EPA/ROD/R02-91/157 1991 EPA Superfund Record of Decision: NAVAL AIR ENGINEERING CENTER EPA ID: NJ7170023744 OU 04 LAKEHURST, NJ 09/30/1991 ------- CONSTANTINE SIDAMON-ERISTOFF REGIONAL ADMINISTRATOR US ENVIRONMENTAL PROTECTION AGENCY, REGION II (DATE) 3 SEPT. 1991 #SD SITE DESCRIPTION NAEC IS LOCATED IN JACKSON AND MANCHESTER TOWNSHIPS, OCEAN COUNTY, NEW JERSEY, APPROXIMATELY 14 MILES INLAND FROM THE ATLANTIC OCEAN (FIGURE 1). NAEC IS APPROXIMATELY 7,400 ACRES AND IS BORDERED BY ROUTE 547 TO THE EAST, THE FORT DIX MILITARY RESERVATION TO THE WEST, WOODLAND TO THE NORTH (PORTIONS OF WHICH ARE WITHIN COLLIERS MILL WILDLIFE MANAGEMENT AREA), LAKEHURST BOROUGH AND WOODLAND, INCLUDING THE MANCHESTER WILDLIFE MANAGEMENT AREA, TO THE SOUTH. NAEC AND THE SURROUNDING AREA ARE LOCATED WITHIN THE PINELANDS NATIONAL RESERVE, THE MOST EXTENSIVE UNDEVELOPED LAND TRACT OF THE MIDDLE ATLANTIC SEABOARD. NAEC LIES WITHIN THE OUTER COASTAL PLAIN PHYSIOGRAPHIC PROVINCE, WHICH IS CHARACTERIZED BY GENTLY ROLLING TERRAIN WITH MINIMAL RELIEF. SURFACE ELEVATIONS WITHIN NAEC RANGE FROM A LOW OF APPROXIMATELY 60 FEET ABOVE MEAN SEA LEVEL IN THE EAST-CENTRAL PART OF THE BASE, TO A HIGH OF APPROXIMATELY 190 FEET ABOVE MEAN SEA LEVEL IN THE SOUTHWESTERN PART OF THE BASE. MAXIMUM RELIEF OCCURS IN THE SOUTHWESTERN PART OF THE BASE BECAUSE OF ITS PROXIMITY TO THE MORE ROLLING TERRAIN OF THE INNER COASTAL PLAIN. SURFACE SLOPES ARE GENERALLY LESS THAN FIVE PERCENT. NAEC LIES WITHIN THE TOMS RIVER DRAINAGE BASIN. THE BASIN IS RELATIVELY SMALL (191 SQUARE MILES) AND THE RESIDENCE TIME FOR SURFACE DRAINAGE WATERS IS SHORT. DRAINAGE FROM NAEC DISCHARGES TO THE RIDGEWAY BRANCH TO THE NORTH AND TO THE BLACK AND UNION BRANCHES TO THE SOUTH. ALL THREE STREAM DISCHARGE INTO THE TOMS RIVER. SEVERAL HEADWATER TRIBUTARIES TO THESE BRANCHES ORIGINATE AT NAEC. NORTHERN TRIBUTARIES TO THE RIDGEWAY BRANCH INCLUDE THE ELISHA, SUCCESS, HARRIS AND OBHANAN RIDGEWAY BRANCHES. THE SOUTHERN TRIBUTARIES TO THE BLACK AND UNION BRANCHES INCLUDE THE NORTH RUCKLES AND MIDDLE RUCKLES BRANCHES AND MANAPAQUA BROOK. THE RIDGEWAY AND UNION BRANCHES THEN FEED PINE LAKE APPROXIMATELY 2.5 MILES EAST OF NAEC BEFORE JOINING TOMS RIVER. STORM DRAINAGE FROM NAEC IS DIVIDED BETWEEN THE NORTH AND SOUTH, DISCHARGING INTO THE RIDGEWAY BRANCH AND UNION BRANCH, RESPECTIVELY. THE PAINT BRANCH LOCATED IN THE EAST-CENTRAL PART OF THE BASE IS A RELATIVELY SMALL STREAM WHICH FEEDS THE MANAPAQUA BROOK. THREE SMALL WATER BODIES ARE LOCATED IN THE WESTERN PORTION OF NAEC: BASS LAKE, CLUBHOUSE LAKE, AND PICKEREL POND. NAEC ALSO CONTAINS OVER 1,300 ACRES OF FLOOD-PRONE AREAS, OCCURRING PRIMARILY IN THE SOUTH-CENTRAL PART OF THE BASE, AND APPROXIMATELY 1,300 ACRES OF PRIME AGRICULTURAL LAND IN THE WESTERN PORTION OF THE BASE. THERE ARE 913 ACRES ON THE EASTERN PORTION OF NAEC THAT LIE WITHIN MANCHESTER TOWNSHIP AND THE REMAINING ACREAGE IS IN JACKSON TOWNSHIP. THE COMBINED POPULATION OF LAKEHURST BOROUGH, MANCHESTER AND JACKSON TOWNSHIPS, IS APPROXIMATELY 65,400, FOR AN AREA OF APPROXIMATELY 185 SQUARE MILES. THE AVERAGE POPULATION DENSITY OF MANCHESTER AND JACKSON TOWNSHIPS IS 169 PERSONS PER SQUARE MILE, WHEREAS THE DENSITY OF LAKEHURST BOROUGH IS 3,061 PERSONS PER SQUARE MILE. THE AREAS SURROUNDING NAEC ARE, IN GENERAL, NOT HEAVILY DEVELOPED. THE CLOSEST COMMERCIAL AREA IS LOCATED NEAR THE SOUTHEASTERN SECTION OF THE CENTER IN THE BOROUGH OF LAKEHURST. THIS IS PRIMARILY A RESIDENTIAL AREA WITH SOME SHOPS BUT NO INDUSTRY. TO THE NORTH AND SOUTH ARE STATE WILDLIFE MANAGEMENT AREAS WHICH ARE ESSENTIALLY UNDEVELOPED. ADJACENT TO AND SOUTH OF NAEC ARE COMMERCIAL CRANBERRY BOGS, THE DRAINAGE FROM WHICH CROSSES THE SOUTHEAST SECTION OF NAEC PROPERTY. NAEC IS BORDERED TO THE WEST BY FORT DIX MILITARY RESERVATION. FOR THE COMBINED AREA OF MANCHESTER AND JACKSON TOWNSHIPS, APPROXIMATELY 41 PERCENT OF THE LAND IS VACANT (UNDEVELOPED), 57 PERCENT IS RESIDENTIAL, ONE PERCENT IS COMMERCIAL AND THE REMAINING ONE PERCENT IS INDUSTRIAL OR FARMED. FOR LAKEHURST BOROUGH, 83 PERCENT OF THE LAND IS RESIDENTIAL, 11 PERCENT IS VACANT, AND THE REMAINING SIX PERCENT COMMERCIALLY DEVELOPED. ------- IN THE LOCAL VICINITY OF THE NAEC, WATER IS GENERALLY SUPPLIED TO THE POPULACE BY MUNICIPAL SUPPLY WELLS. SOME PRIVATE WELLS EXIST BUT THESE ARE USED PRIMARILY FOR IRRIGATION AND NOT AS A SOURCE OF DRINKING WATER. IN LAKEHURST BOROUGH THERE IS A WELL FIELD CONSISTING OF SEVEN 50-FOOT DEEP WELLS, LOCATED APPROXIMATELY TWO-THIRDS OF A MILE SOUTH OF THE EASTERN PORTION OF NAEC. THREE OF THE SEVEN WELLS (FOUR OF THE WELLS ARE RARELY OPERATED) ARE PUMPED AT AN AVERAGE RATE OF 70 TO 90 GALLONS PER MINUTE AND SUPPLY DRINKING WATER FOR A POPULATION OF APPROXIMATELY 3,000. JACKSON TOWNSHIP OPERATES ONE SUPPLY WELL IN THE LEGLER AREA, APPROXIMATELY ONE-QUARTER MILE NORTH OF THE NAEC, WHICH SUPPLIES WATER TO VERY SMALL POPULATION (PROBABLY LESS THAN 1,000) IN THE IMMEDIATE VICINITY OF THE NAEC. SITE 28 (FIGURE 1A AND 2) IS APPROXIMATELY 2,800 FEET FROM THE SOUTHERN BOUNDARY OF NAEC. THREE NON-POTABLE WATER SUPPLY WELLS (SW-13, SW-14, AND SW-15) ARE PRESENT AT THE SITE. THERE IS A SHALLOW GROUND WATER TABLE AT SITE 28 AT A DEPTH OF APPROXIMATELY 7 TO 9 FEET. GROUNDWATER AT THE SITE FLOWS IN AN EASTERLY DIRECTION TOWARD PAINT BRANCH. THE PAINT BRANCH, WHICH FLOWS IN A SOUTHEASTERLY DIRECTION, IS LOCATED APPROXIMATELY 300 FEET NORTHEAST OF THE SITE. MOST OF THE GROUNDWATER FLOWS UNDER PAINT BRANCH IN AN EASTERLY DIRECTION. ACCORDING TO AVAILABLE INFORMATION (WETLAND AND FLOODPLAIN DELINEATIONS BY THE US FISH & WILDLIFE SERVICE AND THE US ARMY CORPS OF ENGINEERS RESPECTIVELY) SITE 28 IS LOCATED IN AN UPLAND AREA. THERE ARE NO WETLAND AREAS IMMEDIATELY DOWN GRADIENT OF THE SITE. #SH SITE HISTORY THE HISTORY OF THE SITE DATES BACK TO 1916, WHEN THE EDDYSTONE CHEMICAL COMPANY LEASED FROM THE MANCHESTER LAND DEVELOPMENT COMPANY PROPERTY TO DEVELOP AN EXPERIMENTAL FIRING RANGE FOR THE TESTING OF CHEMICAL ARTILLERY SHELLS. TESTING WAS ACCOMPLISHED IN COOPERATION AND AGREEMENT WITH THE RUSSIAN IMPERIAL GOVERNMENT UNTIL ITS FALL IN 1919. AT THAT TIME, THE US ARMY ASSUMED CONTROL OF CHEMICAL WARFARE TESTING BY THE EDDYSTONE CHEMICAL COMPANY AND NAMED THE AREA CAMP KENDRICK. BY THE EARLY FALL OF 1919, CONSTRUCTION OF HANGAR NO. 1 FOR THE NAVY HAD COMMENCED. CAMP KENDRICK WAS TURNED OVER TO THE NAVY AND FORMALLY COMMISSIONED NAVAL AIR STATION (NAS), LAKEHURST, NEW JERSEY ON JUNE 28, 1921. NAEC WAS MOVED FROM THE NAVAL BASE, PHILADELPHIA TO LAKEHURST IN DECEMBER 1974. AT THAT TIME, NAEC BECAME THE HOST ACTIVITY, THUS, THE NEW NAME NAEC LAKEHURST. CURRENTLY, NAEC'S MISSION IS TO CONDUCT PROGRAMS OF RESEARCH, ENGINEERING, DEVELOPMENT TESTING AND EVALUATION, SYSTEMS INTEGRATION, LIMITED PRODUCTION, PROCUREMENT AND FLEET ENGINEERING SUPPORT IN THE FOLLOWING AREAS: AIRCRAFT LAUNCHING, RECOVERY, AND LANDING AID SYSTEMS, GROUND SUPPORT EQUIPMENT FOR AIRCRAFT AND FOR AIRBORNE WEAPONS SYSTEMS TO PROVIDE, OPERATE AND MAINTAIN TEST SITES, FACILITIES, AND SUPPORT SERVICES FOR TESTS OF THE ABOVE SYSTEMS AND EQUIPMENT AND CONDUCT RESEARCH AND DEVELOPMENT OF EQUIPMENT AND INSTRUMENTATION USED IN TESTS. NAEC SUPPORTS DEPARTMENT OF DEFENSE (DOD) STANDARDIZATION AND SPECIFICATION PROGRAMS, PROVIDES SERVICES AND MATERIAL, OPERATES AND MAINTAINS AVIATION AND OTHER FACILITIES IN SUPPORT OF ASSIGNED PROGRAMS. NAEC AND ITS TENANT ACTIVITIES NOW OCCUPY MORE THAN 300 BUILDINGS, BUILT BETWEEN 1919 AND 1979, TOTALING OVER 2,845,000 SQUARE FEET. THE COMMAND ALSO OPERATES AND MAINTAINS: TWO 5,000 FOOT LONG RUNWAYS, A 12,000 FOOT LONG CATAPULT AND ARREST RUNWAY, ONE MILE LONG JET CAR TEST TRACK, FOUR ONE AND ONE-QUARTER MILE LONG JET CAR TEST TRACKS, A PARACHUTE JUMP CIRCLE, A 79 ACRE GOLF COURSE, AND A 3,500 ACRE CONSERVATION AREA. THE VARIOUS OPERATIONS AND ACTIVITIES AT NAEC REQUIRED THE USE, HANDLING, STORAGE AND OCCASIONALLY THE ON-SITE DISPOSAL OF HAZARDOUS SUBSTANCES. DURING THE OPERATIONAL PERIOD OF THE FACILITY, THERE HAVE BEEN DOCUMENTED, REPORTED OR SUSPECTED RELEASES OF THESE SUBSTANCES INTO THE ENVIRONMENT. INITIAL INVESTIGATIONS: AS PART OF THE DOD INSTALLATION RESTORATION PROGRAM, THE NAVY DEVELOPED THE NAVY ASSESSMENT AND CONTROL OF INSTALLATION POLLUTANTS (NACIP) PROGRAM TO "IDENTIFY, ASSESS AND CONTROL ENVIRONMENTAL CONTAMINATION FROM PAST METHODS OF STORAGE, HANDLING, AND DISPOSAL OF HAZARDOUS SUBSTANCES AT NAVAL SHORE FACILITIES". AS PART OF THE NACIP PROGRAM, AN INITIAL ASSESSMENT STUDY (IAS) WAS COMPLETED IN 1983 BY THE NAVAL ENERGY AND ENVIRONMENTAL SUPPORT ACTIVITY (NEESA) AT NAEC. THE PURPOSE OF THE IAS WAS TO "IDENTIFY AND ASSESS SITES ------- POSING A POTENTIAL THREAT TO HUMAN HEALTH OR THE ENVIRONMENT DUE TO CONTAMINATION FROM PAST HAZARDOUS MATERIALS OPERATIONS". BASED ON INFORMATION FROM HISTORICAL RECORDS, AERIAL PHOTOGRAPHS, FIELD INSPECTIONS, AND PERSONNEL INTERVIEWS, THE IAS IDENTIFIED A TOTAL OF 44 POTENTIALLY CONTAMINATED SITES, WHICH WERE EVALUATED WITH REGARD TO CONTAMINATION CHARACTERISTICS, MIGRATION PATHWAYS, AND POLLUTANT RECEPTORS. THE IAS CONCLUDED THAT "WHILE NONE OF THE SITES POSE AN IMMEDIATE THREAT TO HUMAN HEALTH OR THE ENVIRONMENT, 16 WARRANT FURTHER INVESTIGATION UNDER THE NACIP PROGRAM, TO ASSESS POTENTIAL IMPACTS". A REMEDIAL INVESTIGATION (RI) (CONFIRMATION STUDY) WAS RECOMMENDED "TO CONFIRM OR DENY THE EXISTENCE OF THE SUSPECTED CONTAMINATION AND TO QUANTIFY THE EXTENT OF ANY PROBLEMS WHICH MAY EXIST". FOLLOWING FURTHER REVIEW OF AVAILABLE DATA BY NAVY PERSONNEL, IT WAS DECIDED THAT 42 OF THE 44 SITES SHOULD BE INCLUDED IN THE REMEDIAL INVESTIGATION. TWO POTENTIALLY CONTAMINATED SITES - AN ORDNANCE SITE (SITE 41) AND AN ADVANCED UNDERGROUND STORAGE FACILITY (SITE 43), WERE DELETED FROM THE REMEDIAL INVESTIGATION BECAUSE THEY HAD ALREADY BEEN REMEDIATED. NAEC WAS DESIGNATED IN 1987 AS A NATIONAL PRIORITIES LIST (NPL) SITE UNDER CERCLA. ENVIRONMENTAL INVESTIGATIONS/FEASIBILITY STUDY: NAEC'S REMEDIAL INVESTIGATION (RI) WAS CONDUCTED IN TWO PHASES. IMPLEMENTATION OF THE VERIFICATION PHASE (PHASE I OF THE RI) WAS INITIATED IN OCTOBER 1984. PHASE II OF THE RI WAS INITIATED IN THE SUMMER OF 1988 TO (A) CONFIRM THE RESULTS OF THE PHASE I STUDY (FALL 1984), SPECIFICALLY THE PRESENCE OR ABSENCE OF CONTAMINATION; (B) DETERMINE WHERE CONTAMINATION IS PRESENT, CHARACTERIZE THE EXTENT OF CONTAMINATION, ASSESS THE POTENTIAL FOR CONTAMINANT MIGRATION AND DEFINE THE SOURCES OF CONTAMINATION; AND (C) SUPPORT A FEASIBILITY STUDY AND FINAL ACTIONS AT SITES. SEE TABLE 1 FOR A SUMMARY OF THE ANALYTICAL DATA FOR AREA E - SITE 28. THE FOLLOWING INVESTIGATIONS AND REMOVAL ACTIONS WERE CONDUCTED AT AREA E - SITE 28 FROM 1981 TO THE PRESENT: PHASE I AND PHASE II INVESTIGATIONS FOR AREA E - SITE 28: IN THE EARLY 1980S, TWO MONITORING WELLS (AN AND BU) WERE INSTALLED BY NAEC AND MONITORED ON A REGULAR BASIS FOR THE PRESENCE OF FREE-FLOATING PRODUCT. A TRACE OF PRODUCT WAS DETECTED IN WELL AN ON JULY 20, 1984. NO PRODUCT WAS DETECTED IN WELL BU. DURING PHASE I REMEDIAL INVESTIGATION (FALL 84), NO CONTAMINATION WAS DETECTED IN THE GROUNDWATER SAMPLES COLLECTED FROM WELL BU AND WELL DT, INSTALLED DOWNGRADIENT FROM THE SITE. LOW LEVELS OF TOLUENE WERE DETECTED IN A GROUNDWATER SAMPLE COLLECTED FROM SUPPLY WELL SW-15. DURING THE PHASE II INVESTIGATION (FALL-WINTER 1988), TWO ROUNDS OF SAMPLES WERE COLLECTED FROM MONITORING WELLS AN, BU AND DT, AND SUPPLY WELL SW-15. ELEVATED LEVELS OF ALKYLBENZENES (BENZENE, TOLUENE, ETHYLBENZENE AND XYLENES), TYPICAL COMPONENTS OF GASOLINE, WERE DETECTED IN WELL BU. IN ADDITION, LOW LEVELS OF NAPHTHALENE AND 2-METHYLNAPHTHALENE WERE DETECTED IN THE SAME WELL. TOTAL PETROLEUM HYDROCARBONS (PHC) WERE DETECTED IN THE FIRST ROUND SAMPLE FROM WELL BU AT A CONCENTRATION OF 3.54 MG/L. ELEVATED LEVELS OF VARIOUS TENTATIVELY IDENTIFIED COMPOUNDS (TICS), PRIMARILY BENZENE SUBSTITUTES, WERE ALSO DETECTED IN WELL BU. FURTHERMORE, FLOATING PRODUCT, PROBABLY GASOLINE, WAS DETECTED IN THIS WELL. IT WAS SUSPECTED THAT A POSSIBLE SOURCE OF THE CONTAMINATION WAS OVERFLOW FROM AND/OR SPILLS DURING THE FILLING OF THE NEARBY 300-GALLON GASOLINE TANK. THE FREE PRODUCT LEVELS IN WELL BU WAS MONITORED IN JANUARY 1990. READINGS INDICATED "TRACE OF PRODUCT" TO 0.34 FEET. A SOIL GAS GROUNDWATER SURVEY (FIGURE 3) WAS CONDUCTED ON AUGUST 6-8, 1990 IN THE VICINITY OF WELL BU TO ASSESS THE HORIZONTAL EXTENT OF VOC CONTAMINATION, AND IDENTIFY THE SOURCE OF THE FLOATING PRODUCT THAT WAS OBSERVED IN WELL BU. THE RESULTS OF THE SOIL GAS/GROUNDWATER SURVEY (SUMMARIZED IN TABLES 2 AND 3 AND DEPICTED IN FIGURE 3 THROUGH 12), SHOWED THAT THE SOIL AND GROUNDWATER CONTAMINATION BY GASOLINE COMPONENTS APPEARED TO EXTEND AT LEAST 150 FEET DOWNGRADIENT (IN AN EASTERLY DIRECTION) FROM WELL BU. ON AUGUST, 1990, NAEC CONDUCTED A PRELIMINARY INVESTIGATION TO VERIFY THE SOURCE OF THE GASOLINE THAT WAS ------- DETECTED IN WELL BU. A SMALL AREA OF SOIL WAS EXCAVATED TO A DEPTH OF ABOUT 2 FEET ALONG THE NORTHWESTERN SIDE OF BUILDING 308 TO EXPOSE A COPPER GASOLINE PIPE RUNNING FROM THE ABOVE GROUND GASOLINE TANK INTO THE BUILDING. A GASOLINE LEAK WAS OBSERVED AT ONE OF THE PIPE COUPLINGS WHICH APPARENTLY WAS THE SOURCE OF FLOATING PRODUCT AND DISSOLVED CONTAMINANTS DETECTED IN WELL BU. THE LEAK WAS REPAIRED AND APPROXIMATELY FOUR DRUMS OF VISUALLY CONTAMINATED SOIL WERE REMOVED. DURING THE PERIOD AUGUST 9 THROUGH AUGUST 13, AND FOLLOWING THE COMPLETION OF THE SOIL GAS/GROUNDWATER INVESTIGATION, A SERIES OF EIGHT TEST PITS WERE DUG IN THE AREA NORTHEAST OF BUILDING 308 TO VERIFY THE PRESENCE OF SOIL GAS CONTAMINANTS. BASED ON OBSERVATIONS MADE IN THESE PITS, SOIL WAS EXCAVATED FROM AN AREA MEASURING APPROXIMATELY 60 FEET LONG, 20 TO 40 FEET WIDE, AND 7 TO 8 FEET DEEP. DURING THE EXCAVATION, ABOUT 65 CUBIC YARDS OF VISUALLY CONTAMINATED SOIL WERE SEGREGATED AND TRANSFERRED TO A NEARBY ON-SITE HAZARDOUS WASTE STORAGE AREA FOR ULTIMATE DISPOSAL AT AN APPROVED FACILITY. THE VISUALLY CLEAN SOIL WAS STOCKPILED AT THE PERIMETER OF THE EXCAVATION. IN APRIL 1991, THE FOCUSED FEASIBILITY STUDY (FFS) FOR AREA E - SITE 28 WAS DISTRIBUTED TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (USEPA), REGION II AND THE NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENERGY (NJDEPE), BUREAU OF FEDERAL CASE MANAGEMENT FOR THEIR REVIEW. THE PROPOSED INTERIM REMEDIAL ACTION PLAN (PIRAP) WAS FINALIZED BY NAEC AND APPROVED (FINAL CONCURRENCE SUBJECT TO PUBLIC MEETING AND COMMENTS) BY THE EPA ON JUNE 14 AND THE NJDEPE ON 21 JUNE 1991. THE FINALIZATION OF THE PIRAP AND PUBLIC NOTIFICATION INITIATED A 30 DAY PUBLIC COMMENT PERIOD (JUNE 19 TO JULY 19, 1991) . HIGHLIGHTS OF COMMUNITY PARTICIPATION THE AREA E - SITE 28, PROPOSED INTERIM REMEDIAL ACTION PLAN WAS ISSUED TO INTERESTED PARTIES ON JUNE 17, 1991. ON JUNE 17-19, A NEWSPAPER NOTIFICATION INVITING PUBLIC COMMENT ON THE FFS AND PIRAP APPEARED IN THE ASBURY PARK PRESS, THE OCEAN COUNTY OBSERVER, AND THE ADVANCED NEWS. THE COMMENT PERIOD WAS HELD FROM JUNE 19 TO JULY 19, 1991. THE NEWSPAPER NOTIFICATION ALSO IDENTIFIED THE OCEAN COUNTY LIBRARY AS THE LOCATION OF THE INFORMATION REPOSITORY. A PUBLIC HEARING WAS HELD ON JUNE 26, 1991. AT THIS MEETING, REPRESENTATIVES FROM THE NAVY, USEPA AND NJDEPE WERE AVAILABLE TO ANSWER QUESTIONS ABOUT AREA E AND THE INTERIM REMEDIAL ALTERNATIVES UNDER CONSIDERATION. A LIST OF ATTENDEES IS ATTACHED (SEE APPENDIX B). A RESPONSE TO THE COMMENTS RECEIVED DURING THIS PERIOD IS INCLUDED IN THE RESPONSIVENESS SUMMARY, WHICH IS PART OF THIS RECORD OF DECISION. THIS DECISION DOCUMENT PRESENTS THE SELECTED REMEDIAL ACTION FOR SITE 28 OF NAEC IN OCEAN COUNTY, NEW JERSEY, CHOSEN IN ACCORDANCE WITH CERCLA, AS AMENDED BY SARA AND, TO THE EXTENT PRACTICABLE, THE NCP. THE DECISION FOR AREA E IS BASED ON THE ADMINISTRATIVE RECORD. SCOPE AND ROLE OF RESPONSE ACTION THE REMEDIAL OBJECTIVES CONSIST OF MEDIUM-SPECIFIC OR OPERABLE UNIT-SPECIFIC GOALS FOR PROTECTING HUMAN HEALTH AND THE ENVIRONMENT. THE REMEDIAL ACTION OBJECTIVES OF THIS RESPONSE ACTION ARE REMOVING RESIDUAL AMOUNTS OF FREE PRODUCT, RESTRICTING CONTAMINANT PLUME MIGRATION, AND COLLECTING DATA ON AQUIFER AND CONTAMINANT RESPONSE TO THE INTERIM REMEDIAL RESPONSE CHOSEN. THE INTERIM REMEDY IS NOT A FINAL ACTION FOR GROUNDWATER OR SOIL. THIS ACTION WILL BE THE FIRST OPERABLE UNIT (I.E. THE FIRST CLEAN UP PHASE) OF THE REMEDIATION OF AREA E (SITE 28) ON THE NAEC FACILITY. ONE OR MORE FUTURE RODS WILL ADDRESS THE ULTIMATE OBJECTIVE WHICH IS DECONTAMINATION TO ACCEPTABLE LEVELS OF ANY CONTAMINATED MEDIUM, INCLUDING FINAL REMEDIATION OF GROUND WATER. THE INTERIM REMEDY PROPOSED, HOWEVER, SHOULD BE CONSISTENT WITH THOSE OBJECTIVES. SUMMARY OF AREA CHARACTERISTICS SITE 28 INCLUDES A FORMER DISPOSAL AREA TO THE NORTHEAST SIDE OF WEST FIELD HANGAR 7 (BUILDING 307), A FORMER OIL STORAGE SHED (BUILDING 536), AND A FORMER PAINT LOCKER (BUILDING 538). SOLVENTS MAY HAVE ALSO BEEN STORED IN THESE TWO BUILDING (FIGURE 2). THE STORAGE SHED AND PAINT LOCKER WERE DISMANTLED AND REMOVED IN THE MID-1980S. ------- THE DISPOSAL AREA HAS BEEN COVERED WITH SAND AND GRADED. THE ORIGINAL SITE WAS ABOUT 20 BY 20 FEET AND DISCOLORED WITH LUBE OIL AND SOLVENTS TO A DEPTH OF 2 TO 3 INCHES. SIMILAR CONDITIONS EXISTED TO THE NORTH OF HANGAR 7, BY THE EDGE OF THE BLACKTOP. UNKNOWN QUANTITIES OF WASTE OILS, HYDRAULIC FLUIDS, AND SOLVENTS WERE DISCHARGED IN THIS AREA FROM ABOUT 1957 WHEN THE WESTFIELD HANGAR WAS CONSTRUCTED TO ABOUT 1980. THERE ARE CURRENTLY FIVE ABOVE-GROUND STEEL STORAGE TANKS AT THE SITE: (1) A 300-GALLON GASOLINE TANK FOR A STANDBY GENERATOR NEAR BUILDING 308; (2) A 200-GALLON DIESEL TANK FOR A STANDBY GENERATOR NEAR BUILDING 282; (3) ONE 300-GALLON TANK AND ONE 50-GALLON DIESEL TANK FOR STANDBY GENERATORS NEAR BUILDING 307; AND (4) A 20,000-GALLON NO. 2 FUEL OIL TANK LOCATED NEAR BUILDING 308. ALL TANKS ARE WITHIN SECONDARY CONTAINMENTS. #SSR SUMMARY OF SITE RISKS A BASELINE RISK ASSESSMENT WAS NOT CONDUCTED FOR AREA E - SITE 28 FOR THE INTERIM REMEDIAL ACTION. HOWEVER, BECAUSE FEDERAL MAXIMUM CONTAMINANT LEVELS (MCLS), WHICH ARE GENERALLY RISKED BASED NUMBERS, HAVE BEEN EXCEEDED FOR SEVERAL CONTAMINANTS, REMEDIAL ACTION IS NECESSARY. A COMPREHENSIVE FEASIBILITY STUDY AND RISK ASSESSMENT WILL BE PREPARED PRIOR TO THE INITIALIZATION OF THE FINAL REMEDIAL ACTION AT THE SITE. THE RISK ASSESSMENT WILL CONSIST OF HAZARD IDENTIFICATION, A DOSE-RESPONSE EVALUATION, EXPOSURE ASSESSMENT AND RISK CHARACTERIZATION. THIS INTERIM ACTION IS BEING IMPLEMENTED TO STOP THE MIGRATION OF THE CONTAMINANT PLUME AND RESIDUAL FLOATING PRODUCT (ENVIRONMENTAL RISK) FROM AREA E TOWARDS THE PAINT BRANCH, A TRIBUTARY OF THE MANAPAQUA BROOK WHICH FEEDS PINE LAKE, A MAJOR RECREATIONAL BODY OF WATER IN THE COUNTY. THIS ACTION WILL LIMIT EXPOSURE RISKS TO NATURAL FAUNA ALONG THE PAINT BRANCH, THE MANAPAQUA BROOK AND THE POPULATION USING PINE LAKE FOR RECREATIONAL ACTIVITIES. TABLE 1 PROVIDES THE HISTORICAL SUMMARY OF ANALYTICAL DATA FOR SITE 28. THE PREDOMINANT VOLATILE ORGANIC COMPOUNDS (VOCS) FOUND AT SITE 28 CONSIST OF THE FOLLOWING COMPONENTS OF FUEL: BENZENE ETHYLBENZENE TOLUENE XYLENES (TOTAL) THE PRIMARY SEMI-VOLATILE ORGANIC COMPOUNDS INCLUDE: 2-METHYLNAPHTHALENE NAPHTHALENE TOTAL PETROLEUM HYDROCARBONS AND TENTATIVELY IDENTIFIED COMPOUNDS (TICS), PRIMARILY BENZENE SUBSTITUTES WERE ALSO DETECTED IN THE GROUNDWATER AT SITE 28. FIGURES 3 THROUGH 12 SHOWS THE KNOWN EXTENT OF THE CONTAMINANT PLUME AT SITE 28. DESCRIPTION OF ALTERNATIVES ALTERNATIVE 1: NO ACTION ESTIMATED CONSTRUCTION COST: $40,000 (FOR MONITORING WELL NETWORK) ESTIMATED NET O&M COST: $50,000/YR ESTIMATED IMPLEMENTATION TIME FRAME: N/A THIS ALTERNATIVE INVOLVES NO ADDITIONAL INTERIM ACTIONS AT SITE 28 OTHER THEN GROUNDWATER MONITORING OF THE AQUIFER. NO CONTAMINANTS WOULD BE TREATED OR CONTAINED AND THE EXISTING HEALTH AND ENVIRONMENTAL RISKS WOULD REMAIN. UNDER THIS ALTERNATIVE, NO FURTHER ACTION TO CONTROL GROUNDWATER CONTAMINATION WOULD BE TAKEN. LONG-TERM MONITORING OF THE SITE CAN BE IMPLEMENTED BY USING EXISTING MONITORING WELLS, WHICH MUST BE SUPPLEMENTED BY ADDITIONAL MONITORING WELLS TO CREATE AN EFFECTIVE MONITORING WELL NETWORK. ------- ALTERNATIVE 2: GROUND WATER PUMPING, REMOVAL OF FREE PRODUCT, TREATMENT, RECHARGE AND IN SITU SOIL FLUSHING ESTIMATED CONSTRUCTION COST: ESTIMATED NET O&M COST: ESTIMATED IMPLEMENTATION TIME FRAME: TIME FRAME FOR OPERATION OF SYSTEM: $1,000,000 $ 100,000/YR 9 MONTHS 3 YEARS - AFTER WHICH A FINAL ACTION FOR GROUNDWATER REMEDIATION WILL BE INITIATED THIS ALTERNATIVE INVOLVES PUMPING GROUNDWATER FROM TWO RECOVERY WELLS (50 GPM EACH), TREATMENT AND DISCHARGE TO THE AQUIFER. DURING THE TEMPERATE MONTHS, THE TREATED EFFLUENT, WHICH WILL MEET NJDEPE GROUNDWATER DISCHARGE EFFLUENT LIMITATIONS, WILL BE DISCHARGED TO THE AQUIFER VIA A SPRAY IRRIGATION SYSTEM. DURING THE WINTER MONTHS DISCHARGE OF THE TREATED EFFLUENT WILL OCCUR VIA AN INFILTRATION SYSTEM. THIS IS NECESSARY SINCE THE DISCHARGE OPTION WILL BE SEASONALLY DEPENDENT UPON CLIMATIC CONDITIONS. IT IS A DESIGN CRITERIA OF THE RECOVERY SYSTEM THAT THE INFILTRATED/IRRIGATED TREATED WATER BE CONTAINED AS PART OF A CLOSED LOOP GROUNDWATER SYSTEM. TO TREAT THE VOLATILE ORGANIC AND OTHER CONTAMINANTS PRESENT IN THE EXTRACTED GROUNDWATER, A TREATMENT SYSTEM WILL BE CONSTRUCTED AT SITE 28. THE CONTAMINATED GROUNDWATER PUMPED FROM THE RECOVERY WELLS WILL ENTER A TANK WHICH WILL SERVE AS A FLOW EQUALIZER. THE SYSTEM WILL CONSIST OF: (1) A PRETREATMENT UNIT FOR METALS, FREE PRODUCT AND SOLIDS REMOVAL; (2) AIR STRIPPING COLUMN(S) (99 PERCENT VOC REMOVAL); (3) GRANULAR ACTIVATED CARBON AIR FILTER FOR AIR STRIPPER EMISSIONS; AND (4) A GRANULAR ACTIVATED CARBON POLISHING FILTER FOR RESIDUAL VOC AND SEMI-VOLATILE REMOVAL (99.9 PERCENT REMOVAL OF VOCS) FROM TREATED GROUNDWATER. THE EXTRACTED FREE PRODUCT WILL BE SENT TO A PERMITTED DISPOSAL FACILITY. A SCHEMATIC REPRESENTATION OF ALTERNATIVE 2 IS SHOWN IN FIGURE 2A. THE EFFLUENT LIMITATIONS FOR THE INTERIM REMEDIAL ACTION WILL BE ESTABLISHED IN ACCORDANCE WITH THE NEW JERSEY POLLUTANT DISCHARGE ELIMINATION SYSTEM (NJPDES) REGULATIONS (NJAC 7:14A-1 ET SEQ.) AND THE NEW JERSEY GROUNDWATER QUALITY STANDARDS (NJAC 7:9-6 ET SEQ.). THE EFFLUENT LIMITATIONS (MAXIMUM CONTAMINANT LEVELS (MCLS) AND SAFE DRINKING WATER ACT CRITERIA) WILL BE ISSUED TO NAEC IN THE FORM OF NJPDES DISCHARGE TO GROUNDWATER (DGW) PERMIT EQUIVALENCE. ALTERNATIVE 3: GROUND WATER PUMPING, TREATMENT AND DISCHARGE TO SURFACE WATER ESTIMATED CONSTRUCTION COST: ESTIMATED NET O&M COST: ESTIMATED IMPLEMENTATION TIME FRAME: TIME FRAME FOR SYSTEM OPERATION: $ 950,000 $ 100,000/YR 9 MONTHS 3 YEARS - AFTER WHICH A FINAL ACTION FOR GROUNDWATER WILL BE INITIATED THIS ALTERNATIVE WOULD BE SIMILAR TO ALTERNATIVE 2, EXCEPT TREATED GROUNDWATER WOULD BE DISCHARGED VIA PIPING TO THE PAINT BRANCH INSTEAD OF BEING RECHARGED BACK INTO THE AQUIFER. FREE PRODUCT WOULD BE SENT TO AN OFFSITE PERMITTED DISPOSAL FACILITY. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES THE THREE ALTERNATIVES IDENTIFIED ABOVE WERE EVALUATED USING CRITERIA DERIVED FROM SECTION 300.430 (E9) OF THE NCP AND SECTION 121 A AMENDED BY SARA OF 1986. THE CRITERIA ARE AS FOLLOWS: OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT DRAWS ON THE ASSESSMENTS CONDUCTED UNDER OTHER EVALUATION CRITERIA AND CONSIDERS HOW THE ALTERNATIVE ADDRESSES SITE RISKS THROUGH TREATMENT, ENGINEERING, OR INSTITUTIONAL CONTROLS. COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) EVALUATES THE ABILITY OF AN ALTERNATIVE TO MEET ARARS ESTABLISHED THROUGH FEDERAL AND STATE STATUTES AND/OR PROVIDES THE BASIS FOR INVOKING A WAIVER. ------- LONG-TERM EFFECTIVENESS AND PERMANENCE EVALUATES THE ABILITY OF AN ALTERNATIVE TO PROVIDE LONG-TERM PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT AND THE MAGNITUDE OF RESIDUAL RISK POSED BY UNTREATED WASTES OR TREATMENT RESIDUALS. REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT EVALUATES AN ALTERNATIVE'S ABILITY TO REDUCE RISKS THROUGH TREATMENT TECHNOLOGY. SHORT-TERM EFFECTIVENESS ADDRESSES THE CLEANUP TIME FRAME AND ANY ADVERSE IMPACTS POSED BY THE ALTERNATIVE DURING THE CONSTRUCTION AND IMPLEMENTATION PHASE, UNTIL CLEANUP GOALS ARE ACHIEVED. IMPLEMENT ABILITY IS AN EVALUATION OF THE TECHNICAL FEASIBILITY, ADMINISTRATIVE FEASIBILITY, AND AVAILABILITY OF SERVICES AND MATERIAL REQUIRED TO IMPLEMENT THE ALTERNATIVES. COST INCLUDES AN EVALUATION OF CAPITAL COSTS, ANNUAL OPERATION AND MAINTENANCE COSTS, AND NET PRESENT WORTH COSTS. STATE ACCEPTANCE INDICATES THE STATE'S RESPONSE TO THE ALTERNATIVES IN TERMS OF TECHNICAL AND ADMINISTRATIVE ISSUES AND CONCERNS. COMMUNITY ACCEPTANCE EVALUATES THE ISSUES AND CONCERNS THE PUBLIC MAY HAVE REGARDING THE ALTERNATIVES. A COMPARATIVE DISCUSSION OF THE THREE ALTERNATIVES ON THE BASIS OF THE EVALUATION CRITERIA PRESENTED ABOVE FOLLOWS. ANALYSIS OF ALTERNATIVES OVERALL PROTECTION - ALTERNATIVE 2, PROVIDES THE GREATEST OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT THROUGH TREATMENT OF GROUNDWATER AND TO SOME DEGREE SOIL. ALTERNATIVE 3, IS SIMILAR TO ALTERNATIVE 2, EXCEPT TREATED GROUND WATER IS DISCHARGED TO SURFACE WATER AS OPPOSED TO THE AQUIFER. BY IMPLEMENTING ALTERNATIVE 3, WATER IS EXTRACTED FROM THE AQUIFER AND DISPOSED OF TO SURFACE WATERS, THE CURRENT OVERPUMPAGE OF THE COASTAL AQUIFER IS EXACERBATED. ALTERNATIVE 2 IS A CLOSED LOOP SYSTEM IN WHICH THE AQUIFER IS RECHARGED BY THE TREATED GROUNDWATER. ALTERNATIVE 1, WHICH OFFERS NO SOIL OR GROUND WATER TREATMENT IS THE LEAST PROTECTIVE ALTERNATIVE. LONG-TERM EFFECTIVENESS AND PERMANENCE - ALTERNATIVES 2 AND 3 ARE INTERIM ACTIONS AND INTENDED TO BE SHORT-TERM RESPONSES. THEREFORE, THE LONG TERM EFFECTIVENESS CANNOT BE ADDRESSED. HOWEVER, IF THE INTERIM REMEDIAL ALTERNATIVE CHOSEN PROVES TO BE EFFECTIVE, IT WILL BE INCORPORATED AND/OR MODIFIED TO BECOME THE FINAL REMEDIAL ACTION. ALTERNATIVE 1 PROVIDES NO TREATMENT AND IS NOT CONSIDERED TO BE EFFECTIVE. REDUCTION OF TOXICITY, MOBILITY OR VOLUME - IN ALTERNATIVES 2 AND 3, THE VAPOR AND AQUEOUS PHASE CARBON SYSTEMS WILL CAPTURE BY ADSORPTION VOLATILE AND SEMI-VOLATILE COMPOUNDS, HENCE THE MOBILITY AND TOXICITY OF GROUNDWATER CONTAMINANTS WILL BE REDUCED BY THE REMOVAL OF THESE COMPOUNDS. DESTRUCTION OF CONTAMINANTS WILL OCCUR DURING THE REGENERATION OF CARBON AT AN OFF-SITE FACILITY. ALTERNATIVE 1 OFFERS NO TREATMENT OF THE CONTAMINATED MEDIA. SHORT-TERM EFFECTIVENESS - INTERIM REMEDIAL ACTION ALTERNATIVES 2 AND 3 IN THE SHORT-TERM WILL HALT THE SPREAD OF CONTAMINATED GROUND WATER AND RESIDUAL AMOUNTS OF FLOATING PRODUCT. THEY WILL ALSO STOP THE MIGRATION OF THE CONTAMINANT PLUME AND RESIDUAL AMOUNTS OF FLOATING PRODUCT FROM ENTERING THE PAINT BRANCH. ALTERNATIVE 2 HAS THE ADDED BENEFIT OF FLUSHING THE SOIL OF SOME CONTAMINANTS (IN AREAS WHERE TREATED WATER IS BEING RECHARGED) AND INCREASING THE HYDRAULIC GRADIENT, THUS SPEEDING UP THE REMEDIATION PROCESS. IN ALTERNATIVE 3, TREATED GROUND WATER IS RECHARGED INTO THE PAINT BRANCH, NO SOIL FLUSHING ACTION TAKES PLACE. ALTERNATIVE 1 PROVIDES NO TREATMENT OF SOIL OR GROUNDWATER AND IS NOT CONSIDERED TO BE EFFECTIVE IN THE SHORT-TERM BECAUSE RESIDUAL RISKS ARE NOT REDUCED. IMPLEMENT ABILITY - ALTERNATIVE 1 OFFERS THE GREATEST IMPLEMENT ABILITY FOLLOWED BY ALTERNATIVE 2, AND 3 WHICH INVOLVES CONVENTIONAL TECHNOLOGIES WITH PROVEN RELIABILITY. ------- COST - ALTERNATIVE 1, THE NO ACTION ALTERNATIVE, HAS THE LOWEST ASSOCIATED COST. ALTERNATIVES 2 AND 3 HAVE A CAPITAL COST OF ABOUT $1,000,000 AND O & M COSTS OF $100,000/YEAR. ALTERNATIVE 3 HAS A SLIGHTLY LOWER CAPITAL COST OF APPROXIMATELY $950,000 SINCE THERE IS NO COST ASSOCIATED WITH THE INFILTRATION SYSTEM. INSTEAD, THERE IS CONSTRUCTION OF A PIPING AND PUMP SYSTEM FROM THE TREATMENT BUILDING TO THE PAINT BRANCH. O & M COST IS THE SAME. COMPLIANCE WITH ARARS - ACTION SPECIFIC ARARS ARE NOT APPLICABLE TO ALTERNATIVE 1, AS THE "NO ACTION" ALTERNATIVE. ALTERNATIVES 2 AND 3 WILL COMPLY WITH ACTION-SPECIFIC ARARS SUCH AS OSHA, RCRA, ENDANGERED SPECIES, CLEAN AIR AND WATER ACTS. STATE AND FEDERAL ACTION AND CONTAMINANT SPECIFIC ARARS WHICH INCLUDE SURFACE WATER, GROUNDWATER AND AIR DISCHARGE LIMITATIONS, AS WELL AS HAZARDOUS WASTE HANDLING REQUIREMENTS, WILL BE COMPLIED WITH DURING THE INTERIM REMEDIAL ACTION. BECAUSE OF THE LIMITED FOCUS OF THIS PROPOSED INTERIM ACTION, CONTAMINANT-SPECIFIC CLEAN-UP LEVELS FOR GROUNDWATER HAVE NOT BEEN IDENTIFIED FOR ALTERNATIVES 2 AND 3. THESE LEVELS WILL BE IDENTIFIED AND MET WHEN A FINAL REMEDIAL ACTION IS CHOSEN FOR SITE 28. TREATMENT RESIDUALS WILL BE TESTED TO DETERMINE WHETHER RCRA LAND DISPOSAL RESTRICTIONS APPLY FOR ALTERNATIVES 2 AND 3. LOCATION-SPECIFIC ARARS WHICH WILL INCLUDE AQUIFER AND FACILITY GROUNDWATER REMEDIATION ISSUES WILL BE ADDRESSED IN THE FINAL REMEDY. THE NEW JERSEY POLLUTANT DISCHARGE ELIMINATION SYSTEM (NJPDES) DISCHARGE TO GROUNDWATER (DGW) PERMIT EQUIVALENCE WILL BE APPLIED FOR TO IRRIGATE AND INFILTRATE THE TREATED GROUNDWATER. THE TREATED WATER WILL MEET THE NJDEPE GROUNDWATER DISCHARGE EFFLUENT LIMITATIONS AS SET FORTH IN THE PERMIT EQUIVALENCE. STATE ACCEPTANCE - THE PREFERRED ALTERNATIVE (ALTERNATIVE 2) IS ACCEPTABLE TO THE NJDEPE. COMMUNITY ACCEPTANCE - COMMUNITY ACCEPTANCE OF THE PREFERRED ALTERNATIVE HAS BEEN EVALUATED ON THE BASIS OF PUBLIC COMMENTS AND IS DESCRIBED IN THE RESPONSIVENESS SUMMARY OF THIS RECORD OF DECISION. #SR SEIiECTED INTERIM REMEDY THE FOLLOWING SECTION DESCRIBES IN DETAIL THE INTERIM REMEDIAL ACTION PLAN WHICH THE NAVAL AIR ENGINEERING CENTER, IN CONCURRENCE WITH THE USEPA AND NJDEPE, HAS SELECTED TO IMPLEMENT AT AREA E - SITE 28. THIS SELECTION IS IDENTICAL TO THAT PRESENTED IN THE PROPOSED INTERIM REMEDIAL ACTION PLAN. BECAUSE THIS IS AN INTERIM ACTION, CHANGES COULD BE IMPLEMENTED DURING THE FINAL DESIGN AND CONSTRUCTION PROCESSES. SUCH CHANGES REFLECT MODIFICATIONS RESULTING FROM THE ENGINEERING DESIGN PROCESS AND WILL NOT SUBSTANTIALLY CHANGE THE INTENT OF THE SELECTED ALTERNATIVE DESCRIBED HEREIN. THE SELECTED INTERIM REMEDIAL ACTION IS ALTERNATIVE 2 - GROUNDWATER PUMPING, REMOVAL OF FREE PRODUCT, TREATMENT, RECHARGE AND IN SITU SOIL FLUSHING. THIS ALTERNATIVE WILL ADDRESS GROUNDWATER TREATMENT AND PRODUCT EXTRACTION SIMULTANEOUSLY. THE ALTERNATIVE IS COST EFFECTIVE AND IMPLEMENTS PROVEN TECHNOLOGIES. GROUNDWATER AND RESIDUAL AMOUNTS OF FREE PRODUCT WILL BE EXTRACTED VIA TWO WELLS AT A RATE OF 100 GPM. THE EXTRACTED WATER WILL BE HELD IN A FLOW EQUALIZATION TANK AND THEN PRETREATED TO REMOVE METALS, FREE PRODUCT AND SOLIDS. THE PRETREATMENT SYSTEM WILL CONSIST OF USING A CAUSTIC SOLUTION AND A FLOCCULENT TO PRECIPITATE AND SETTLE SOLIDS AND METALS FROM THE CONTAMINATED GROUNDWATER. THE EXTRACTED FREE PRODUCT WILL BE SENT TO A PERMITTED OFF-SITE DISPOSAL FACILITY. NAEC WILL COMPLY WITH NJ HAZARDOUS WASTE REGULATIONS. THE PRETREATED WATER WILL BE AIR STRIPPED TO REMOVE 99.0 PERCENT OF VOCS. DUE TO THE TRANSFER OF CONTAMINANTS FROM THE AQUEOUS PHASE TO THE AIRSTREAM, EMISSIONS CONTROL UNITS WILL BE REQUIRED ON THE AIR STRIPPERS. THE TREATMENT SYSTEM, INCLUDING THE EMISSION CONTROL UNIT WILL BE DESIGNED TO MEET THE SUBSTANTIVE REQUIREMENTS OF THE NEW JERSEY AIR POLLUTION CONTROL REGULATIONS (NJAC 7:27-16). THE AIR AND LIQUID EFFLUENT STREAMS FROM THE AIR STRIPPER WILL BE TREATED BY GRANULATED ACTIVATED CARBON FILTERS PRIOR TO DISCHARGE. RESIDUAL SLUDGE FROM THE PRETREATMENT PROCESS WILL BE TESTED TO DETERMINE IF THE WASTE IS HAZARDOUS AND IF RCRA LAND DISPOSAL RESTRICTIONS ARE APPLICABLE. THE WASTE WILL BE HANDLED ACCORDINGLY. SPENT GRANULAR ACTIVATED CARBON WILL BE SENT TO THE VENDOR FOR REGENERATION. ONCE TREATED, THE GROUNDWATER WILL MEET FEDERAL AND STATE DRINKING WATER STANDARDS (NJAC 7:14A-1.1 ET SEQ.) INCLUDING MCLS AND SAFE DRINKING WATER ACT CRITERIA WHICH ARE THE DISCHARGE EFFLUENT CRITERIA FOR THIS LIMITED ACTION. RECHARGE TO THE AQUIFER WILL OCCUR THROUGH AN IRRIGATION AND INFILTRATION SYSTEM. THE ------- TREATED WATER WILL BE SPRAY IRRIGATED OVER AREAS OF SUBSURFACE SOIL CONTAMINATION. THIS ACTION WILL INCREASE BIOLOGICAL ACTIVITY PROMOTING CONTAMINANT DECOMPOSITION. THE GROUNDWATER CLASSIFICATION FOR THE IMMEDIATE NAEC AREA IS CENTRAL PINE BARRENS GW1. THE GROUNDWATER IS SUITABLE FOR POTABLE WATER SUPPLY, AGRICULTURAL WATER SUPPLY, CONTINUAL REPLENISHMENT OF SURFACE WATERS TO MAINTAIN THE EXISTING QUANTITY OF THE SURFACE WATERS IN THE CENTRAL PINE BARRENS, AND OTHER REASONABLE USES QUALITY CRITERIA FOR THESE WATERS MAY BE FOUND IN NJAC 7:9-5.6. THE REMEDIAL ACTION IN THE SHORT-TERM WILL HALT THE SPREAD OF CONTAMINATED GROUNDWATER AND RESIDUAL AMOUNTS OF FLOATING PRODUCT FROM ENTERING ECOLOGICALLY SENSITIVE AREAS. THIS INTERIM REMEDIAL ACTION WILL BE IMPLEMENTED UNTIL THE FINAL REMEDY IS SELECTED, DESIGNED AND IMPLEMENTED. IF THE INTERIM REMEDY PROVES TO BE EFFECTIVE, IT WILL BE INCORPORATED AND/OR MODIFIED TO THE FINAL REMEDIAL ACTION. THE FINAL REMEDY FOR THE SITE WILL ADDRESS THE LOCATION SPECIFIC ARARS FOR PINELANDS AS SET FORTH IN NJAC 7:9-5.6. TO THE EXTENT THAT THESE ARARS ARE RECOGNIZED BY THE USEPA AND NJDEPE. STATUTORY DETERMINATIONS UNDER SECTION 121 OF CERCLA AND SECTION 300.430(F5) OF THE NCP, SELECTED REMEDIES MUST MEET CERTAIN STATUTORY AND REGULATORY REQUIREMENTS. THESE REQUIREMENTS AND A DESCRIPTION OF HOW THE SELECTED REMEDY SATISFIES EACH REQUIREMENT ARE PRESENTED BELOW. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT THE SELECTED ALTERNATIVE WILL PROTECT HUMAN HEALTH AND THE ENVIRONMENT THROUGH TREATMENT OF THE CONTAMINATED GROUNDWATER AND IN SITU SOIL FLUSHING. THE TREATED GROUNDWATER WILL MEET NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENERGY DISCHARGE EFFLUENT LIMITATIONS. RESIDUAL AMOUNTS OF FLOATING FREE PRODUCT WILL BE EXTRACTED AND REMOVED TO A PERMITTED OFF-SITE DISPOSAL FACILITY. THE INTERIM REMEDIAL ACTION WILL STOP THE MIGRATION OF THE CONTAMINANT PLUME AND RESIDUAL AMOUNTS OF FLOATING PRODUCT FROM ENTERING THE PAINT BRANCH A TRIBUTARY OF THE MANAPAQUA BROOK WHICH FEEDS PINE LAKE, A MAJOR RECREATIONAL BODY OF WATER IN THE COUNTY. THIS INTERIM ACTION WILL IN THE SHORT-TERM PREVENT DEGRADATION OF THE AQUIFER AND LIMIT CONTAMINANT EXPOSURE RISKS TO THE POPULATION USING PINE LAKE. COMPLIANCE WITH ARARS THE SELECTED REMEDY WILL COMPLY WITH ACTION SPECIFIC ARARS SUCH AS OSHA, RCRA, ENDANGERED SPECIES, CLEAN AIR AND WATER ACTS. STATE AND FEDERAL ACTION SPECIFIC ARARS PERTAINING TO THE DISCHARGE OF TREATED WATER TO GROUND SURFACES AND GROUNDWATER IS ALSO ADDRESSED AND WILL BE COMPLIED WITH DURING THE INTERIM ACTION. ALSO, TREATED WATER WILL MEET SAFE DRINKING WATER STANDARDS PRIOR TO SPRAY IRRIGATION AND INFILTRATION. A LIST OF ARARS SPECIFIC TO THIS ACTION IS PRESENTED IN TABLE 4. COST EFFECTIVENESS THE SELECTED REMEDY PROVIDES GROUNDWATER TREATMENT AND REMOVAL OF RESIDUAL AMOUNTS OF FLOATING PRODUCT THROUGH TREATMENT METHODS THAT HAVE BEEN PROVEN EFFECTIVE, COST EFFICIENT AND EXPECTED TO ATTAIN ARARS. PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT THE PRINCIPAL THREATS AT AREA E - SITE 28 INCLUDE GROUND WATER AND SOIL CONTAMINATION AND THE PRESENCE OF RESIDUAL AMOUNTS OF FLOATING FREE PRODUCT ASSOCIATED WITH THE PRESENCE OF THE PLUME AT AREA E. THE SELECTED REMEDY SATISFIES THE STATUTORY PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT IN ADDRESSING THE HUMAN HEALTH AND ENVIRONMENTAL THREATS POSED BY THE SITE. GROUNDWATER WILL BE TREATED BY AIR STRIPPING TO REMOVE VOCS AND POLISHED BY GRANULAR ACTIVATED CARBON TO REMOVE SVOCS AND FURTHER REDUCE VOC LEVELS. IN SITU SOIL FLUSHING WILL AERATE AND ENHANCE BIOLOGICAL ACTIVITY AND CONTAMINANT DECOMPOSITION. RESIDUAL AMOUNTS OF FLOATING PRODUCT WILL BE COLLECTED AND DISPOSED AT AN OFF-SITE PERMITTED HAZARDOUS WASTE FACILITY. THE INTERIM REMEDY IS NOT A FINAL ACTION FOR GROUNDWATER OR SOIL. THE ULTIMATE GOAL OF THE FINAL REMEDIATION OF BECOME THE THE ------- THIS AREA SHOULD INCLUDE DECONTAMINATION TO ACCEPTABLE LEVELS OF ANY CONTAMINATED MEDIUM, NOT JUST GROUNDWATER. THE SELECTED INTERIM REMEDY, HOWEVER, SHOULD BE CONSISTENT WITH THOSE OBJECTIVES. DOCUMENTATION OF SIGNIFICANT CHANGES THE PROPOSED INTERIM REMEDIAL ACTION PLAN FOR AREA E - SITE 28 WAS RELEASED FOR PUBLIC COMMENT ON JUNE 17, 1991. THE PIRAP IDENTIFIED ALTERNATIVE 2 AS THE PREFERRED ALTERNATIVE. NAEC RECEIVED ONE WRITTEN COMMENT; ALL VERBAL COMMENTS WERE RESPONDED TO AT THE PUBLIC HEARING ON JUNE 26, 1991. UPON REVIEW OF THE COMMENTS, IT WAS DETERMINED THAT NO SIGNIFICANT CHANGES TO THE INTERIM REMEDY, AS IT WAS ORIGINALLY IDENTIFIED IN THE PIRAP, WERE NECESSARY. ------- #TA TABLE 1 HISTORICAL SUMMARY OF ANALYTICAL DATA - SITE 28 PRE-1985 NO DATA COLLECTED PHASE I REMEDIAL INVESTIGATION GROUNDWATER VOLATILE ORGANIC COMPOUNDS (UG/L) PHASE II REMEDIAL INVESTIGATION GROUNDWATER VOLATILE ORGANIC COMPOUNDS (UG/L) TOLUENE: ND - 10.2 TOLUENE: 590 - 5,100 BENZENE: 100- 330 ETHYLBENZENE: 130 - 1,100 XYLENES: 990 - 12,000 SEMI-VOLATILE ORGANIC COMPOUND (UG/L) NAPHTHALENE: 67 - 120 2-METHYL-NAPHTHALENE: 29 - 1,300 MISCELLANEOUS (MG/L) PETROLEUM-HYDROCARBONES: ND - 3.54 SOIL SOIL NO DATA COLLECTED SEMI-VOLATILE ORGANIC COMPOUND (UG/L) PHENANTHRENE: ND - 90 FLUORANTHENE: 40 - 110 PYRENE: ND - 80 BENZO(A)ANTHRACENE: ND - 0.40 CHRYSENE: ND - 50 METALS (MG/KG) BERYLLIUM: 40 CADMIUM: 10 MISCELLANEOUS (UG/L) PETROLEUM HYDROCARBONS: ND - 22 6.73 SEDIMENT SEDIMENT NO DATA COLLECTED METALS (MG/KG) CADMIUM: 50.9 ------- 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 26 27 28 29 30 31 32 33 34 35 36 37 38 TABIiE 2 CONTAMINANT CONCENTRATIONS IN SOIL GAS SITE 28 (WESTSFIELD HANGAR) CONCENTRATION (UG/L) SAMPLE TOTAL DEPTH PETROLEUM (FEET) BENZENE TOLUENE ETHYLBENZENE XYLENES HYDROCARBONS 5 LT 0.02 500 LT 0.3 4 6, 100 6 LT 0.06 LT 0.07 LT 0.08 LT 0.09 LT 0.3 6.5 LT 0.02 LT0.03 LT 0.03 LT 0.04 LT 0.01 6 LT 0.2 14 LT 0.3 LT 0.4 240 6.5 LT0.02 LT0.03 LT 0.03 LT 0.04 LT0.1 6 LT 0.02 LT 0.03 LT 0.03 LT 0.04 LT 0.1 6 LT 0.01 LT 0.01 LT 0.02 LT 0.02 LT 0.06 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.02 0.1 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.02 LT 0. 6 6.5 LT 0.02 LT 0.03 LT 0.03 LT 0.04 LT 0.1 6 LT 0.06 0.6 LT 0.08 LT 0.09 12 6 LT 0.01 LT 0.01 LT 0.02 LT 0.02 LT 0.06 6.5 16,000 9, 100 LT 3 1,500 140,000 10 LT 0.01 LT 0.01 LT 0.02 LT 0.02 0.09 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 0.08 6 LT 0.02 LT 0.02 LT 0.02 LT 0.02 0.4 6.5 LT 0.02 LT 0.02 LT 0.02 LT 0.02 0.2 6 LT 0.02 LT 0.02 LT 0.02 LT 0.02 0.1 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 0.1 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6.5 3,700 1,700 LT 3 80 28,000 6.5 8, 000 2,700 LT 3 230 110,000 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 400 180 LT 3 8 5, 600 6 LT 2 24 LT 3 LT 3 1, 000 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6.5 230 100 LT 3 LT 3 3,300 6 LT 2 56 LT 3 LT 3 3,100 6.5 LT 0.02 LT 0.02 LT 0.03 LT 0.03 LT 0.1 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 310 220 3 5 6, 100 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 6.5 LT 0.01 LT 0.01 LT 0.02 LT 0.01 LT 0.05 ------- TABLE 3 CONTAMINANT CONCENTRATIONS IN GROUNDWATER SITE 28 (WESTFIELD HANGAR) CONCENTRATION (UG/L) SAMPLE TOTAL SAMPLE DEPTH PETROLEUM LOCATION (FEET) BENZENE TOLUENE ETHYLBENZENE XYLENES hydrocarbon: 1 8 570 180 LT 1 57 5, 400 2 7 8, 100 9,500 LT 25 3,300 76,000 10 10 LT 0.1 LT 0.1 LT 0.1 LT 0.2 LT 0.5 10 8 LT 0.1 0.6 LT 0.2 0.8 10 11 7 8, 800 5, 600 LT 25 4, 600 27,000 13 6.5 76,000 37,000 LT 25 17,000 1,000,000 24 7 47,000 35,000 LT 25 17,000 410,000 25 8 14,000 10,000 LT 25 7,300 78,000 26 10 LT 0.1 LT 0.1 LT 0.2 LT 0.2 LT 0.5 26 8 0.3 1 LT 0.2 0.6 2 28 7 37 60 LT 0.2 4 1,500 31 7 30 42 LT 0.3 2 770 32 9 LT 0.3 2 LT 0.3 3 4 35 7.5 350 260 25 61 7,200 36 6.5 0.3 0.6 LT 0.2 0.6 2 40* 6.5 38,000 29,000 LT 25 20,000 540,000 41* 7 0.3 2 LT 0.2 6 8 42* 9 LT 0.2 0.6 LT 0.2 0.7 2 (*) LOCATIONS AT WHICH ONLY GROUNDWATER SAMPLES WERE COLLECTED ------- TABLE 4 LIST OF ARARS ONLY ACTION-SPECIFIC ARARS WHICH INCLUDE SURFACE WATER, GROUND WATER, AND AIR DISCHARGE LIMITATIONS AS WELL AS HAZARDOUS WASTE HANDLING REQUIREMENTS, WETLAND AND FLOODPLAIN REQUIREMENTS WILL BE COMPLIED WITH DURING THE INTERIM REMEDIAL DESIGN. CONTAMINANT SPECIFIC CLEAN UP LEVELS WILL BE ADDRESSED IN THE FINAL REMEDY. THE INTERIM REMEDIATION ACTIVITIES AT AREA E (SITE 28) WILL PRIMARILY ADDRESS GROUND WATER AND RESIDUAL FLOATING PRODUCT. IDENTIFICATION OF FEDERAL ACTION-SPECIFIC ARARS APPLICABLE TO THE INTERIM REMEDIAL ALTERNATIVES CHOSEN ARE: OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA) (29 CFR 1910, 1926, 1904) : ARARS FOR WORKERS AND WORKPLACE THROUGHOUT THE IMPLEMENTATION OF HAZARDOUS ACTIVITIES. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) (40 CFR 264.10-.77): POTENTIAL ARARS FOR ALTERNATIVES UTILIZING TREATMENT, STORAGE OR DISPOSAL ACTIONS (NOTE: PERMITS NOT REQUIRED FOR ON SITE ACTIONS) RCRA (40 CFR 264.90-.101): GROUNDWATER PROTECTION. GROUNDWATER MONITORING/CORRECTIVE ACTION REQUIREMENTS; DICTATE ADHERENCE TO MCLS AND ESTABLISHES POINTS OF COMPLIANCE. RCRA - PART 263 (40 CFR 263.10-.31) AND HAZARDOUS MATERIALS TRANSPORTATION ACT (49 CFR 170, 171): TRANSPORTER REQUIREMENTS. ARARS FOR ALTERNATIVES INVOLVING SHIPMENT OF HAZARDOUS MATERIALS OR WASTES. RCRA - PART 268 (40 CFR 268): LAND DISPOSAL RESTRICTIONS. POTENTIALLY PERTAINS TO SPENT CARBON FILTERS AND SLUDGE FROM PRETREATMENT PROCESS. WASTES WILL BE TESTED TO DETERMINE IF THEY ARE HAZARDOUS WASTE UNDER RCRA. CLEAN AIR ACT (40 CFR 50): ARARS FOR ALTERNATIVE WHICH INVOLVE TREATMENTS WHICH IMPACT AMBIENT AIR. CLEAN WATER ACT (40 CFR 401): NPDES PERMIT REQUIREMENTS. REQUIREMENTS FOR POINT SOURCE DISCHARGE TO SURFACE WATERS. POTENTIAL ARARS WHICH WILL AFFECT THE IMPLEMENTABILITY OF REMEDIAL ACTION INVOLVING EFFLUENT DISCHARGE TO THE MANAPAQUA BROOK. CLEAN WATER ACT (40 CFR 404): PROHIBITS ACTIONS THAT IMPACT A WETLAND UNLESS NO OTHER ALTERNATIVES ARE AVAILABLE. IDENTIFICATION OF STATE ACTION-SPECIFIC ARARS ARE AS FOLLOWS: NJ HAZARDOUS WASTE REGULATIONS (NJAC 7:26): PERMITTING, CONTINGENCY PLANS, SPECIFICATION FOR TREATMENT/ DISPOSAL UNITS. POTENTIAL ARARS FOR ALTERNATIVES WHICH INVOLVE THE TREATMENT, STORAGE OR DISPOSAL OF HAZARDOUS WASTES. NJ CLEAN WATER ACT (NJAC 7:14A-1.1 ET SEQ.): NJPDES WATER QUALITY TOXIC EFFLUENT LIMITATIONS. ARAR FOR ALTERNATIVE INVOLVING TREATMENTS WHICH DISCHARGE EFFLUENTS TO SURFACE WATER. NJ POLLUTANT DISCHARGE ELIMINATION SYSTEM (NJAC 7:14A-1 ET SEQ.): PERMIT REQUIREMENTS. ARAR FOR ALTERNATIVES INVOLVING TREATMENTS WHICH DISCHARGE EFFLUENT TO GROUND SURFACES. NJ SURFACE WATER REGULATIONS (NJAC 7:9-5.1): ARARS FOR ALTERNATIVES INVOLVING TREATMENT WHICH DISCHARGE TOXIC POLLUTANTS TO AREA WATER BODIES. NJ AIR POLLUTION CONTROL REGULATIONS (NJAC 7:27-16): PERMITS AND EMISSION LIMITATION FOR VOCS. ARARS FOR ALTERNATIVES FOR TREATMENTS WHICH IMPACT AMBIENT AIR. ------- ENDANGERED SPECIES ACTION (16 USC 1531): CONSULTATION WILL BE UNDERTAKEN WITH THE FISH AND WILDLIFE SERVICE TO DETERMINE IF THE REMEDIAL ACTION WILL ADVERSELY AFFECT ENDANGERED SPECIES IN THE AREA. THE PINELANDS PROTECTION ACT (NJSA 18A-1 ET AL) AND THE PINELANDS COMPREHENSIVE MANAGEMENT PLAN (NJAC 7:50-1.1 ET AL). ------- |