87th Air Base Wing Joint Base McGuire-Dix-Lakehurst Public Meeting - - PowerPoint PPT Presentation
87th Air Base Wing Joint Base McGuire-Dix-Lakehurst Public Meeting - - PowerPoint PPT Presentation
87th Air Base Wing Joint Base McGuire-Dix-Lakehurst Public Meeting March 14, 2019 Proposed Plan Dix Site NW042 (0900 Area) 87th Air Base Wing Mr. Curtis Frye, P.E. Chief, Environmental Restoration Program, JB MDL AFCEC/CZOE Mr.
87th Air Base Wing
- Mr. Curtis Frye, P.E.
Chief, Environmental Restoration Program, JB MDL AFCEC/CZOE
- Mr. David Heuer, Phase Manager, Arcadis
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Public Meeting Purpose
◼
U.S. Air Force is inviting the public to comment on the proposed environmental actions for the Dix Site NW042 (0900 Area)
◼
The opening of a 30-day public comment period was posted in the Asbury Park Press and Burlington County Times and started March 3rd and will end April 2, 2019
◼
Comments from the public may be submitted tonight (verbally
- r written), or sent to Curtis Frye (mail or e-mail)
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Status of CERCLA* Process
Preliminary Assessment Site Inspection Remedial Investigation Feasibility Study Proposed Plan Record of Decision Remedial Design Remedial Action
Long Term Management
✓Remedial Investigation (RI) - characterization of site ✓Feasibility Study (FS) - assessment of possible remedies ✓Proposed Plan (PP) - solicit public input on preferred remedy ❑Record of Decision (ROD) - legal documentation of remedy selection ❑Remedial Design (RD) - remedy implementation plan ❑Remedial Action (RA) - remedy implementation
*Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
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Proposed Plan
◼
Provides information necessary to allow the public to participate in selecting the appropriate remedial alternatives
◼ The Proposed Plan
▪
Summarizes site history, investigations, and results of human health and ecological risk assessments
▪
Describes remedial alternatives considered
▪
Provides a comparative analysis of remedial alternatives based upon USEPA established criteria
▪
Presents the preferred remedial alternative
▪
Contains information on community participation
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Presentation Agenda
◼
Background
◼
Conceptual Site Model
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Remedial Action Objectives
◼
Technology Assessment
◼
Assembly and Evaluation of Alternatives; and Identification of the Preferred Remedy
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Public Comment Period Information
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Background
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NW042 Site Location
NW042 SITE
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NW042 Site Plan
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NW042 History
◼ ~40 acre site ◼ Currently vacant grassy
land
◼ Military Housing 1955 to
1994 (Kennedy Court Housing complex)
- 400 family units in 64
buildings ◼ Undeveloped land prior to
construction of housing
Photo-credit: Arcadis site investigation photo
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Summary of Historical Investigations
◼ 2009 surface soil sampling completed by Ft. Monmouth DPW
- 102 soil samples collected around former Buildings 923 through 933
for pesticides
◼ August and September 2009 Site Investigation
- Geophysical survey (i.e., exploration for potential USTs)
- Sitewide, 36 soil borings sampled for VOCs, SVOCs, and metals
- 3 temporary wells sampled for VOCs, SVOCs, metals, and pesticides
- 12 surface soil samples for PCBs targeting fallen pole-mounted
transformers
- Buildings 923 through 933, 50 shallow soil borings sampled for
pesticides
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Summary of Historical Investigations continued
◼ 2012-2013 Remedial Investigation
- 472 soil samples collected from 135 soil borings
- 18 direct-push technology groundwater samples
- 11 monitoring wells installed; 25 groundwater samples collected
from wells ◼ The RI focused on a subset of five former buildings (923
through 927) with an extensive sampling program to precisely define nature and extent of impacts and support a thorough Conceptual Site Model (CSM) for the entire site
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Conceptual Site Model
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Investigation/Sampling 2009 through 2012
Impacted media limited to soil near former buildings. Groundwater is not impacted.
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Nature and Extent
◼ Site soil impacted by three pesticides at concentrations
exceeding the Residential Direct Contact Soil Remediation Standards (RDCSRSs)
- Alpha chlordane (RDCSRS 0.2 mg/kg)
- Gamma chlordane (RDCSRS 0.2 mg/kg)
- Dieldrin (RDCSRS 0.04 mg/kg)
◼ Pesticide impacts generally limited to the interval between 2 and
4.5 feet below ground surface near former buildings; no impacts to soil in courtyard areas or in soil 25 feet from former buildings
◼ No VOC, SVOC, PCBs, or metals impacts to soil ◼ Groundwater is not impacted
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Source and Distribution
Impacts limited to shallow soil near former housing
Pesticides: alpha chlordane, gamma chlordane, and dieldrin
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Remedial Action Objectives (RAOs)
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Feasibility Study
◼ Feasibility Study (FS) was conducted to evaluate possible
remedial alternatives at this site
▪ Trigger for remediation: Pesticides were identified in soils at
concentrations above the New Jersey Residential Direct Contact Soil Remediation Standards (RDCSRSs).
▪ Soil is the only media impacted at the site
▪ No action required for groundwater ▪ Surface water and sediment are not present at the site
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Remedial Action Objectives
◼ The following RAOs were established for Dix Site NW042 (0900 Area) and
are presented below:
- RAO No, 1: To prevent human exposure to soil by the direct contact pathway
(i.e., inhalation and ingestion-dermal pathways) that would cause unacceptable risk to human health, thereby allowing for unlimited use/unrestricted exposure.
- RAO No. 2: To achieve the applicable NJDEP RDCSRS for the identified COCs
in soil in a reasonable timeframe, thereby restoring the Site for unlimited use/unrestricted exposure.
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Preliminary Remedial Goals
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Technology Assessment
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Pre-Design Investigation 2017
◼ August 2017 Pre-Design Investigation
- 171 subsurface soil and 27 surface soil samples collected for alpha
chlordane, gamma chlordane, technical chlordane, and dieldrin
◼ The PDI sampling was completed to confirm the CSM developed during
the RI and obtain data to determine site-wide compliance status
◼ The evaluation of Site soils was completed in accordance with the
NJDEP Historically Applied Pesticide Technical Guidance (NJDEP 2016) and Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria (September 2012).
- A site-wide average concentration can be calculated to determine compliance
with the applicable soil standards using NJDEP-approved statistical calculations
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Investigation/Sampling 2017
PDI sampling confirmed the CSM and provided data for compliance calculations.
Soil sampling at Former Buildings 923 through 933 completed during SI/RI phase
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Baseline Compliance Status
- Site-wide spatially-weighted
average calculated using the Thiessen Polygon method in accordance with NJDEP guidance.
- Used all available data from
the SI (AMEC 2009), RI (CB&I 2014), and pre- design sampling (2017).
- 308 data points across 40
acres (approximately 8 samples per acre)
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Targeted Remediation Areas
- The compliance averaging
calculations were performed by replacing the concentrations of the two highest baseline total chlordane (alpha and gamma) concentration polygons
- SB-243 and SB217 – total
area 0.3 acres; volume 2,420 cubic yards)
- Used a typical soil quality
concentration (0.5 mg/kg) resulting from soil mixing (estimated total chlordane was 0.5 mg/kg per the pilot study results provided in FS [Arcadis 2016]).
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Technology Assessment
- In-Situ Soil Mixing
Blending/ Mixing
- Soil Excavation and Offsite Disposal
Removal and Disposal
- Ex-Situ Soil Treatment and Backfill
Treatment
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In-Situ Soil Mixing Pilot Testing
◼ August 2015 Pilot Test for In-Situ Soil Mixing
- Three mixing scenarios were implemented in three different test cells
- Baseline and two rounds of post mixing soil sampling were
completed
- Objective was to determine effectiveness and viability of mixing to
support evaluation of this potential alternative in the FS (results included as appendix to the FS [Arcadis 2016].
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In-Situ Soil Mixing
Image Credit: 2015 Soil Mixing Pilot Test, Site NW042
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Removal and Disposal Soil Excavation and Offsite Disposal
Image Credit: Excavation remedy at McGuire
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Treatment Ex-situ Soil Treatment
Image Credit: Site remediation project, Arcadis NA
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Assembly and Evaluation of Alternatives; and Identification of the Preferred Remedy
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Remedial Alternatives
◼
Alternative 1: No Further Action: The NCP requires that the “No Action” alternative be developed and examined as a potential remedial action for all sites.
◼
Alternative 2: (In-Situ Soil Mixing): In-situ soil mixing of impacted soil in targeted areas to reduce the overall concentration of pesticides in soil at the Site to meet the Remedial Goals on a sitewide basis
◼
Alternative 3: (Excavation and Offsite Disposal): Removal and off-site disposal of impacted soil from targeted areas to meet the Remedial Goals on a sitewide basis; impacted soil would be landfilled at an off-site disposal facility under this alternative
◼
Alternative 4: (Ex-Situ Soil Treatment ): Impacted soil in targeted areas would be excavated, temporarily stockpiled, processed through an on-site treatment system, and utilized as backfill material on-site to meet the Remedial Goals on a sitewide basis
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Target Remediation Areas
Alternatives 2, 3, and 4
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CERCLA Evaluation Criteria
Modifying Criteria
State/Support Agency Acceptance Community Acceptance
Primary Balancing Criteria
Long-term effectiveness and permanence Reduction of toxicity, mobility, and volume through treatment Short-term Effectiveness Implementability Cost Effectiveness
Threshold Criteria
Overall protection of human health and the environment Compliance with applicable or relevant and appropriate requirements (ARARs)
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Evaluation of Alternatives
Criteria 1 2 3 4
Overall Protection of Human Health and the Environment Does Not Meet Meets Meets Meets Compliance with ARARs Does Not Meet Meets Meets Meets Long-Term Effectiveness and Permanence Poor Good Superior Better Reduction of Toxicity, Mobility, or Volume through Treatment Poor Good Poor Superior Short-Term Effectiveness Poor Good Good Good Implementability Superior Better Good Good Cost $0 $218,000 $580,000 $550,000
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Preferred Alternative
◼ The preferred alternative for Site NW042 is Alternative
2: In-Situ Soil Mixing
◼ NJDEP and NJ Pinelands Commission concur with the
preferred alternative
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Proposed Plan
◼ The PP will be available for public review from March 3, 2019 to
April 2, 2019 in the Administrative Record located:
Burlington County Library 5 Pioneer Boulevard Westampton, NJ 08060 NJDEP Records Custodian 401 East State St. P.O. Box 420 Trenton, NJ 08625
◼ A copy of the PP also available online at: http://afcec.publicadmin-
record.us.af.mil/ or at www.envirorestorejbmdl.com (click on the Community Involvement tab)
◼ Public comments will be reviewed and considered before remedy
selection is finalized and documented in the Record of Decision
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Public Comments
◼ Comments from the public will be accepted tonight
(verbal or written)
◼ Comments will be accepted until April 2nd, 2019 ◼ Send comments to the following:
- Mail:
- E-mail: curtis.frye@us.af.mil
- Mr. Curtis Frye; Chief Environmental Restoration Program
787 CES/CEIE 2403 Vandenberg Avenue JB MDL, NJ 08641
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BACK UP SLIDES
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Compliance Status Overview
◼ The evaluation of Site soils was completed in accordance with the
NJDEP Historically Applied Pesticide Technical Guidance (NJDEP 2016). The guidance is applicable to the Site based on meeting the following required conditions identified in the guidance:
- The application of pesticides at the Site was in accordance with intended and
proper use;
- Dieldrin and chlordane (the identified contaminants of concern [COCs]) are
specifically cited as applicable pesticides included in the guidance document;
- The Site is not a mixing or storage site, spill site, or recent discharge; and
- The pesticide application is historical, evident from the fact that chlordane
application was banned in the U.S. in 1988 according to the Toxicological Profile for Chlordane (U.S. Department of Health and Human Services 2018).
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NJDEP Pesticide Guidance
◼ Key provisions of the NJDEP Historically Applied Pesticide (HAP)
Technical Guidance (NJDEP 2016):
- A site-wide average concentration can be calculated to determine compliance
with the applicable soil standards for the pesticides covered by the HAP guidance
- After completing the initial calculations, if remediation is required to attain
compliance in-situ soil mixing can be performed to blend impacted soil and non-impacted soil to lower soil pesticide concentrations until target concentrations are achieved
- The guidance is provided at https://www.nj.gov/dep/srp/guidance/.
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Overview of Calculations
◼
NJDEP provides technical guidance for compliance attainment: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012.
◼
The Thiessen polygon method was used for Site NW042 (specially Section A3.0 of the technical guidance)
◼
Thiessen polygon define individual areas of influence around each set of points and are polygons whose boundaries define the area that is closest to each point relative to all other point (they are mathematically constructed)
◼
This is a spatially-weighted average approach to compliance attainment; sampling results are weighted according to the area they represent (i.e., the results of each sample are adjusted for the percentage of the
- verall area the corresponding sample represent, and the
adjusted values are averaged) Image Credit: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012
Sample locations Polygon set up
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Overview of Calculations
Image Credit: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012
◼
An iterative analysis is typically performed when determining extent of remediation required if the initial (i.e., baseline) calculation does not demonstrate compliance
◼
Replace the most highly contaminated polygon with a fill or background concentration and then recalculate the area weighted mean concentration
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This process continues progressively with the next most contaminated polygon until the area weighted mean for the site is at or below the applicable standard
Polygon replacement
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Compliance Status Overview
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The quantity of impacted soil requiring remediation is 2,420 cubic yards, which is based on the compliance averaging calculations discussed in the FS Addendum (Arcadis 2018).
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The quantity of soil requiring remediation is consistent for all remedial alternatives evaluated in the FS (Arcadis 2016) and presented in the Proposed Plan.
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The compliance averaging calculations completed to determine the compliance status of the Site soil, and subsequently the amount of remediation required to attain compliance for the compounds requiring further action, was completed in accordance with NJDEP technical guidance.
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Compliance Status Overview
◼ The evaluation of Site soils was completed in accordance with the
NJDEP Historically Applied Pesticide Technical Guidance (NJDEP 2016). The guidance is applicable to the Site based on meeting the following required conditions identified in the guidance:
- The application of pesticides at the Site was in accordance with intended and
proper use;
- Dieldrin and chlordane (the identified contaminants of concern [COCs]) are
specifically cited as applicable pesticides included in the guidance document;
- The Site is not a mixing or storage site, spill site, or recent discharge; and
- The pesticide application is historical, evident from the fact that chlordane
application was banned in the U.S. in 1988 according to the Toxicological Profile for Chlordane (U.S. Department of Health and Human Services 2018).
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NJDEP Pesticide Guidance
◼ Key provisions of the NJDEP Historically Applied Pesticide (HAP)
Technical Guidance (NJDEP 2016):
- A site-wide average concentration can be calculated to determine compliance
with the applicable soil standards for the pesticides covered by the HAP guidance
- After completing the initial calculations, if remediation is required to attain
compliance in-situ soil mixing can be performed to blend impacted soil and non-impacted soil to lower soil pesticide concentrations until target concentrations are achieved
- The guidance is provided at https://www.nj.gov/dep/srp/guidance/.
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Overview of Calculations
◼
NJDEP provides technical guidance for compliance attainment: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012.
◼
The Thiessen polygon method was used for Site NW042 (specially Section A3.0 of the technical guidance)
◼
Thiessen polygon define individual areas of influence around each set of points and are polygons whose boundaries define the area that is closest to each point relative to all other point (they are mathematically constructed)
◼
This is a spatially-weighted average approach to compliance attainment; sampling results are weighted according to the area they represent (i.e., the results of each sample are adjusted for the percentage of the
- verall area the corresponding sample represent, and the
adjusted values are averaged) Image Credit: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012
Sample locations Polygon set up
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Overview of Calculations
Image Credit: Technical Guidance for Attainment of Remediation Standards and Site-Specific Criteria. September 2012
◼
An iterative analysis is typically performed when determining extent of remediation required if the initial (i.e., baseline) calculation does not demonstrate compliance
◼
Replace the most highly contaminated polygon with a fill or background concentration and then recalculate the area weighted mean concentration
◼
This process continues progressively with the next most contaminated polygon until the area weighted mean for the site is at or below the applicable standard
Polygon replacement