circular storage tank. Runoff
from the concrete pad was collected in a 5,000-gallon underground storage tank. Both of these tanks
were emptied, removed, and disposed of off site in an environmentally safe manner in December
1988. Area K was formerly used to store drums and tanks. The drums were removed by the fall of
1986 and were also disposed of off site in an environmentally acceptable manner.
The FAA Technical Center was listed on the National Priorities List (NPL) on August 30,
1990, 55 FR 35502, 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
Decision Summary - 3
-------
PREVIOUS DRUM
STORAGE AREA
FORMER STORAGE
TANK LOCATIONS
TEST BURN AREA
ABOVE-GROUND
FUEL TANKS
5 Waterside Crossing
Windsor, a 06095
(203) 289-8631
FAA TECHNICAL CENTER
RECORD OF DECISION
FIGURE 2.
AREAS 29 AND K SITE PLAN
Date: 1/96
I Drawing No. 01040-0010-00220
Decision Summary - 4
-------
B. Initial Investigations
In 1983, the New Jersey Department of Environmental Protection (NJDEP) commissioned
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 the five areas considered most threatening to ground water supplies in the area. The
entire FAA Technical Center was included in the Weston Study, and the five areas identified by
Weston were all located on the FAA Technical Center property. Weston's report led the FAA to
initiate the present EI/FS, and the five areas identified by Weston have been investigated further,
along with additional areas identified by the FAA.
C. Environmental Investigation/Feasibility Study
Area 29 is one of the areas of concern identified by the Weston Study. Weston's investigation
of Area 29 included the installation and sampling of three ground water monitoring wells (29-MW1S
to 29-MW3S) One of these wells, 29-MW2S located southeast of the concrete burn pad and the two
underground storage tanks, was contaminated with several volatile organic compounds (VOCs)
(benzene, 1,1-dichloroethane, ethyl benzene, toluene, and xylenes) and two semi-volatile organic
compounds (SVOCs) (naphthalene and phenol).
The FAA's Environmental Investigation (El) of Area 29 was conducted in two phases
between December 1986 and December 1988. Due to its proximity of Area 29, Area K was included
in the scope of Area 29 investigations.
Area 29
The El was conducted to determine if past activities at Areas 29 and K had impacted soils and
ground water. Following the two phases of the El, ground water sampling was conducted in
December 1991 and quarterly ground water sampling has been performed since May 1993.
Phase I. Site investigation activities conducted during the Phase I El included a soil gas
survey, geophysical survey, surface soil sampling, subsurface soil sampling, ground water sampling,
air monitoring, and a hydrogeological investigation. Each of these Phase I El components is
discussed in the Phase I EI/FS Report (TRC, March, 1989) and 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 soils or contaminant plumes through the presence of elevated levels of VOCs
within the soil's pore space. Elevated organic vapor concentrations (greater than 1,000 parts
per million (ppm)) were identified in the area surrounding the circular test burn area.
A geophysical survey (EM-31 and EM-34) and resistivity profiling to detect buried metal
objects were also conducted during the Phase I investigations. No anomalies indicative of
buried waste or contaminant plumes were identified.
Decision Summary - 5
-------
/ _ -^_«-"WA 0 j,!- N
/ .' - ~"7* ~ai-m
NOTE: SOIL GAS SURVEY INCLUDES WORK DONE AT AREA F
0
H
SCALE
400
^
FEET
LEGEND
LJU AREA OF SOIL GAS SURVEY
« MONITORING WELL
SOIL BORING
A SURFACE SOIL SAMPLE
Cll- SOIL GAS ANOMALY
TRC Environmental
S Waterside Crossing
Windsor, Ct 06095
(203) 289-8631
FAA TECHNICAL CENTER
RECORD OF DECISION
FIGURE 3.
PHASE I SAMPLING LOCATIONS
AND MONITORING WELLS
Date: 1/96
Drawing No. 01040-0010-00220
Decision Summary - 6
-------
Sixteen (16) surface soil samples (29-SS1 to 29-SS16) were collected including one
background sample collected from the western side of the site. Seven of the surface soil
samples were analyzed for priority pollutants plus 40 (PP+40), while the remaining nine were
analyzed for total petroleum hydrocarbons (TPH). The presence of TPH was detected in
surface soils over a large portion of the site, with the highest concentrations present adjacent
to the circular bum area. Only one of the seven surface soil samples analyzed for PP+40 (29-
SS3 within the circular burn area) exhibited VOCs. Polychlorinated biphenyls (PCBs) were
also detected in 29-SS3 and in 29-SS10 located next to the concrete burn pad.
Four 10-foot deep soil borings were drilled and eight subsurface soil samples (two from each
boring) were collected to assess the vertical extent of contamination and site geology. One
sample from each boring was analyzed for PP+40, while the other sample was analyzed for
TPH. The presence of TPH was detected in three of the four borings, but at concentrations
less than those identified in surface soils. Low concentrations of VOCs in one boring location
(29-B2, east of the circular burn area) and SVOCs in all four boring locations were also
identified. PCBs were detected in one of the samples from 29-B4, located near the concrete
bum pad.
Two shallow monitoring wells were also installed during the Phase I El. The two Phase I El
monitoring wells as well as the three monitoring wells installed by Weston were sampled to
assess ground water quality. All five wells were sampled for PP+40. With the exception of
phenol in all five wells, the detection of VOCs and SVOCs was limited to 29-MW2S. This
limited VOC presence in ground water was consistent with the results obtained by Weston
prior to the Phase I El
Air monitoring for particulates, inorganics, VOCs, SVOCs, and PCBs was conducted during
the drilling of borings 29-B1, 29-B2, and 29-B3. Four inorganics and one VOC (toluene)
were detected, but at concentrations well below the applicable occupational guidelines.
The Phase I El also indicated that a clay layer of variable thickness exists at a depth of 10 to
14 feet over the western and central portions of the site, including the areas beneath the
circular bum area and the concrete burn pad. Where the soil in the unsaturated zone is locally
saturated because it overlies a low-permeability clay unit above the water table, the water
within this zone is referred to as perched ground water. At Area 29, a zone of perched
ground water was identified above the clay layer. While ground water flow in the regional
true water table was determined to be towards the east-southeast (Figure 4), the flow of
perched ground water was estimated to be much more variable due to localized changes in
the slope of the clay layer. Although ground water outside the perched zone did not appear
impacted, the potential for lateral or vertical movement of dissolved chemical constituents
from the perched zone into the true water table was identified.
Decision Summary - 7
-------
29-MW2S ^
(PERCHED):*
1) WATER ELEVATIONS MEASURED 08/16/94
TnC Enwomnofitol
Corporanon
5 Waterside Crossing
Windsor, Ct 06095
(203) 289-8631
FAA TECHNICAL CENTER
RECORD OF DECISION
FIGURE 4.
PRESUMED GROUND WATER FLOW
DIRECTION IN THE TRUE WATER TABL
Date: 1/96
I Drawing No. 01040-0010-00220
Decision Summary - 8
-------
Phase n. Following the Phase I El, a Phase II investigation was conducted to further define
the lateral extent of PCB contamination in surface soils and to investigate the potential presence of
soil contamination beneath the two underground runoff collection tanks removed during the Phase
n El. Each of these components of the Phase II El is discussed in the Phase II EI/FS Report (TRC,
January, 1 990) and briefly below. Figure 5 provides the Phase II sampling locations
Seven surface soil samples (29-SS17 to 29-SS23) were collected within the area of known
petroleum contamination and analyzed for PCBs. Three of these samples (within or near the
circular burn area and concrete burn pad) were also analyzed for dioxins and furans. PCBs
were detected in all but one of the seven surface soil samples, with one of the three surface
soil samples analyzed for dioxins and furans exhibiting octachlorodibenzo-p-dioxin (OCDD).
No furans were detected in the three surface soil samples analyzed for these constituents.
Four subsurface soils samples were collected at the base of each of the underground runoff
containment tanks removed during Phase II activities. All eight samples were analyzed for
TPH, four for PCBs, and two for Resource Conservation and Recovery Act (RCRA) waste
characteristics. TPH was detected beneath the 5,000-gaIlon tank, while both TPH and PCBs
were identified beneath the 10,000-gallon tank None of the subsurface soil samples met any
of the RCRA waste characteristics.
Quarterly Ground Water Sampling. Ground water monitoring has been conducted at Area
29 subsequent to the Phase I El (i.e., in December 1991 with quarterly monitoring beginning in May
1993). During each sampling round, ground water samples were collected from each of the five
monitoring wells and analyzed for VOCs. Results of this sampling indicate that the VOCs identified
at 29-MW2S may occasionally migrate within the perched zone (e.g., to 29-MW3S). While dissolved
VOCs have been detected in samples collected from the true water table, their detection has been
sporadic and at trace to low levels. Specifically, VOCs were detected for the first time in 29-MW1 S
in May 1993 (1,2-dichloroethane at 0.001 ppm) and in 29-MW4S and 29-MW5S in August 1993 (at
0.0006 to 0.004 ppm). Furthermore, none of the detections since August 1993, except for the 0.002
ppm detection of chloroform at 29-MW4S in October 1995, have been above Practical Quantitation
Levels (PQLs).
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A newspaper notification of the availability of the Proposed Plan for Areas 29 and K was
published in the Atlantic City Press on Thursday, April 1 1, 1996. The notice invited the public to
comment on the EI/FS and Proposed Plan. The public comment period was held from April 1 1
through May 10, 1996. The Proposed Plan and EI/FS Reports were placed in the administrative
record maintained at the Atlantic County Library.
Decision Summary - 9
-------
0
H_
SCALE
400
FEET
LEGEND « SURFACE SOIL SAMPLE-PETROLEUM
HYDROCARBON ANALYSIS (PHASE I)
A SURFACE SOIL SAMPLE-PRIORITY POLLUTANTS
(PHASE I)
PCB ONLY
+ PCB, DIOXIN, FURANS
TUC Enyiiumnental
5 Waterside Crossing
Windsor, Ct 06095
(203) 2894631
FAA TECHNICAL CENTER
RECORD OF DECISION
Date: 1/96
FIGURE 5.
PHASE II SURFACE SOIL
SAMPLING LOCATIONS y
I Drawing No. 01040-0010-00220 |
Decision Summary - 10
-------
A public meeting was held on May 2, 1996 at the Atlantic County Library. At the meeting,
representatives from the FAA, the FAA's environmental consultant (TRC Environmental
Corporation), U.S. Environmental Protection Agency (USEPA), and New Jersey Department of
Environmental Protection (NJDEP) were available to answer questions about Areas 29 and K. 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 Areas 29 and K
of the FAA Technical Center in Atlantic County, New Jersey, chosen in accordance with CERCLA,
as amended by SARA and, to the extent practicable, the NCP. The decision for Areas 29 and K is
based on the administrative record.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy described herein is an Excavation/Removal Action for selected site soils
and demolition debris and an Extraction/Treatment Action for on-site perched ground water. In
summary, the remedy provides for the excavation and off site disposal of PCB-contaminated soils,
TPH-contaminated soils, and demolition debris from the circular burn area and concrete burn pad,
and for the extraction, on-site treatment of ground water, and nearby reinjection to the subsurface
It should be noted that Areas 29 and K represent only two of more than 20 areas of potential
environmental concern identified at the FAA Technical Center. This document addresses only Areas
29 and K, and is not intended to address the entire FAA Technical Center 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 contaminants in soils and ground water at Areas 29 and K
which appears to be mainly attributable to the storage or burning of aviation gasoline and fuels, some
potentially containing PCBs.
Surface soils exhibited the presence of PCBs at concentrations ranging from non-detectable
to 30 ppm and TPH at concentrations ranging from 6 to 6,200 ppm. Of three surface soil samples
analyzed for dioxins and furans, one sample (29-SS18, collected adjacent to the concrete burn pad)
exhibited 0.0034 ppm of octachlorodibenzo-p-dioxin (OCDD). Other constituents detected in surface
soils which were not detected in associated blank samples include the following:
Methylene chloride Non-detectable (ND) to 0.043 ppm
Phenol 0.058 to 1.7 ppm
SVOC Tentatively Identified Compounds (TICs) 8.2 to 100.6 ppm
Cadmium ND to 1.8 ppm
Chromium 2.7 to 15 ppm
Copper ND to 30.9 ppm
Lead 3.9 to 33 ppm
Decision Summary - 11 '
-------
Mercury ND to 0.22 ppm
Silver ND to 3.3 ppm
Zinc 20 to 75 ppm
Sample 29-SS3, collected within the circular burn area, also exhibited benzene at 0.063 ppm, ethyl
benzene at 0.5 ppm, isophorone at 1.3 ppm and naphthalene at 0.46 ppm.
PCBs were the only constituents detected in surface soils at levels exceeding non-residential
New Jersey soil cleanup criteria. The non-residential soil cleanup criteria for PCBs is 2 ppm.
Subsurface soils exhibited TPH at levels of 2 to 14,000 ppm, with the greatest concentrations
detected at the base of the excavated 10,000-gallon underground storage tank. Other constituents
detected in subsurface soils which were not detected in the associated blank samples include the
following:
Benzene ND to 0.034 ppm
Ethyl benzene ND to 0.19 ppm
Phenol ND to 0.14 ppm
SVOC TICs 2.5 to 68 ppm
PCBs ND to 24 ppm
Antimony ND to 12 ppm
Chromium 2.9 to 5.6 ppm
Lead 2.1 to 5.3 ppm
Mercury ND to 0.0002 ppm
Zinc 6.8 to 11.9 ppm
PCBs and TPH were the only constituents detected in subsurface soils at levels exceeding
non-residential New Jersey soil cleanup criteria. The non-residential soil cleanup criteria for PCBs
is 2 ppm, while the cleanup criteria for total organic compounds is "10,000 ppm and is exceeded by
the maximum detected TPH level of 14,000 ppm.
Based on the identification of PCBs in surface soils and subsurface soils at levels exceeding
New Jersey soil cleanup criteria, three areas of soils containing elevated PCBs levels were identified:
within the circular burn area, adjacent to the concrete burn pad, and in the former drum storage area
(Area K). A total of 350 cubic yards of contaminated soil was estimated to exceed NJDEP cleanup
criteria for PCBs. Based on the identification of TPH at a level of 14,000 ppm, which exceeds the
New Jersey soil cleanup criteria of 10,000 ppm for total organic compounds, in one of four
subsurface soil samples collected at the base of the former 10,000 gallon underground storage tank,
a total volume of 50 cubic yards of contaminated subsurface soil was estimated to exceed the NJDEP
soil cleanup criteria for total organic compounds. The general locations of these guidance criteria
exceedances are indicated in Figure 6.
Decision Summary - 12
-------
Locations where PCB soil levels exceed
NJDEP cleanup criteria (2 ppm)
O Location where TPH soil level exceeds
NJDEP cleanup criterion (10,000 ppm)
TRC £nvvonmenfaf
Corporation
5 Waterside Crossing
Windsor, Ct 06095
(203) 289-6631
FAA TECHNICAL CENTER
RECORD OF DECISION
FIGURE 6.
SOIL CONTAMINATION AREAS
Date: 1/96
I Drawing No. 01040-0010-00220
Decision Summary - 13
-------
In ground water, priority pollutant VOCs and SVOCs were initially detected in only the
perched ground water sample collected from well 29-MW2S (with the exception of bis(2-
ethylhexyl)phthalate which was also detected in wells 29-MW1S and 29-MW3S). Inorganics
detected in ground water samples include cadmium (ND to 0.006 ppm), chromium (ND to 0.029
ppm), mercury (ND to 0.00031 ppm), lead (ND to 0.0086 ppm) and zinc (0.023 to 0.049 ppm).
During some of the quarterly ground water sampling rounds, VOCs were also detected in well 29-
MW3S, which is also located in the perched zone. VOCs which were detected in ground water at
levels exceeding state or federal Maximum Contaminant Levels (MCLs) or New Jersey Ground
Water Quality Standards (i.e., PQLs) in the perched zone include ethylbenzene (detected at 0.95
ppm), methylene chloride (0.056 ppm), toluene (1.9 ppm), 1,1,1-trichloroethane (0.1 ppm), and
xylene (2.8 ppm). During the August 1993 quarterly sampling round, VOCs were detected for the
first time in 29-MW4S, which is screened in the true water table. The detected concentrations ranged
from 0.0009 ppm (toluene and 1,1-dichloroethene) to 0.004 ppm (1,1,1-trichloroethane). The
subsequent detection of VOCs in the true water table has been sporadic. 1,1,1 -Trichloroethane (at
a maximum concentration of 0.004 ppm), chloroform (0.002 ppm) and tetrachloroethane (0.003 ppm)
have been detected during only one often quarterly sampling rounds and in only one well at levels
exceeding MCLs or Ground Water Quality Standards (i.e., PQLs). Based on these results, the
primary area of ground water impact is located within the perched water table zone, as indicated in
Figure 7.
VI. SUMMARY OF SITE RISKS
A baseline risk assessment was conducted based on the results of the Phase I El for Areas 29
and K to estimate the potential risks associated with current site conditions under current and
potential future land uses. The baseline risk assessment estimates the potential human health and
ecological risks which could result from the contamination at the site if no remedial action was taken.
A summary of the Human Health Risk Assessment (HHRA) and Environmental Risk Assessment
(ERA) is presented below. A more complete description can be found in the Phase IEI/FS Report
(TRC, March, 1989) at pages 11-45 through 11-68. The Area 29 Feasibility Study (FS) (TRC, July,
1989) provides a discussion of the potential impacts of the Phase n El data on the human health and
ecological risks estimated in the Phase I HHRA and ERA, respectively. This latter discussion is also
summarized as part of this Decision Summary.
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.
Decision Summary -14
-------
Note .Flow direction in the perched zone is determined by the extent of the underlying day layer.
nvuminicfitai
Corporation
5 Waterside Crossing
Windsor, Ct 06095
(203) 289-8631
FAA TECHNICAL CENTER
RECORD OF DECISION
FIGURE 7.
APPROXIMATE EXTENT OF PERCHED
GROUND WATER CONTAMINATION
Date: 1/96
Drawing No. 01040-0010-00220
Decision Summary - 15
-------
Hazard Identification '
The hazard identification 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 29 were chosen
based upon the relative toxicity of the detected constituents, the measured concentrations in the site
media, and the physical/chemical properties related to the environmental mobility and persistence of
each constituent. The COCs selected in the Area 29 HHRA by media included:
Benzene and PCBs in surface soil,
PCBs in subsurface soil, and
Benzene, 1,1-dichloroethane, toluene, and bis(2-ethylhexyl)phthalate in ground water.
Exposure Assessment
The exposure assessment identified the potential pathways and routes for COCs to reach
potential receptors and estimated the constituent concentrations at the points of exposure as well as
characterized the extent of the potential exposures. Constituent release mechanisms from the
environmental media, based on relevant hydrologic and hydrogeologic information (fate and
transport, and other pertinent site-specific information) are also presented in the HHRA.
The entire FAA Technical Center is restricted by a fence and security and only government
employees have access to the facility, thereby precluding persons under the age of 18 At Area 29,
the current receptor population was characterized as limited to government employees due to the size
and security of the FAA Technical Center. Under this current government employee scenario,
workers were assumed exposed through ingestion of and dermal contact with COCs in surface soils.
Currently, the site is not actively used. However, incidental exposure could occur as a result of
activities such as atypical work assignments which could require the presence of a person at the site.
Exposures to subsurface soils and ground water were not evaluated under this scenario since there
is no current use of ground water at Area 29 and no excavations or building projects which would
uncover subsurface soils are taking place.
Since the use of Area 29 is not anticipated to change in the foreseeable future, adult
government employees were also identified as the future receptor population. Consequently, the
potential exposures to surface soils evaluated under the current scenario are also applicable to future
government workers at the site (and thus were not reevaluated under the future scenario). Under the
future government worker scenario, exposures to subsurface soils, as a result of future excavation
and/or construction, and ground water, assuming the installation of an on-site well, were quantified.
Future workers were assumed exposed to COCs in subsurface soil through ingestion and dermal
contact, and to COCs in ground water through ingestion.
The assumptions used in the HHRA regarding the magnitude, frequency, and duration of
exposures to the COCs in surface soils, subsurface soils, and ground water are provided in Table 1
Two exposure point concentrations (EPCs) were identified for each COC; namely, the
arithmetic average concentration and the maximum detected concentration. The average and
Decision Summary - 16
-------
TABLE 1
EXPOSURE ASSESSMENT INPUT PARAMETERS
USED IN THE PHASE I AND II HHRAs
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Most
Probable
Case
Realistic
Worst
Case
General
Exposure Point Concentration
(mg/kg; mg/l): (a) Average Maximum
Body Weight, Adult (kg): 70 70
Current FAA Worker (Surface Soils)
Ingestion
Digestion rate (kg/d): NC 0.0002
Oral absorption (-):
Benzene & PCBs NC 0.5 & 1.0
Exposure Frequency (d/yr): NC 2
Exposure Duration (yr): NC 20
Dermal Contact
Dermal Contact Rate (kg/d): 0.01 0.01
Dermal absorption (-):
Benzene 0.1&0.5 0.1&0.5
PCBs 0.02 & 0.04 0.02 & 0.04
Exposure Frequency (d/yr): 12 24
Exposure Duration (yr): 10 20
Future Construction (Subsurface Soils)
Ingestion
Ingestion rate (kg/d): NC 0.0002
Oral absorption (-): (b) NC . 0.5 & 1.0
Exposure Frequency (d/yr): NC 20
Exposure Duration (yr): NC 2
Dermal Contact
Dermal Contact Rate (kg/d): 0.01 0.01
Dermal absorption (-): (b) 0.02 & 0.04 0.02 & 0.04
Exposure Frequency (d/yr): 120 240
Exposure Duration (yr): 1 2
Future Commercial/Industrial (Ground Water)
Ingestion
Ingestion rate (l/d): 1 2
Oral absorption (-): (c) 0.5 & 1.0 0.5 & 1.0
Exposure Frequency (d/yr): 250 250
Exposure Duration (yr): 10 20
NC = Not calculated since the realistic worst case risk estimate was
below the 1E-06 to 1E-04 cancer risk range or 1.0 non-cancer
hazard index
(a) Chemical-specific
(b) For PCBs
(c) For benzene, 1,1-dichloroethane, toluene, and bis(2-ethylhexyl)phthalate
Decision Summary - 17
-------
maximum concentrations (and corresponding exposure assumptions) were used to characterize the
"most probable" and "realistic worst case" exposures to the identified COCs, respectively.
Toxicity Assessment
The toxicity assessment summarizes the types of adverse health effects associated with
exposures to each COC 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 a
combination of EPA's Superfund Public Health Evaluation Manual (EPA, 1986), EPA's Office of
Research and Development Health Effects Assessments (HEAs) (EPA, 1986), EPA's Environmental
Criteria and Assessment Office (EPA, 1985), EPA's Carcinogenic Assessment Group (EPA, 1984),
and EPA's Office of Drinking Water (EPA, 1985). The toxicity values used in the HHRA are
summarized in Table 2.
For potential carcinogens, risks are estimated as probabilities. Constituent-specific cancer
potency factors (CPFs) are estimates of the constituent's carcinogenic potency based upon studies,
most often in laboratory animals but occasionally in humans, which test the relationship between the
magnitude of exposure and the prevalence of tumors in the exposed population. The CPFs used in
the HHRA are presented as the expected cancer risk for a chronic exposure to 1 mg/kg/day of the
specific constituent (i.e., risk per unit dose or (mg/kg/day)'1), and are estimates of the 95% upper
confidence limit (UCL) on the slope of the dose-response curve.
Determining the potential for chronic non-cancer (systemic) effects was based on the use of
constituent-specific reference doses (RfDs) or acceptable chronic intake (AIC) values. Chronic RfDs
are estimates of the daily, chronic exposure to the population that is likely to be without appreciable
risk of deleterious effect. RfD values incorporate numerous safety and/or modifying factors which
serve as a conservative downward adjustment of the numerical value. The Area 29 HHRA also
incorporated AIC values in the event these values were more health protective (i.e., lower) than the
RfDs. For assessing the potential for acute non-cancer effects, the HHRA applied values based on
1-day health advisories (HAs).
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 the potential for adverse non-
cancer health effects. For each exposure pathway and land use evaluated, most probable and
reasonable worst case risk estimates were generated for each COC corresponding to exposure to the
average and maximum detected concentrations, respectively.
Excess lifetime cancer risks were determined for each COC by multiplying the COC-specific
exposure dose by the COC-specific CPF, described above. The resulting cancer risk estimates are
expressed in scientific notation as a probability (e.g. 1 x 10"6 for 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 over a 70 year lifetime. Current EPA practice considers carcinogenic risks to be additive
when assessing exposure to a mixture of constituents. That is, the COC-specific cancer risks were
summed to estimate pathway-specific cancer risks.
Decision Summary -18
-------
TABLE 2
TOXICITY VALUES USED IN THE PHASE I AND II HHRAs
FAA AREAS 29 AND K
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Non-Cancer
Constituent
Benzene
Dichloroethane, 1,1-
Toluene
Bis(2-ethylhexyl)phthalate
PCBs
Acute (a)
(mg/kg/d)
0.023
0.1
1.8
NA
0.013
Chronic
(mg/kg/d)
7.0E-04 (c)
0.009 (c)
0.3 (d)
0.02 (d)
3.0E-04 (c)
Cancer
Potency
Factor (b)
(mg/kg/d)-1
0.052
0,58
NA
6.8E-04 (e)
4.34
(a) 1-Day child health advisories (EPA Office of Drinking Water, 1985)
converted to adult
(b) EPA, Office of Resaerch and Development, Health Effects
Assessments (1986)
(c) Reference dose (EPA, Environmental Criteria and Assessment
Office, 1985)
(d) Chonic acceptable intake (EPA, Superfund Public Health Evaluation
Manual, 1986)
(e) EPA Carcinogenic Assessment Group (1984)
Decision Summary - 19
-------
Hazard indices (His) were also calculated for each pathway as a measure of the potential for
non-carcinogenic health effects. The HI is the sum of the constituent-specific hazard quotients (HQs)
which are calculated by dividing the exposure dose by the reference dose (RfD) or other suitable
benchmark for non-carcinogenic health effects for an individual constituent. In general, HQs are
assumed additive for constituents with similar toxic endpoints. In the HHRA, acute and chronic HQs
were calculated using the chronic RfDs (or similar benchmark) and 1-day HAs, respectively.
The estimated cancer risks and non-cancer His (Table 3) were evaluated using EPA's
established target risk range for Superfund cleanups (i.e, cancer risk range of 10"6 to 10"4) and target
HI value (i.e., HI less than or equal to 1).
The results of the HHRA indicate that the presence of benzene and PCBs in surface soil and
PCBs in subsurface soil do not pose an unacceptable human health risk. That is, estimated cancer
risks and non-cancer His were below the target values (i.e., 10"6 to 10"4 and 1.0, respectively). The
cancer risks associated with nature exposures to ground water were estimated to exceed the target
cancer risk range of 10"6 to 104 under the realistic worst case (based on the maximum detected
concentrations), and to fall within this range under the most probable case (based on the average
concentrations). The elevation under the realistic worst case was primarily due to the presence of
benzene and 1,1-dichloroethane which had individual cancer risks of 3.2 x 10"4 and 8.4 x 1Q4 ,
respectively. The estimated non-cancer His for ingestion of ground water ranged from 1.5 (acute)
to 9.3 (chronic) under the realistic worst case, but were less than 1.0 under the most probable case.
Benzene was the main contributor to the estimated non-cancer His.
While not included in the quantitative assessment of site risks, the presence of TPH in site
surface soils was evaluated qualitatively. It was concluded that minimal risk would be associated with
direct contact with TPH-contaminated surface soils.
Implications of the Phase II El on the Phase I HHRA
A discussion of the implications of the Phase II El on the Phase I HHRA results is provided
in the FS for Area 29 (TRC, July, 1989) at pages 1-20 through 1-29 and is summarized below.
PCBs and octachlorodibenzo-/?-dioxin (OCDD) were the constituents detected in Phase II
surface soil samples. While PCBs were also detected in Phase I, dioxins and fiirans were not included
as Phase I analytes. Consequently, OCDD was evaluated with regard to inclusion as a COC on the
basis of the Phase n El. Due to OCDD's low toxicity, it was determined not to be of environmental
concern and was not selected as a COC for Areas 29 and K. Therefore, no additional COCs were
identified on the basis of the Phase II El.
The risk results calculated on the basis of the Phase I and II data combined (Table 4) are
consistent with those obtained in Phase I. That is, the inclusion of the Phase IIPCB data does not
change the Phase I conclusion that the COCs in surface and subsurface soils do not pose an
unacceptable human health risk.
Decision Summary - 20
-------
TABLE 3
SUMMARY OF ESTIMATED HUMAN HEALTH RISKS
BASED ON PHASE I DATA
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Cancer Risk
Current FAA Worker
(Surface Soils):
Ingestion
Dermal Contact
Future Construction
(Subsurface Soils):
Most
Probable
Case
NC
4.9E-08
Ingestion NC
Dermal Contact 7.0E-07
Future Commercial/Industrial
(Ground Water):
Ingestion
5.8E-5 (b)
Realistic
Worst
Case
9.3E-08
| 2.2E-06 (a)|
4.7E-07
1.1E-05(a)|
| 1.2E-03(b)|
Non-Cancer
Most
Probable
Case
Acute/Chronic
NC/NC
NC/NC
NC/NC
NC/NC
1.5E-01/9.3E-01
I
Hazard index i
Realistic
Worst
Case
Acute/Chronic
1.1E-03/7.2E-05
2.4E-03/1.8E-03
5.5E-03/1.3E-02
1.1E-02/3.0E-01
I 1.5E-00/9.3E+00(c)j
; i = Within 1E-06 to 1E-04 cancer risk range
: ! = Exceeds 1E-06 to 1E-04 cancer risk range or 1.0 non-cancer hazard index
NC = Not calculated since the realistic worst case estimate was below the 1 E-06 to 1 E-04
cancer risk range or 1.0 non-cancer hazard index
(a) Attributable to PCBs
(b) Primarily attributable to benzene and 1,1-dichloroethane
(c) Primarily attributable to benzene
Decision Summary - 21
-------
I TABLE 4
SUMMARY OF ESTIMATED HUMAN HEALTH RISKS
BASED ON PHASE I AND II DATA (a)
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Cancer Risk
Current FAA Worker
(Surface Soils):
Ingestion
Dermal Contact
Future Construction
(Subsurface Soils):
Most
Probable
Case
NC
4.0E-07
Ingestion NC
Dermal Contact 3.8E-07
Future Commercial/Industrial
(Ground Water):
Ingestion [
5.8E-5 (c) |
Realistic
Worst
Case
5.8E-07
1.4E-05(b)|
4.7E-07
1.1E-05(b)i
1.2E-03(c)l
Non-Cancer
Most
Probable
Case
Acute/Chronic
NC/NC
NC/NC
NC/NC
NC/NC
1.5E-01/9.3E-01
Hazard index
Realistic
Worst
Case
Acute/Chronic
6.9E-03/4.5E-04
1.4E-02/1.1E-02
5.5E-03/1.3E-02
1.1E-02/3.0E-01
| 1.5E-00/9.3E+00(d)i
j | = Within 1E-06 to 1E-04 cancer risk range
| j = Exceeds 1E-06 to 1E-04 cancer risk range or 1.0 non-cancer hazard index
NC = Not calculated since the realistic worst case estimate was below the 1E-06 to 1E-04
cancer risk range or 1.0 non-cancer hazard index
(a) Note that the Phase II investigation was limited to the analysis of surface soil samples for
dioxin and furans and PCBs and subsurface soil samples for PCBs. No additional ground
water data were obtained.
(b) Attributable to PCBs
(c) Primarily attributable to benzene and 1,1-dichloroethane
(d) Primarily attributable to benzene
Decision Summary - 22
-------
B. Environmental Risk Assessment
A qualitative environmental risk assessment was conducted on the basis of the same COCs
as the HHRA. Since PCBs are persistent in the environment, tend to bioaccumulate, and can cause
reproductive and behavioral changes in animals, it was surmised that concentrations of PCBs in
surface soils may be high enough to affect the reproduction and behavior of some wildlife. Currently,
a comprehensive ecological risk evaluation of the entire FAA Technical Center facility is being
conducted which will further define ecological risks associated with Area 29 and other portions of
the facility.
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.
. REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment;
they specify the COCs, the 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 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 Areas 29 and K was
completed by TRC in July 1989 and established the objectives for remedial actions at Areas 29 and
K. Due to changes in ARARs which have occurred since the time the FS was prepared, the
objectives have been revised accordingly. The following remedial action objectives have been
established for Areas 29 and K:
Eliminate exposures to PCB-contaminated soils at levels which exceed state or federal
cleanup criteria;
Reduce concentrations of TPH in subsurface soils to prevent continued leaching of
contaminants into ground water;
Prevent the migration of VOCs in perched ground water to deeper aquifer systems,
Reduce contaminant concentrations in the perched ground water system to acceptable
levels; and
Reduce human health risks posed by the site in accordance with state and federal
remediation goals.
Decision Summary - 23
-------
DESCRIPTION OF THE ALTERNATIVES
The Area 29 FS (TRC, July, 1989) included 12 remedial alternatives formulated for
addressing soil and perched ground water remediation at Areas 29 and K. An initial screening of the
twelve alternatives was conducted in the FS based on acceptable engineering practice, effectiveness,
and cost. On the basis of the initial screening, this list was reduced to six alternatives which were
considered to provide the greatest degree of compliance with the screening criteria. An additional
alternative (Alternative 2 - RCRA Capping of Contaminated Soil) was removed from further
consideration subsequent to the FS (as described in the Proposed Plan) based on the issuance of the
New Jersey soil cleanup criteria which eliminated the need for remediation of surficial TPH-
contaminated soil.
The remaining five alternatives are referred to as Alternatives 1, 3, 4, 10, And 12. Included
among these alternatives is the no action alternative (Alternative 1), a required consideration for every
FS. The five alternatives are summarized below. Because a number of the alternatives involve
common remedial elements, these are described first and then are referenced in the subsequent
individual alternative descriptions, as appropriate.
Common Major Elements of Remedial Alternatives
PCB-Contaminated Soil Excavation and Off Site Disposal
For each of the alternatives except the no action alternative (Alternative 1), the PCB-
contaminated soils in three areas (within the circular burn area, adjacent to the concrete burn pad, and
in the former drum storage area of Area K) will be excavated and disposed of off site at licensed
landfill facilities permitted to accept soils containing chemicals at the levels detected. The soils
exceeding the NJDEP cleanup criteria of 2 ppm, estimated to be approximately 350 cubic yards in
volume, will be excavated for off site disposal. The remediation of the PCB-contaminated soils
includes landfill disposal of PCB-contaminated soils which are not characteristically hazardous by
RCRA definition and which do not exceed a total halogenated organic compound level of 1,000 ppm.
Based on existing data, all PCB-contaminated soils at Area 29 are not expected to exceed land
disposal restrictions. Prior to off site disposal, sampling and analysis to characterize the excavated
soils will be performed. In association with the soil excavation activities, the circular burn area and
concrete burn pad will be demolished and the demolition debris will also be further characterized for
off site disposal. Disposal of these materials will be performed in accordance with RCRA and Toxic
Substance Control Act (TSCA) regulations which address the handling and disposal of PCB-
contaminated materials, as well as with state and local regulations.
TPH-Contaminated Soil Excavation and Off Site Disposal
For each of the alternatives except the no action alternative (Alternative 1), the TPH-
contaminated soils at the former 10,000-gallon underground storage tank location will be excavated
and disposed of off site at licensed landfill facilities permitted to accept soils containing chemicals
at the levels detected. The soils exceeding the NJDEP cleanup criteria of 10,000 ppm for total
organic compounds, estimated to be approximately 50 cubic yards in volume, will be excavated for
off site disposal. Prior to off site disposal, sampling and analysis to characterize the excavated soils
will be performed. Disposal of these soils will be conducted in accordance with RCRA and NJDEP
industrial waste disposal regulations.
Decision Summary - 24
-------
Declaration of Environmental Restrictions
New Jersey non-residential soil cleanup criteria will be attained by the remedial alternatives
(except for Alternative 1, the no action alternative). Although not required by EPA, the FAA will
install an institutional control in order to prevent unacceptable exposures from occurring under future
site use. A Declaration of Environmental Restrictions will be placed on the land records for the
portions of Areas 29 and K containing constituents of concern in soil above the New Jersey
residential soil cleanup criteria.
Ground Water Extraction/Treatment
Ground water extraction and treatment systems are included as components for two of the
remedial alternatives (Alternatives 3 and 4). Perched ground water will be extracted for subsequent
treatment. The remedial alternatives and costs presented herein are based on perched ground water
extraction and treatment only. For the purpose of estimating relative costs, ground water is assumed
to be extracted for treatment at a rate of five gallons per minute. Following treatment, the ground
water will be reinjected back into the subsurface.
Ground water cleanup criteria will include federal and state MCLs and New Jersey Ground
Water Quality Standards. 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 quality criteria for Class I-PL (Protection Area) shall be background water quality, as that term
is defined in NJAC 79-6.4. The NJDEP and Pinelands Commission recognize that technical
limitations exist for measuring compliance with such criteria. The seven constituents identified below
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 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 seven constituents in ground water of concern at the FAA Technical
Center are as follows:
Constituent POL (ppm)
Benzene 0.001
Ethylbenzene 0.005
Methylene Chloride 0.002
Tetrachloroethene 0.001
Toluene 0.005
1,1,1-Trichloroethane 0.001
Xylene 0.002
Decision Summary - 25
-------
Ground Water In Situ Treatment
In situ treatment of ground water is included as part of two of the alternatives (Alternatives
10 and 12). This treatment does not involve the extraction and subsequent reinjection of ground
water. Similar to the ground water extraction/treatment components above, the remedial alternatives
and costs presented herein are based on perched ground water treatment only.
A brief description of the five remedial alternatives is presented below.
Alternative 1 - No Action
Capital Cost: $7,000
O&MCost: $332,000
Present Worth Cost: $408,000
Construction Time: 1 month
This alternative involves no additional actions other than installation of two additional
monitoring wells and continued ground water monitoring. No contaminants would be treated
or contained and existing health and environmental risks would remain.
Alternative 3 - Ground Water Extraction with Air Stripping
Capital Cost: $404,000
O&MCost: $195,000
Present Worth Cost: $719,000
Construction Time: 6 months
This alternative involves the removal and off-site disposal of PCB-contaminated soils,
petroleum hydrocarbon-contaminated soils and demolition debris. Perched ground water
contamination is addressed through extraction and air stripping for treatment of VOCs.
Alternative 4 - Ground Water Extraction with Carbon Adsorption
Capital Cost: $401,000
O&MCost: $201,000
Present Worth Cost: $723,000
Construction Time: 6 months
This alternative involves the removal and off-site disposal of PCB-contaminated soils,
petroleum hydrocarbon-contaminated soils and demolition debris Perched ground water
.would be extracted and treated using carbon adsorption, with both VOC and SVOC
contamination in ground water addressed.
Decision Summary - 26
-------
Alternative 10 - In Situ Aeration of Contaminated Ground Water and Vacuum Extraction
Capital Cost: $398,000
O&MCost: $313,000
Present'Worth Cost: $854,000
Construction Time: 8 months
This alternative involves a combination of in situ aeration and vacuum extraction. In situ
ground water treatment is treatment which is conducted in-place, with no extraction of the
ground water prior to treatment. Aeration wells are used to aerate the perched ground water
in situ, stripping volatile contaminants from the ground water into the soil pore spaces The
vacuum extraction system subsequently extracts the gas from the soil pore spaces for
discharge or treatment. It would be combined with removal and off-site disposal of
PCB-contaminated soils, petroleum hydrocarbon-contaminated soils, and demolition debris.
Alternative 12 - In Situ Biodegradation
Capital Cost: $441,000
O&MCost: $201,000
Present Worth Cost: $770,000
Construction Time: 8 months
This alternative involves ground water treatment using in situ biodegradation Perched
ground water remediation would be achieved by installing wells for nitrate addition, which
would enhance subsequent anaerobic degradation of ground water contaminants in-place,
without ground water extraction. It would be combined with removal and off-site disposal
of PCB-contaminated soils, petroleum hydrocarbon-contaminated soils, and demolition
debris.
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The five alternatives identified in Section Vffl 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 Amendment and
Reauthorization Act of 1986 (SARA), as presented in the Proposed Plan. These criteria relate to the
SARA amendment to Section 121 ofCERCLA [Section 121 (b)(l)] as 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.
Decision Summary - 27
-------
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 inv.oking 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
and determines the magnitude of residual risk posed by untreated wastes or treatment
residuals.
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.
Implementabilitv 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 operational and maintenance costs, and net present worth
costs.
State acceptance indicates whether, based on its review of the EI/FS reports and the Proposed
Plan, the State concurs, opposes, or has no comment on the preferred alternative at the
present time.
Community acceptance evaluates the issues and concerns the public usually have regarding
the alternatives.
The following presents a comparative analysis of the five alternatives based upon the
evaluation criteria noted above.
Overall Protection of Human Health and the Environment - Alternative 4 provides the greatest
overall protection of human health and the environment through its ability to treat both volatile and
semi-volatile organic compounds dissolved in ground water, its removal and off-site disposal of
PCB-contaminated soils and petroleum hydrocarbon-contaminated soils, and its proven reliability and
effectiveness. Alternative 3 also offers a high degree of overall protection through the removal and
off-site disposal of PCB-contaminated soils and petroleum hydrocarbon-contaminated soils and
treatment of ground water, although it would not be as effective in the treatment of semi-volatile
organic ground water contaminants. Alternatives 10 and 12 would provide s-mie protection of human
health and the environment since they also include removal and off-site disposal of PCB-contaminated
soils and petroleum hydrocarbon-contaminated soils, but due to the innovative nature of their ground
water treatment technologies, their reliability and capability in attaining ARARs are not as
well-defined as Alternatives 3 and 4. Alternative 1, which provides no soil or ground water
treatment, is the least protective alternative.
Decision Summary - 28
-------
Compliance with ARARs - Each of the remedial alternatives except for Alternative 1 will
comply with chemical-specific to-be-considered criteria (TBCs) applicable to PCB-contaminated soils
and petroleum hydrocarbon-contaminated soils. Soil characterization, handling, transport and
disposal will be conducted in accordance with applicable federal and state waste management
regulations. Chemical-specific ARARs applicable to ground water are considered to be achievable
for Alternatives 3 and 4. Alternatives 3 and 4 would also be designed to comply with ARARs
applicable to the operation of the ground water extraction, treatment and discharge systems. Due to
the more innovative nature of Alternatives 10 and 12, a greater degree of uncertainty is associated
with the ability of these alternatives to achieve chemical-specific ground water ARARs, although
Alternatives 10 and 12 would also be designed and operated in accordance with action-specific
ARARs. Alternative 1 will not meet chemical-specific ARARs or TBCs for soil or ground water.
Long-Term Effectiveness and Permanence - Alternatives 3,4, 10 and 12 will all be effective
in the long-term in addressing soils contaminated with PCBs or petroleum hydrocarbons. Alternatives
3 and 4 will also be effective in the long-term in treating ground water contamination. Alternatives
10 and 12 may not be as effective in the long-term due to uncertainties associated with innovative and
in situ treatment technologies. Alternative 1 provides no treatment of ground water and is not
considered to be effective in the long-term.
Reduction of Toxicity. Mobility, or Volume through Treatment - Each of Alternatives 3, 4,
10 and 12 provide a reduction in ground water toxicity through treatment and a reduction in the
mobility of soil contaminants through the containment features of an off-site landfill. Alternative 4
provides the greatest reduction in toxicity by treating both volatile and semi-volatile organic
compounds dissolved in ground water. Alternative 3 would be successful in reducing the volume of
ground water contaminated with VOCs. Alternatives 10 and 12 would also provide some reduction
in ground water contaminant toxicity and mobility. Alternative 1 provides no treatment of VOCs in
the ground water.
Short-Term Effectiveness - Alternatives 3 and 4 offer the greatest short-term effectiveness
due to the ease and speed with which they could be implemented. Alternatives 10 and 12 require a
greater implementation period and could require a greater operational period due to their in situ
treatment methods. Alternative 1 involves minimal short-term effects but would not achieve remedial
goals.
Implementability - Alternative 1 offers the greatest implementability followed by Alternatives
3 and 4, which involve conventional technologies with proven reliability and performance.
Alternatives 10 and 12 are implementable but, due to their more innovative nature, their reliability and
performance are not well-documented and the availability of equipment and services may be limited.
Cost - The total estimated costs of the four alternatives which include active remediation fall
within a range of less than $150,000. The No Action alternative, Alternative 1, which includes
long-term ground water monitoring is the lowest cost alternative. Alternatives 3 and 4 are next in
cost, with very comparable total costs. Each of these two alternatives utilizes more conventional
technologies and, therefore, is less sensitive to potential variations in assumed technology costs. The
remaining alternatives in order of increasing cost are Alternative 12 and Alternative 10, both
innovative alternatives which may be sensitive to cost variations.
Decision Summary - 29
-------
State Acceptance - The preferred alternative, as discussed in the following section, is
acceptable to the NJDEP (see NJDEP letter of concurrence, Appendix A.
Community Acceptance - Community acceptance of the preferred alternative has been
evaluated on the basis of public comments, as is described in the'Responsiveness Summary of this
ROD
X. SELECTED REMEDY
The following section describes in detail the remedial action which the FAA, in concurrence
with EPA, has selected to implement at Areas 29 and K. The selected remedial alternative for Areas
29 and K at the FAA Technical Center is Alternative 4, Ground Water Extraction and Carbon
Adsorption, and Excavation and Off Site Disposal of Soils Contaminated with PCBs and/or TPH, as
presented in the Proposed Plan. Because of the design's preliminary nature, changes could be
implemented during the final design and construction processes to address unforeseen conditions and
more cost-effective remedial technologies for ground water extraction, treatment and recharge. Such
changes will reflect modifications resulting from the engineering design process and will not
substantially change the intent of the selected alternative described herein.
PCB-contaminated soils which exceed the NJDEP non-residential cleanup criterion of 2 ppm
will be excavated and disposed of off site at a landfill licensed and permitted to handle the waste. The
main areas of excavation will be within the circular burn area, adjacent to the concrete burn pad, and
in the former drum storage area (Area K). The volume of soil requiring excavation is estimated to
be approximately 350 cubic yards. Based on existing data, the chemical concentrations in the
excavated soils are not expected to exceed land disposal restrictions. Prior to off site disposal,
remedial sampling and analysis to further characterize the excavated surface soils will be performed.
In association with the soil excavation activities, the circular burn area and concrete burn pad will be
demolished and the demolition debris will also be further characterized for off site disposal. Disposal
of these materials will be performed in accordance with RCRA regulations and Toxic Substances
Control Act (TSCA) regulations which address the remediation of PCB-contaminated materials, as
well as with state and local regulations.
The TPH-contaminated soils beneath the former 10,000-gallon underground storage tank
location will be excavated and disposed of off site at a landfill licensed and permitted to handle the
waste. The soils exceeding the NJDEP total organic compound cleanup criteria of 10,000 ppm,
estimated to be approximately 50 cubic yards in volume, will be excavated for off site disposal. Prior
to off site disposal, remedial sampling and analysis to further characterize the excavated soils will be
performed. Disposal of these soils will be performed in accordance with RCRA and NJDEP industrial
waste disposal regulations.
Perched ground water will be extracted and treated using carbon adsorption. Pre-treatment
of water to remove iron and other metals or sequestration may be employed to minimize fouling of
carbon beds and the reinjection system. Other dissolved VOC treatment technologies may be
employed as a substitute for carbon adsorption, as long as they meet or exceed the treatment
efficiency of carbon adsorption. Treated ground water will be reinjected back into the subsurface.
Decision Summary - 30
-------
Although not required by EPA, the FAA will establish a Declaration of Environmental
Restrictions where constituents of concern in soil exceed the New Jersey residential soil cleanup
criteria, to prevent further development of the site for residential use.
XL STATUTORY DETERMINATIONS
Under Section 121 ofCERCLAand Section 300.430(f) of the NCP, selected remedies must
meet certain statutory and regulatory requirements. These requirements and a description of how the
selected remedy satisfies each requirement are presented below.
Protection of Human Health and the Environment
The preferred alternative provides the greatest overall protection of human health and the
environment by providing remediation of soil contaminants and treatment of both VOCs and SVOCs
in perched ground water. It is effective in the short term, with only minimal risks associated with its
installation and operation. It also utilizes a proven treatment technology which is readily
implemented, and its long-term effectiveness and permanence are expected to be good.
Compliance with ARARs
The selected remedy will attain federal ARARs and those New Jersey ARARs which are more
stringent than federal ARARs for ground water, as well as TBCs for soil quality. A summary of
applicable chemical-specific, location-specific and action-specific ARARs and TBCs is presented by
media in Table 5. Table 6 presents numerical chemical-specific ARAR and TBC values.
The selected remedy is expected to achieve compliance with NJDEP's non-residential soil
cleanup standards for PCBs (2 ppm) and total organic compounds (including TPH) (10,000 ppm)
through the excavation and off site disposal of any soils exceeding these standards. ARARs for
ground water (the most stringent of state or federal MCLs and New Jersey Ground Water Quality
Standards) will be achieved through the extraction of perched ground water and subsequent treatment
through carbon adsorption.
The regulations established under RCRA, the Hazardous Materials Transportation Act,
TSCA, the New Jersey Hazardous Waste Regulations, the New Jersey Hazardous Discharge Site
Remediation Requirements, and the New Jersey Pollutant Discharge Elimination System will apply
to the implementation of this alternative. Compliance with the Pinelands Protection Act, including
the Pinelands Comprehensive Management Plan, a TBC, will be required due to the facility's location
within the Pinelands.
Cost-Effectiveness
The selected remedy is comparable in cost to the other alternatives which provide remediation
of the contaminated soils and the treatment of perched ground water. The alternatives are similar in
their handling of contaminated soils but vary in their means of ground water treatment. The ground
water treatment component of Alternative 4 provides treatment of both VOCs and SVOCs while
utilizing a proven treatment technology. Therefore, it provides the greatest overall cost-effectiveness
of the alternatives considered.
Decision Summary - 31
-------
TABLE 5
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
AND TO-BE-CONSIDERED CRITERIA (TBCs)
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
CHEMICAL-SPECIFIC ARARS (Also see Table 6)
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 7:105.1-5.3]
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 quality criteria for Class I-PL (Protection Area) shall be
background water quality, 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 seven 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 quantitation level (PQL), as that
term is identified 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. 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 seven constituents in ground water of concern at Areas 29 and
K of the FAA Technical Center are listed in Table 6.
Decision Summary - 32
-------
TABLE 5 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
. AND TO-BE-CONSIDERED CRITERIA (TBCs)
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
CHEMICAL-SPECIFIC TBCs
NJ Soil Cleanup Criteria
Non-promulgated criteria used to determine the potential need for soil remediation
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 aquifers from actions by federally-funded
programs
LOCATION-SPECFIC 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-SPECIFIC ARARS
NJ Water Pollution Control Act
NJPDES Permit/Discharge Requirements [NJAC 7:14A-2.1]
State standards for discharges to ground water
NJ Water Supply Management Act
General Water Supply Management Regulations [NJAC 7:19-1.4, 1.5, 1.6(b) and 2.2]
Well Drilling Permits [NJSA 58:4A-14]
Well Certification Forms [NJAC 7:8-3.11]
State regulations governing the extraction of ground water at a rate which exceeds 100,000
gallons per day and the drilling and construction of new wells; applicable should the
extraction rate of the ground water extraction system exceed 100,000 gallons per day and
applicable to the installation of ground water extraction wells
Toxic Substances Control Act
Requirements for PCB Spill Cleanup [40 CFR 761.125]
Establishes requirements for the removal and disposal of PCB-contaminated materials.
Decision Summary - 33
-------
TABLE 5 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
AND TO-BE-CONSIDERED CRITERIA (TBCs)
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Resource Conservation and Recovery Act (RCRA)
Identification and Listing of Hazardous Waste [40 CFR 261]
Waste classification procedures applicable to the characterization of excavated soils and spent
carbon
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 wastes shipped off site are determined to be hazardous
RCRA
Standards Applicable to Transporters of Hazardous Waste [40 CFR 263]
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 wastes
shipped off site are determined to be hazardous
NJ Solid Waste Management Act
NJ Hazardous Waste Regulations [NJAC 7:26-8.5]
Waste classification procedures applicable to the characterization of excavated soils and spent
carbon
Decision Summary - 34
-------
TABLE 6
CHEMICAL-SPECIFIC ARABS AND TBCS
AREA 29 - FIRE TRAINING AREA AND
AREA K - STORAGE AREA NEAR AREA 29
FAA TECHNICAL CENTER
Ground Water
Parameter
Benzene
Ethylbenzene
Methylene Chloride
Toluene
Xylene (total)
Tetrachloroethene
1,1,1-Trichloroethane
Soil
Parameter
PCBs
Total Organics
Federal
ARARS febW%4
MCLTt) V
5
700
1,000
10,000
5
200
State w- ...
.- -^-^^ARS^obbV^^- :
v/ ^x^Cx QWQS<3) '
- NJMCL{2) FPQL]
1 HI
[5]
2 [2]
[5]
44 [2]
1 [1]
26 [1] |
i
State TBCs toom)
Non-Residential Soil
Cleanup Criterion (4)
2
10,000
(1) MCL - Maximum Contaminant Level. National Primary Drinking Water Regulations, Final
Rule
(2) Maximum Contaminant Level for Drinking Water; NJ Safe Drinking Water Act,
NJAC7:10-16.7
(3) Ground Water Quality Standards; based on Class I-PL (Protection Area, ground water
quality criteria shall be the background ground water quality. As discussed in the
associated text, when the background water quality is lower than the Practical Quantitation
Level (PQL), a discharge will not contravene the standard so long as the concentration of
the constituent is less than the relevant PQL.
(4) Compliance with the PCB soil cleanup criterion is determined based on compliance
averaging procedures as described in NJDEP Site Remediation News, Spring 1995,
Volume 7, No. 2; compliance averaging is not applicable to the total organic soil cleanup
criterion.
Decision Summary - 35
-------
Utilization of Permanent Solutions and Alternative Treatment Technologies
The FAA, in cooperation with EPA, has determined that the selected remedy utilizes
permanent solutions and treatment technologies to the maximum extent practicable. This
determination was made based on the comparative evaluation of alternatives with respect to long-
term effectiveness and permanence, reduction of toxicity, mobility, or volume through treatment,
short-term effectiveness, implementability, and cost, as well as the statutory preference for treatment
as a principal element and state and community acceptance.
The main difference between the alternatives is related to the ground water treatment
technology utilized. Alternative 4 provides for permanent treatment of the ground water
contaminants through extraction and treatment utilizing carbon adsorption. The contaminants are
permanently removed from the ground water and transferred to the carbon media for subsequent
disposal or regeneration. The proven nature of the carbon adsorption technology in treating the
COCs ensures its effectiveness in meeting the remediation goals of the treatment process. The
technology is readily implemented and presents minimal short-term risks. The excavation and off site
disposal of contaminated soils provides for the permanent elimination of the potential for direct
contact with constituents in these media as well as the removal of these materials from acting as a
potential source of ground water contamination.
Preference for Treatment as a Principal Element
The preferred alternative addresses the principal threat, which is associated with the presence
of contaminants in the perched ground water at levels which present unacceptable risks to human
health, through treatment of the ground wafer. Extraction of perched ground water followed by
carbon adsorption will provide treatment of the ground water contamination and will lessen the
potential for the movement of dissolved constituents from the perched water table into the true water
table. The preferred alternative also addresses the presence of PCBs and TPH in soils through off
site disposal of soils which do not meet New Jersey non-residential soil cleanup criteria (TBCs).
XH. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Proposed Plan for Areas 29 and K was released for public comment on April 11, 1996.
The Proposed Plan identified Alternative 4, Ground Water Extraction and Carbon Adsorption, and
Excavation and Off Site Disposal of Soils Contaminated with PCBs and/or TPH as the preferred
remedy. FAA received no written and verbal comments on the Proposed Plan, either during the
public meeting or the subsequent 30-day comment period. Consequently, it has been determined that
no significant changes to the remedy, as originally identified in the Proposed Plan, are necessary.
Decision Summary - 36
-------
RESPONSIVENESS SUMMARY
RECORD OF DECISION
Area 29 - Fire Training Area and
Area K - Storage Area Near Area 29
FAA Technical Center
The purpose of this Responsiveness Summary is to review public response to the Proposed Plan for
Areas 29 and K. 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 Areas 29 and K.
Background on Community Development - This section provides a summary of community
interest in Areas 29 and K and identifies key public issues. It also describes community
relations activities conducted with respect to these areas 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 29 is located northeast of Atlantic City International Airport runways and
southwest of White Horse Pike and was constructed in the early 1970s for the training of airport fire
fighting personnel. Area K is located northwest of the test burn areas at Area 29 and was formerly
used to store drums and tanks. This Responsiveness Summary addresses public response to the
Proposed Plan for Areas 29 and K only.
The Proposed Plan and other supporting information for Areas 29 and K 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 EI/FS activities conducted at
Areas 29 and K.
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.
Responsiveness Summary - 1
-------
On April 11, 1996, a newspaper notification was published in the Atlantic 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 Areas 29 and K EI/FS results were discussed. FAA representatives included: Keith C.
Bucn, Program Manager, Howard Kimpton, Supervisor, Environmental Section and Gary Poulsen,
Manager, Facility Engineering and Operations Division. Betsy Donovan, Remedial Project Manager,
Federal Facilities Section represented the USEPA Emergency and Remedial Response Division, and
Ian Curtis, Case Manager, represented the NJDEP Bureau of Federal Case Management. Sean
Clancy represented the Atlantic County Health Department. TRC Environmental Corporation, FAA's
environmental contractor, also attended. The complete attendance list is provided as Appendix B to
this ROD. A transcript of the public meeting is provided as Appendix C.
Ill SUMMARY OF MAJOR QUESTIONS AND COMMENTS
No questions or comments with regard to the Proposed Plan for Areas 29 and K 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.
Responsiveness Summary - 2
-------
APPENDIX A
NJDEP AND PINELANDS COMMISSION
LETTERS OF CONCURRENCE
-------
of
Clirislinc Todd \Vhitman Dcp
-------
The previously submitted Proposed Plan for Areas 29 and K had been reviewed and
approved by the NJDEP prior to this latest revision. This copy/revision of the Proposed
Plan has undergone minor changes in order clarify certain statements to make the
Proposed Plan more consistent with other decision documents at the FAA Technical
Center and other USEPA decision documents.
The Proposed Plan is approved subject to approval of the Pinelands Commission, and
addressing the comments below.
Page 6; In regard to the PCBs in the soil. The current soil cleanup criteria of PCBs
is 0.49 for residential use, and 2 ppm for non-residential (industrial) use. These
criteria are applicable through the entire soil column (please see attachment).
Further, the Impact To Ground Water criteria - stated as 100 ppm - is incorrectly
used and has been modified to 50 ppm to be consistent with TSCA requirements.
Impact to ground water criteria is a "screening" criteria which should be used to
determine if ground water investigation is necessary. In the event that FAA
chooses to cleanup the soils to the non-residential cleanup criteria, a Declaration
of Environmental Restriction (DER - deed restriction) will be necessary.
A major remedial objective for the remediation of Areas 29 and K is the reduction
in the human health risks and Hazard Index. The NJ required risk criteria is 10"6
and hazard index is 1. Please state this a remedial action objective.
The NJDEP has determined that Alternative 4 and the Proposed Plan is consistent with
State regulations and policies. Based on discussions with Kathy Swigon of the Pinelands
Commission, the Pinelands Commission will be commenting on this Proposed Plan
separately from the NJDEP. Pinelands Commission approval must be obtained prior to
implementation of the Proposed Plan.
If you should have any questions or require additional information, please do not hesitate
to contact me at (609) 633-1455.
Sincerely,
Bruce Venner, Chief
Bureau of Federal Case Management
cc. Kathy Swigon, Pinelands Commission
Betsy Donovan, USEPA - Region II
George Nicholas, BGWPA
Steve Byrnes, BEERA
-------
THE PINELANDS COMMISSION
POBox?
NEW LISBON NJ 08064
(609) 894-9342
CHRISTINE TODD WHITMAN
Governor
April 25, 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. 87-0046.12
Areas 29 & K
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 Area2 29 & K at the FAA Technical Center.
The Plan will be consistent with the. minimum standards of
the Pinelands Comprehensive Management Plan provided that the
groundwater extraction, treatment and reinjection system is
designed to comply with the non-degradation water quality stan-
dards and other applicable standards. Please refer to our March
13, 1996 letter (enclosed) regarding Commission concerns and ap-
plication requirements for the proposed remedial design.
If you have any questions, please contact our development
review staff.
Sincerely,
William F. Harrison, Esq.
Assistant Director
Encl(l): March 13, 1996 letter
cc: Keith Buch
Jean Oliva (with enclosure)
The Pinelands Our Country's First National Reserve
, .^ - and an International Biosphere Reserve
*V *
"*«, co»* iiew jersey Is An Equal Opportunity Employer Printed on Recycled and Recyclable Paper
-------
In addition to meeting the water quality standards of the
CMP, the proposed remedial action must comply with all applicable
requirements of the CMP, including the standards relating to vet-
lands protection and protection of threatened and endangered
species. Prior to implementation of the remedial alternative, it
will be necessary for the Pinelands Commission to determine that
the remedial design plans are consistent with the CMP. In order
for the Commission to make such a determination, the following
information must be provided:
1. Fill out, sign, have notarized and return the Pinelands
Comprehensive Management Plan's Application (enclosed).
2-. A dated plan showing the location of all existing and
proposed development including all existing and
proposed equipment, facilities, the treatment system
extraction and injection wells, monitoring wells,
pipelines, buildings, structures, parking areas, roads,
limits of disturbance and clearing and driveways.
3. The limits of any wetlands located within 300 feet of
the project must be indicated on a plan.
4. Modeling of the expected impacts of the system on the
perched groundwater and an analysis of the expected ef-
ficiency of the treatment unit in reducing the con-
centration of each contaminant of concern.
Table 5 of the submitted ROD contains a list of ARAR's for
the site. The table should include the requirements of the
Pinelands Comprehensive Management Plan (N.J.A.C. 7:50-1.1 et
seq.) in this list. The standards of the CMP are ARAR's.
If you have any questions, please contact our development
review staff.
. . ,
William F. Harrison, Esq.
Assistant Director
TD
Encl(l): Application Form
cc: Keith Buch
Jean Oliva
-------
THE PINELANDS COMMISSION
POBox7
NEW LISBON NJ 08064
(609) 894-9342
CHRISTINE TODD WHITMAN
Governor
March 13, 1996
Ian Curtis
NJDEP Bureau of Federal Case Management
CN 028
401 East State Street
Trenton, NJ 08625-028
Please Always Refer To
This Application Number
RE: App. No. 87-0046.12
FAA Technical Center
Areas 29 & K
Egg Harbor Township
Dear Mr. Curtis:
The Commission staff has received and reviewed the Revised
Draft Final Proposed Plan and the Record of Decision (ROD)
regarding the remediation of soils and groundwater for Areas 29 &
K at the FAA Technical Center. The revised Plan proposes the in-
stitution of a Declaration of Environmental Restriction (DER) for
soils.
The proposed remedial alternative described in the draft ROD
will be consistent with the water quality standards of the
Pinelands Comprehensive Management Plan (CMP) provided that the
groundwater extraction, treatment and re-injection system is
designed so that:
1. Prior to re-injection, the concentrations of the con-
taminants of concern in the treated groundwater are reduced
to a levels that do not exceed the Practical Quantitation
Levels as defined in N.J.A.C. 7:9-6.4, or
2. The design and location of the components of the ex-
traction, treatment and re-injection system ensure that, as
monitored in groundwater monitoring wells installed on the
site, the concentration of contaminants in the treated
groundwater at the site are reduced to levels do not exceed
the PQL for each contaminant of concern.
The Pinetands Our Country's First National Reserve
and an International Biosphere Reserve
New Jersey Is An Equal Opportunity Employer Printed on Recvcled and Recyclable Paper
-------
APPENDIX B
PUBLIC MEETING ATTENDANCE LIST
-------
SIGN-IN SHEET
PUBLIC MEETING
MAY 2,1996
PROPOSED REMEDIAL ACTION AT
AREAS 29, K, & B
FAA TECHNICAL CENTER
ATLANTIC CITY INTERNATIONAL AIRPORT, NEW JERSEY
NAME ADDRESS PHONE NUMBER
2.
3.
4.
5.
/In.
J
9.
2.
3.
-------
APPENDIX C
PUBLIC MEETING TRANSCRIPT
-------
»
tr
1C
a.
tc
O
to
c
C.
O
tr
o
tr
o
o
UJ
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PUBLIC MEETING
To Discuss the Proposed Remedial Action at
Area 29 - Fire Training Area
Area K - Storage Area Near Area 29
Area B - Former Navy Fire Test Facility
FAA Technical Center
Atlantic City International Airport, NJ
Thursday, May 2, 1996
2:00 p.m.
Atlantic County Library
2 South Farragut Avenue
Mays Landing, NJ 08330
-APPEARANCES
For the FAA Technical Center;
For TRC Environmental Corp.;
KEITH C. BUCK, Program Manager
FAA Technical Center
LARRY BUTLIEN, Project Hydro-
geologist, TRC Environmental
Corporation
JEAN M. OLIVA, P.E., Project
Engineer, TRC Environmental
Corporation
GCI TRANSCRIPTION AND RECORDING SERVICES
505 HAMILTON AVENUE, Suite 107
LINWOOD, NEW JERSEY 08221
(609) 927-0299 FAX (609) 927-6420
1-800-471-0299
-------
1
2
2
4
5
6
7
| 8
IT
O)
2 Q
u. s
tr
o
u- 10
o
ft 11
(C
UJ
CO
5 12
13
14
o
| 15
i
a.
1 U
m 18
" 19
I
20
21
22
23
24
25
INDEX
Opening Remarks and Introductions
Keith C. Buch, Program Manager
FAA Technical Center
Environmental Investigation
Overview (Areas 29 and K)
Larry But lien, Project Hydrogeologist
TRC Environmental Corporation
Risk Evaluation and Feasibility
Study Overview and Presentations
of Proposed Plan (Areas 29 and K)
Jean M. Oliva, P. E., Project Engineer
TRC Environmental Corporation
Environmental Investigation
Overview (Area B)
Larry But lien
Risk Evaluation and Feasibility
Study Overview and Presentation
of Proposed Plan (Area B)
Jean M. Oliva, P.E.
Final Remarks
Keith C. Buch
Questions and Answers
Page 2
Page 3
Page 5
Page 12
Page 15
Page 22
Page 26
None
5-2-96
-------
Page 3
s
tc
in
cc
o
O
e
CO
a:
tu
CO
a.
o
tc
o
o
o
IU
Tape #CP-4-96, Index #0025 at 2:00 p.m.)
MR. BUCK: Hello. My name is Keith Buch. I'm the
FAA Superfund Program Manager, and welcome to today's public
hearing for Area 29 and Area B. The public hearing was duly
advertised in the Press of Atlantic City as required by the
Superfund regulations. We expect that after today's public
hearing to have a finalized rod within how many days,
Jean?
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
IE remedial investigations and feasibility studies and designs
that are required to effectuate a proper Superfund Cleanup.
17 I'd like to introduce Jean Oliva from TRC and Larry Butlien
is 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
-------
CC
03
u_
c
o
o
o
CO
c
LU
CO
Q.
O
tt
c
(C
O
U
LU
Page 4
In 1980 and 1981 contamination was found at the
Price's Pit Landfill. This contamination also affected the
Atlantic City well field which wa's located adjacent to
Price's Pit. Price's Pit is a Superfund site which is
located about three to four miles east-southeast of the
Technical Center. In 1981 the New Jersey Department of
Environmental Protection (NJDEP) and the Atlantic City
Municipal utility Authority (ACMUA) hired Roy F. Weston to
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
is 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 required. 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 require evaluation.
25 All the work that TRC has performed has been in
5-2-96
-------
Page 5
(0
u.
tr
S
o
e
IB
Jt
s
O
I
O
U
Ul
accordance with all applicable federal and state
environmental laws, statutes and regulations. The FAA has
worked closely with USEPA, the New Jersey DEP, Atlantic
County Health Department, and the Pinelands Commission. Eact
step of the investigative process has been reviewed and
approved by these organizations and no work has been
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
u 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
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
5-2-96
-------
0>
c
CO
o
O
fe
tc
UJ
en
o
in
in
a.
O
£C
a
§
ui
I
t-
Page 6
personnel. The area contains a 150 foot-diameter burn pad
and a smaller concrete burn pad where test burns were
conducted. The area also contained two underground storage
tanks for the collection of run-off from the burn pads and
two above ground tanks located on a small hill. The two
underground tanks were emptied, removed, and disposed of
off-site in an environmentally acceptable manner in December
s 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
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.
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
is 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
5-2-96
-------
tr
CO
11.
c
o
u.
*
U
o
5
tr
ui
(O
o
s
8
C.
o
IE
O
O
Ul
Page 7
recently from the small hill looking northeast along the
dirt road. The small concrete burn pad is in the center of
the photograph and Area X is located on the far left-hand
side of the photo.
This is a photograph taken recently from the small
hill looking east toward the large circular burn pad, and
note the current conditions showing standing water in the
middle of the burn pad.
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
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
is 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
5-2-96
-------
Page 8
water. The initial investigation was conducted by Roy F.
Weston in 1983 as part of the Atlantic City well field
relocation study. During this initial investigation, Weston
installed and sampled three ground water monitoring wells of
which one exhibited significant levels of organic compounds.
TRC's Phase I investigation at Areas 29 and K
during 1987 included preliminary investigations including a
a
soil gas and a geophysical investigation. In addition, a |
10
total of sixteen surface soil samples were collected, four '_
&
o
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 aquifer.
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
«
I
-------
Page 9
accomplished by collecting a total of seven surface soil
samples and eight subsurface soil samples at the base of the
tank-excavations. As mentioned earlier, the two underground
tanks were removed during the Phase II investigation. The
Phase II results further defined the lateral extent of PCB
contamination in the surface soils while elevated levels of
TPH were detected in the soils beneath the ten thousand
gallon storage tank.
This next slide shows the locations of the Phase I
10 surface soil samples. Four subsurface soil samples were
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
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
1B 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 quality
24 standards. Specifically, PCB contamination has been detected
25 in the site's surface and subsurface soils. TPH
5-2-96
14
-------
tr
u.
o
u.
*
in
tc
in
3
CM
8
Q.
O
§
oc
o
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 10
contamination was also identified in the subsurface soils. .
And finally, VOC contamination has been identified in the
perched ground water aquifer above ground water quality
standards. Results from the quarterly ground water sampling
program have not identified contaminated ground water within
the true water table aquifer at levels above ground water
quality standards.
This slide shows locations of soil contamina
where soil contamination exceeds the current soil cleanup
criteria. Specifically, the areas include surface soils
contaminated with PCBs in the immediate vicinity of Area K,
the area surrounding the small concrete burn pad, and within
the large circular burn pad. The maximum PCS level detected
in the surface soils was thirty parts per million (ppm).
NJDEP soil cleanup criteria for PCBs is two parts per
million. The other area of soil contamination is at the
location of the former ten thousand gallon underground
storage tank. At this location the maximum level of TPH
contamination was fourteen thousand ppm. The NJDEP soil
cleanup criteria for total organics is ten thousand ppm.
As mentioned earlier, during the environmental
investigations at Area 29, a zone of perched ground water was
identified across the site. This perched zone was identified
as underlying a significant portion of Area 29 including the
circular and concrete burn pads. This slide represents a
5-2-96
-------
EC
CO
u.
It
s
X
8
to
tr
UJ
£
g
00
n.
§
CD
cc
o
o
ui
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 11
schematic geologic cross-section of Area 29 showing the
relationship between the perched and true water table
aquifers. As you can see, the perched water table is
situated above the true water table and is relatively limited
in lateral and vertical extent. The perched ground water is
formed where the soil in the unsaturated zone is locally
saturated because it overlies a low-permeability silty clay
or clayey silt zone situated above the true water table.
During the investigation the clay unit was identified as
being variable in thickness ranging between two and sixteen
feet thick with the surface of the clay unit found at a depth
of ten to fourteen feet below the ground surface. While
ground water flow in the regional true water table aquifer
was determined to be toward the east-southeast, the flow of
perched ground water was estimated to be much more variable
due to localized changes in the slope of the surface of the
clay unit.
This slide represents an approximation of the
aerial extent of ground water contamination in the perched
zone where ground water quality standards have been exceeded.
Ground water results from monitoring well 29-MW2S have
consistently exhibited VOCs above ground water quality
standards, while exceedances of ground water qualities
standards have been more sporadic and periodic in monitoring
well 29-MW3S.
5-2-96
-------
cc
(A
u_
CC
O
O
O
w
IT
Ul
O
O
>
ffl
CC
O
O
111
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 12
This slide represents a contour map and ground
water flow direction of the true water table aquifer. As
stated earlier, the ground water flow direction in the true
water table aquifer is toward the east-southeast direction as
represented by contouring the water level elevations in the
wells screened in the true water table aquifer.
I would now li.ke to turn the presentation over to
Jean Oliva of TRC. She will summarize the risk evaluation
and the remedial action objectives associated with Areas 29
and Area K.
MS. OLIVA: Thank you, Larry. As Larry mentioned,
my name is Jean Oliva and I'm a project engineer with TRC
Environmental Corporation and I have been involved in
feasibility study activities at the FAA Technical Center
since 1989.
(SLIDE PRESENTATION CONTINUED)
Based on the results of the site investigations, a
human health risk assessment was conducted to evaluate
potential risks associated with exposures to soil and ground
water. Ground water ingestion was evaluated even though
there is no drinking water well currently located at Areas 29
or K. The risk estimated for ground water ingestion was
above acceptable limits indicating that a remedial response
is appropriate. A qualitative assessment of ecological risks
also identified a potential risk to wildlife.
5-2-96
-------
I
03
s
u.
i
o
en
cc
Ul
to
in
g
ffi
tc
o
o
m
Page 13
Based on the results of the risk assessment and th
site investigation/ objectives were developed for a remedial
response as listed here. In general these objectives include
preventing exposures to contaminants in soil and ground water
and minimizing the potential migration of these contaminants
Based on these objectives, a feasibility study was conducted
This slide highlights the elements of a feasibility
study. Initially, remedial technologies are identified and
screened to determine which technologies are most appropriate
10 for use at the site. The selected technologies are then used
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
is 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
2s phase. The second of the two alternatives involves
5-2-96
-------
z
CE
CO
u.
5
EC
£
*
o
tr
ID
CO
o.
o
cc
o
ec
o
o
01
2
3
4
5
6
7
e
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 14
carbon adsorption in which the ground water
contaminants are transferred to a carbon filter
media. The last two remedial alternatives employ
in situ, or in-place, remedial actions which do not
, involve ground water extraction. They would also
be combined with soil excavation and off-site
disposal. The first of the two in situ remedial
alternatives uses processes similar to air
stripping but applies them below ground to remove
contaminants from the ground water. The second
alternative uses microbes to break down the ground
water contamination.
Each of the remedial alternatives underwent a
detailed evaluation based on the nine criteria listed here.
The alternatives and their evaluations are described in more
detail in the proposed plan. Compliance with the last
criterion community acceptance will be determined based on
public comments which I'll discuss in more detail later in
this presentation.
Based on the detailed analysis of the remedial
alternatives, a preferred remedy was selected for Areas 29
K. The preferred remedy consists of ground water extraction
and treatment using carbon adsorption in combination with
soil excavation and off-site disposal as well as the
establishment of a Declaration of Environmental Restrictions
5-2-96 i
-------
tr
w
tr
o
o
e
CO
tr
UJ
en
8
o
>
m
tr
O
o
LU
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 15
to ensure that future residential site development does not
occur. This alternative offers the greatest overall
protection of human health in the environment through its
off-site disposal of contaminated soils and its ability to
treat the ground water contaminants. It is also cost-
effective and meets regulatory requirements.
I will now turn the presentation back to Larry
Butlien of TRC who will describe the investigations that
were conducted at Area B, the Navy Fire Test Facility.
Larry.
MR. BUTLIEN: Thanks, Jean.
(SLIDE PRESENTATION CONTINUED)
First I want to just talk briefly about the
background information and the results of the remedial
investigation at Area B.
Area B is located in the southwestern portion of
the FAA Technical Center property. The South Branch of
Doughty's Mill Stream is located along the southern portion
of the area. Area B is located approximately forty-five
hundred feet upstream of the Upper Atlantic City Reservoir.
This slide also shows the locations of Area 29 and K, and
other areas of concern relative to Area B.
Area B is referred to as the Navy Fire Test
Facility. The area was used during the late 1950's and early
1960's for aircraft fire training. A review of historical
5-2-96
-------
cc
(/)
ll-
CC
O
u.
X
O
1
HI
to
O.
O
tr
c
I
o
O
UJ
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I
Page 16
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
exhibited dark-colored stains. By 1965 the area had been
grassed over. A portion of the area was later used for GSA
motor pool parking. Today a majority of Area B is grass-
covered with a heavily wooded area in the souther portion of
the site along the stream.
This next slide shows the general layout of Area B.
Shown are the approximate limits of the Navy Fire Test Area
and then the smaller area showing the GSA Motor Pool parking
location. Also note the South Branch of Doughty's Mill
Stream along the southern portion of the area and that the
and also the location of the former wastewater treatment
plant which was closed and demolished in 1992.
This photo was taken in 1988. It shows the
southern portion of the site. I'm sorry. This photo was
taken in 1987 from the northern portion of Area B looking
southwest toward the wastewater treatment facility. Note the
dirt road which essentially separates Area B into the
northern and southern halves, and also note that the area is
generally an open grassy field.
This next photo was taken in 1988 and shows the
southern portion of the site. The South Branch of Doughty's
5-2-96
-------
1C
in
£
cc
s
W
tc
0.
o
-------
z
a.
CO
u.
cr
£
*
o
e
CO
cc
g
0.
g
tl
c
ffl
re
UJ
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 18
headspace readings were measured in the soil samples
collected from each soil boring. Elevated readings were
plotted to determine the lateral extent of the subsurface
contamination associated with the floating product. In
addition, a sample of the floating product was collected and
was determined to be similar to gasoline. Finally, a sample
of ground water beneath the floating product was collected
and analyzed and it determined to exhibit elevated levels of
VOCs.
This next slide shows the locations of the Phase II
soil borings drilled in the vicinity of well MW3S. It also
shows the approximate extent of the floating product based on
the elevated headspace readings. Also note the direction of
shallow ground water flow toward the southeast, which is
toward the South Branch.
During 1989 TRC conducted a supplemental
investigation. The purpose of this investigation was to
further define the subsurface soil quality in the area of the
floating product. This was accomplished by drilling two soil
borings and collecting three subsurface soil samples for
chemical analysis. The results of the soil testing did not
indicate any exceedance of federal or state soil standards.
This next slide shows the locations of the
supplemental investigation soil borings drilled adjacent to
well MW3S.
5-2-96
-------
cc
CO
u.
tt
o
CO
DC
UJ
o
^-
o
in
ffi
CJ
o.
o
cc
m
(C
O
U
UJ
10
11
12
. 13
14
15
16
17
18
19
20
21
22
23
24
25
Page 19
A number of additional investigations were
conducted at Area B to determine the source of the
contamination and to further delineate the nature and extent
of ground water contamination at the site. During August of
1992 a HydroPunch study was conducted and focused on areas of
stained soils and aircraft staging areas that were visible in
the historical aerial photographs. A total of ten HydroPunch
locations were sampled in which shallow ground water was
collected. The results of this study did not identify a
source of the floating product.
The next investigation occurred in January of 1993
and included the installation of two additional monitoring
wells, downgrading of well MW3S to further define the nature
and extent of dissolved ground water contamination. These
wells were sampled during February and May of 1993 and
determined to contain several chlorinated VOCs at levels
above federal and state ground water quality standards.
During July of 1993 a Geoprobe investigation was
conducted to further define the extent of the floating
product as well as the nature and extent of dissolved ground
water contamination up gradient and down gradient of well
MW3S. A total of twenty-six .Geoprobe ground water samples
were collected during this investigation. The results of the
Geoprobe samples resulted in the installation of four addi-
tional monitoring wells, one located up gradient, one side
5-2-96
-------
c
w
-
CD
tc
O
O
10
n
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 20
gradient, and two down gradient of well 3S. In addition, one
subsurface soil sample was collected and analyzed from each
of the new monitoring well soil borings. The results of this
investigation further defined the extent of the floating
product and the nature and extent of the dissolved ground
water contamination plume.
Lastly, a program of guarterly ground water and
surface water monitoring was implemented at Area B starting
in February of 1993 and is still ongoing. The purpose of the
monitoring was to determine trends in the dissolved ground
water contamination, evaluate the South Branch surface water
quality adjacent to the site, and to measure the product
thickness in well MW3S.
(POSTER BOARD)
I would like to now direct your attention to. the
poster board I'll move it a little closer. This poster
board basically shows the colored areas which represent the
historical ground scars and stained soils that were
indicated from the aerial the historical aerial
photographs. Shown on this poster are all the environmental
investigations that have been conducted during the Phase I
and Phase II supplemental in the HydroPunch investigation.
The HydroPunch investigation focused on areas within or down
gradient of the stained soil area as represented by these
black symbols here, and this generally just gives you kind of
5-2-96
-------
o:
in
l
I
tr
UJ
CO
°
6
o
I
O
o
Ul
Page 21
a general overview of the historical site use with like I
said, of the ground stains and scars, and also shows airplan
fuselage locations relative to the various investigation
sampling locations.
5 (SLIDE PRESENTATION CONTINUED)
e This next slide shows the locations of the twenty-
7 six Geoprobe ground water samples and the four new monitoring
wells associated with the investigation. Also shown is the
updated approximation of the lateral extent of the floating
10 product plume in the vicinity of MW3S.
This next slide identifies the locations of the
12 three wells and the three surface water sampling stations
13 sampled during the ongoing quarterly 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 quality standards.
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 water contaminants exceeding the
25 ground water quality standards include aromatic and
5-2-96
-------
tr
CO
11.
c
o
u.
CO
tc
in
ni
o
a.
O
n
s.
UI
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 22
chlorinated VOCs. However, no specific contaminant source
area or areas have been identified during the various
investigations at Area B.
This shows the aerial extent of ground water
contamination where the ground water quality standards have
been exceeded. As you can see, this area is in the southern
portion of the site immediately north of the stream.
I would now like to turn the presentation back over
to Jean who will summarize the risks associated with the
contamination found at 'Area B, and also summarize the
remedial action objectives associated with the site.
MS. OLIVA: Based on the results of the site
investigations at Area B, a human health risk assessment was
conducted to evaluate potential risks associated with
exposures to the soil and ground water. Again, ground water
ingestion was evaluated even though a drinking water well
i
does not exist at Area B. The risk estimated for ground
water ingestion was above acceptable limits, indicating a
remedial response is appropriate. A quantitative assessment
of ecological risks also identified a potential risk to
wildlife.
Remedial objectives were developed for a remedial
response as listed here. The objectives include preventing
exposures to both the floating product and the ground water
contamination and minimizing the potential migration of these
5-2-96
-------
u.
1
u.
&
cc
UJ
(I)
S
in
in
a
tc
8
UJ
Page 23
, t
contaminants. Based on these objectives a feasibility study
was conducted.
The Area B Feasibility Study used the same
technology evaluation and alternative development process
which was used for the Areas 29 and K Feasibility Study.
e The remedial actions developed for Area B include
7 the no action alternative; there are three
e 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
n 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
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
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
5-2-96
-------
1C
in
u.
tr
O
u.
X
O
O
m
cc
u
o
^-
o
If}
B
o.
1
O
a
o
u
Ul
2
3
4
5
6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 24
product and ground water would be treated without
being extracted from the ground. The air
sparging/vapor extraction technology uses processes
similar to air stripping but applies them below
ground to remove the contaminants.
Each of the remedial alternatives underwent a
detailed evaluation based on the nine Superfund criteria
and, again, public comments will provide the basis for
determining compliance with the last criterion community
acceptance.
Based on the detailed analysis of the remedial
alternatives, no action is the preferred remedy for Area B
soils. For ground water at Area B, a preferred remedy and a
contingency remedy were selected. The preferred ground wate:
remedy consists of in situ treatment to the ground water
using air sparging and vapor extraction.
I wanted to describe the air sparging treatment
system. In air sparging treatment, air is injected beneath
the water table using an air sparging well. As the air
bubbles move upward to the soil, ground water and any
floating product which may be present, they strip away the
volatile contaminants. The air with the contaminants is then
extracted using a vapor extraction well and, if necessary, is
treated before being released. Additional testing needs to
be conducted at Area B to ensure that the subsurface
5-2-96
-------
CO
IT
O
O
ui
en
Q.
O
H.
O
tr
o
u
Ul
10
13
14
15
17
18
19
20
21
22
23
24
25
Page 25
conditions are appropriate for the use of this technology.
In the event that this preferred alternative is not
appropriate for use at Area B, then the contingency remedy
will be employed. And the contingency remedy consists of
floating products and ground water extraction with off-site
incineration of the floating product and air stripping of the
contaminated ground water.
In an air stripping system the extracted ground
water is allowed to flow down over packing material to a
stripping tower as air is blown countercurrent to the
direction of the water flow. As the air passes over the
water it strips away the volatile contaminants and they're
released through the top of the air stripper.
Both the preferred ground water remedy and the
contingency remedy are protective of human health in the
environment because they both treat the floating product and
the ground water contaminants. Since the contingency remedy
utilizes the same basic treatment processes as the cross-flow
I'm sorry as the air sparging vapor extraction/ they
offer both alternatives offer a similar degree of
effectiveness.
And this last slide shows the process that will be
used to determine the final remedial actions at Areas 29 and
K, and Area B. Through this meeting as well as an ongoing
thirty-day public comment period, the FAA is soliciting
5-2-96
-------
X
CO
u.
2
o
o
E
LU
in
CJ
g
Q.
O
1C
o
I
o
13
1U
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 26
public comments on the Proposed Plans. We're right in this
area here. Written comments will be accepted through May
10th and verbal comments will be accepted here this afternoon
following these presentations. Based on the Proposed Plan
and the public comments, a Records of Decision will be
prepared for each, Areas 29, K and Area B. The Records of
Decision will include Responsiveness Summaries which will
address all public comments which will be received during the
public comment period. Upon finalization of the Records of
Decision, a notice will be printed in the Press and a copy of
the Records of Decision will be placed in the Administrative
Record which is maintained in the reference section here at
the Library.
I will now turn the presentation back to Keith Buch
of the FAA Technical Center. Keith.
MR. BUCH: Well, thank you, Jean and Larry. I'd
just like to state for the record that all practices that led
to the contamination of ground water and soil that we have
previously viewed have been eliminated at the FAA Technical
Center, and that the FAA is currently in compliance with all
federal, state, and local regulations respecting the handling
storage and disposal of hazardous waste and materials.
At this point we will end the formal presentation
and will open the floor up to interested members of the
public that may have questions regarding what they've seen
5-2-96
-------
tc
CO
u.
IT
o
en
ff
ui
(0
s
g
CO
O.
O
IT
O
ffl
E
O
U
UI
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 27
for the past forty minutes. If you do have a question,
please state your name, affiliation, and address for the
record. Seeing that there's no members from the public in
the audience and there are no questions, I will now close
this public meeting. Thank you for coming and please come to
our next meeting.
(Ended at Index #1329 at 2:45 P.M.)
CERTIFICATION
I, CAROL PLATT, agent for GCI TRANSCRIPTION AND
RECORDING SERVICES, a Notary Public and State- and Federal-
ly-Approved Sound Recording operator and transcriber, do
hereby certify that the foregoing is a true and accurate
transcript of the TRC Public Meeting taken by electronic
sound recording at the time, place, and on the date herein-
before set forth.
CAROL PLATT
Notary Public of New Jersey
My Commission expires July, 1997
Dated:
5-2-96
------- |