Attachment VI - QPI RCAG PASI final with attchmts_Reduced.pdf

Preliminary Assessment / Site Investigation Report

Matawan, NJ

QPI Remote Communications Air/Ground (RCAG)

JCN 19003801

November 4, 2020

PREPARED BY: PARSONS

T4 New England Program Office 1200 District Avenue Burlington, MA 01803

PREPARED FOR: Federal Aviation Administration 1200 District Avenue Burlington, MA 0180

Preliminary Assessment / Site Investigation – QPI RCAG

Table of Contents

1.0 INTRODUCTION

2.0 SITE DESCRIPTION

3.0 ENVIRONMENTAL DUE DILIGENCE

3.1 EDR Database Report

3.2 Historic Aerial Photographs

4.0 SUMMARY OF ACTIVITIES

4.1 Site Reconnaissance

4.2 Site Investigation

4.2.1 Exterior Paint and Soil at Towers

4.2.2 Exterior Paint and Soil at Equipment Building

4.2.3 Exterior Paint and Soil at EG Building

5.0 CONCLUSIONS

6.0 RECOMMENDATIONS

7.0 REFERENCES

TABLES

Table 1 – Site Information Table 2 – Summary of Analytical Results

FIGURES

Figure 1 – Site Location Figure 2 – Site Layout Figure 3 – Soil Sample Locations

APPENDICES

Appendix A – Site Photographs Appendix B – EDR Radius Search & Aerials Appendix C – Contractor Summary Reports & Laboratory Analytical Reports

1.0 INTRODUCTION

The purpose of the Preliminary Assessment / Site Investigation (PA/SI) was to determine whether contaminants of concern are present on-site, have migrated or are migrating from the site, and conduct the initial search for and evaluation of, existing site-specific operational and environmental information, both current and historic, to determine if further investigation concerning the documented, suspected, or latent discharge of any contaminant is required. Due to the age of the facility, the contaminants of concern include polychlorinated biphenyls (PCBs), lead associated with potential lead-based paint, and asbestos. This PA/SI was completed in accordance with the Federal Aviation Administration (FAA) Air Traffic Organization (ATO) Environmental and Occupational Safety and Health (EOSH) Services Soil Baseline Sampling Guide for Facilities Scheduled for Decommissioning with Suspected Lead Based Paint and Polychlorinated Biphenyl (PCB)- Containing Paint (FAA Sampling Guide), dated September 2019, Version 3; in accordance with the FAA Air Traffic Control Facilities EOSH Services Environmental Cleanup Program (ECU) Research Paper on Polychlorinated Biphenyls (PCBs) in Paint and Other Building Materials, dated August 12, 2019; and in compliance with United States Environmental Protection Agency (USEPA) federal guidance.

Methods include interviews with individuals familiar with the subject properties, site surveys, historical records review, and report preparation. Information obtained in interviews and the sites reconnaissance was recorded and reviewed before inclusion into this report. All information obtained during the PA/SI and subsequently included within this report is assumed to be reliable.

2.0 SITE DESCRIPTION

The subject site is located in Marlboro Township, NJ (FAA facility identifier QPI). The facility at the subject site is a Remote Communications Air/Ground (RCAG). The site is located in a forested and residential area. The subject site is referred to herein as QPI RCAG, or subject site.

The subject site is situated within an approximate 150 ft. x 75 ft. metal-fenced in area on a gravel plot and consists of an equipment building, engine generator (EG) building, two unpainted metal self-supporting towers, and a well. The towers are 40 ft. and 50 ft. tall. The equipment building is a 13 ft. x 29 ft. wood frame building on a concrete slab foundation. The EG building is a 13 ft.

x 17 ft. wood frame building on a concrete slab foundation. Both buildings were in good condition with fully intact flooring.

A review of the historic aerials indicates that a structure has been present at the subject site since 1951. FAA records obtained from the UIS GIS database indicate that the current buildings and Tower 1 were constructed in 1974, and Tower 2 was constructed in 1957. The subject site is located on a hill and is approximately 0.12 miles east of a freshwater wetland per the National Wetlands Inventory Map. The surrounding area is generally forested land with residential use.

Several residential-use wells are present within ¼ mile of the site. Therefore, the site is considered to be within a wellhead protection area and sensitive receptor use is presumed.

3.0 ENVIRONMENTAL DUE DILIGENCE

Environmental due diligence for this PA/SI is limited to a site-specific review of the standard federal, state, and local environmental databases and a review of historic aerial photographs.

3.1 EDR Database Report

A review of environmental records and databases was performed utilizing Environmental Data Resources Inc. (EDR). The subject site (40.370895°, -74.220954°) and adjoining properties were not listed in any of the environmental records listed in the database report.

Sites surrounding the subject site, located within the standard ASTM search distances from the subject site appeared in the following environmental databases: State Hazardous Waste Sites (SHWS); New Jersey Environmental Management System (NJEMS); Known Contaminated Sites Listing (HIST HWS); Hazardous Material Incident Database (NJ Release); Facility Index System/Facility Registry System (FINDS); and Voluntary Cleanup Program (VCP).

Based on the relative distance from the subject site, down-gradient to cross-gradient hydraulic position, continued regulatory oversight, soil-only media impacted, lack of reported violations or releases, and/or current case-closed/NFA status, sites that are non-adjoining are not anticipated to represent a significant environmental concern to the subject site and are not further discussed.

Several domestic water wells were identified by EDR within a1/4-mile radius of the site, including:

Thirteen (13) domestic supply wells are located within 500-feet of and topographically down-gradient from the site (EDR wells A1, A2, A3, A4, A5, A6, A7, A8, A9, B10, B11, C12, and C13);

Forty eight (48) domestic supply wells are located within 1/8 and 1/4 mile of and topographically down-gradient from the site (EDR wells D14, D15, E16, E17, E18, E19, E20, E21, E22, E23, E24, E25, E26, E27, E28, E29, E30, E31, E32, E33, E34, E35, E36, E37, E38, E39, E40, F41, F42, F43, F44, F45, F46, F47, F48, F49, G50, G51, H52, H53, I54, I55, I56, G57, H58, H59, H60, 61).

Based on the presence of thirteen (13) domestic water supply wells within 500 feet of the site and one (1) well located on the site, the property is considered to be within a wellhead protection area, and sensitive receptors are assumed.

3.2 Historic Aerial Photographs

Historic aerial photographs were obtained from EDR and reviewed to assess historic conditions at the subject site including photographs for the years 1931 to 2017. The aerial photographs are included in Appendix B and are summarized briefly below.

The subject site is undeveloped in 1931. Initial development includes the appearance of a structure in 1951. The adjoining properties appear to be undeveloped or residential use to 2017.

There is a small site located west of the QPI RCAG site that appears in 1940 through 1995. No indications of industrial activity or environmental disturbance were noted at the subject site or adjoining properties from the aerial photographs reviewed. Residential use of adjoining properties is considered a sensitive receptor group for the subject site.

4.0 SUMMARY OF ACTIVITIES

4.1 Site Reconnaissance

A site visit was conducted on November 4, 2020 to inspect the facility property and perform a Site Investigation. Refer to Section 7.0 for a full list of any records reviewed individuals interviewed. Refer to Table 1 for a detailed list of wastes and hazardous substances managed at the Facility. Refer to Appendix A for site photographs from the inspection.

At the time of the site inspection, the QPI RCAG towers were noted to be in fair condition and the two buildings were noted to be in good condition. There is a 500-gallon above ground storage tank (AST) containing diesel fuel at the site, which appeared to be in good condition. One pole-mounted transformer is present immediately outside the perimeter fence, which is in good condition. However, it is not labeled for presence or absence of PCBs. A pump pit containing a well head is also present on site. No evidence of hazardous material mismanagement, in terms of storage, use or disposal, was observed on the subject site during the site visit, interviews, or during record review. Site drawings were found on site. As-built drawings found on ProjectWise show a former underground fuel storage tank (UST) on site. The UST was removed on October 10, 1997 and a Closure Report was sent to the State with a No Further Action recommendation.

4.2 Site Investigation

Due to the age of the site (the current structures pre-date 1983), the presence or absence of lead and PCBs in exterior paint, and lead- and PCBs-in-soil concentrations at the subject site and surrounding soils was investigated in support of this PA/SI. Building materials testing was conducted concurrently with the soil and exterior paint testing in support of a Parsons Site Survey for decommissioning purposes, as briefly summarized in Table 1 of this report. Interior building materials are not further discussed in this document as the focus of this PA/SI pertains to environmental conditions. The Site Survey Report is referenced at the end of this document and is available upon request.

Site Investigation activities were conducted by TTI Environmental on November 4, 2020 to collect and analyze soil and building material samples in accordance with the FAA Sampling Guide. The sampling conducted is summarized as follows:

Soil samples were analyzed for total lead via USEPA Method 7000B Soil samples were analyzed for PCBs via USEPA Method 8082A Paint chip samples were analyzed for lead via USEPA Method SW 846 7000B Building material samples were analyzed for PCBs via USEPA Method 8082A.

The investigation and results are summarized in sub-sections 4.2.1 and 4.2.2 below and are presented in Table 2.

4.2.1 Exterior Paint and Soil at Towers

The towers were not painted at the time of the site survey. Therefore, no paint chip samples were collected from the two towers to assess levels of lead or PCBs.

Soil in the vicinity of the two towers were investigated for the presence of lead based on the threshold of the USEPA residential limit and New Jersey Residential Direct Contact Soil Remediation Standard (400 mg/kg lead) (state cleanup level for lead); and for the presence of PCBs for comparison to the Toxic Substances & Control Act (TSCA) limit of 1 mg/kg PCBs for high occupancy areas and the New Jersey Residential Direct Contact Soil Remediation Standard (0.2 mg/kg PCBs) (state cleanup level for PCBs). Soil samples were collected to assess levels of lead and PCBs present around the drip line and five feet horizontally from the dripline at the towers in accordance with the September 2019 FAA Sampling Guide. Samples were collected from bare soil areas only. The sampling conducted and results are summarized as follows:

All lead in soil results are below the USEPA residential limit and the state cleanup level for lead (400 mg/kg).

All PCB in soil results were below laboratory quantitation limits, and below the TSCA limit of 1 mg/kg PCBs for high occupancy areas and the state cleanup level for PCBs (0.2 mg/kg).

4.2.2 Exterior Paint and Soil at Equipment Building

Three representative paint chip samples were collected from the exterior of the equipment building to assess levels of lead present for comparison to the USEPA and HUD Guidelines for the determination of LBP (5,000 mg/kg lead, or 0.5% by weight). The result is summarized below:

Two of the samples collected were above the USEPA threshold lead concentration value of 0.5% by weight for classification as LBP. Concentrations were 2.0% and 2.50%.

Four representative paint chip samples were collected from the exterior of the equipment building to assess levels of PCBs present for comparison to the FAA ECU screening criteria of 50 mg/kg for classification as PCB Bulk Product Waste.

PCBs were detected in three (3) of the samples collected from the exterior of the equipment building. Concentrations range from 0.24 mg/kg to 4.5 mg/kg. All PCB results for the exterior samples are less than the FAA ECU screening criteria of 50 mg/kg for classification as PCB Bulk Product Waste. Therefore, the samples from the exterior of the equipment building are not considered PCB Bulk Product Waste.

Soil in the vicinity of the equipment building was investigated for the presence of lead based on the threshold of the USEPA residential limit and the state cleanup level for lead (400 mg/kg); and for the presence of PCBs for comparison to the TSCA limit of 1 mg/kg PCBs for high occupancy areas and the state cleanup level for PCBs (0.2 mg/kg). Soil samples were collected to assess levels of lead and PCBs present around the drip line and five feet horizontally from the dripline at the equipment building in accordance with the September 2019 FAA Sampling Guide. The sampling conducted and results are summarized as follows:

The results for the four soil samples collected at the dripline around the equipment building range from 86 mg/kg to 12,000 mg/kg lead. The results for the four step-out soil samples collected five feet from the drip line samples at the equipment building range from 190 mg/kg to 940 mg/kg lead. Four lead in soil results are above the USEPA residential limit and the state cleanup level for lead (400 mg/kg).

All PCB in soil results are below the TSCA limit of 1 mg/kg PCBs for high occupancy areas.

One PCB result (0.88 mg/kg) is above the state cleanup level for PCBs (0.2 mg/kg).

4.2.3 Exterior Paint and Soil at EG Building

Two representative paint chip samples were collected from the exterior of the EG building to assess levels of lead present for comparison to the USEPA and HUD Guidelines for the determination of LBP (5,000 mg/kg lead, or 0.5% by weight). The result is summarized below:

Both of the samples collected were above the USEPA threshold lead concentration value of 0.5% by weight for classification as LBP. Concentrations are 0.52% and 1.4%.

Two representative paint chip samples were collected from the exterior of the EG building to assess levels of PCBs present for comparison to the FAA ECU screening criteria of 50 mg/kg for classification as PCB Bulk Product Waste.

Both PCB results are less than the FAA ECU screening criteria of 50 mg/kg for classification as PCB Bulk Product Waste. Therefore, the samples from the exterior of the equipment shelter are not considered PCB Bulk Product Waste.

Soil in the vicinity of the EG building was investigated for the presence of lead based on the threshold of the USEPA residential limit and the state cleanup level for lead (400 mg/kg lead);

and for the presence of PCBs for comparison to the TSCA limit of 1 mg/kg PCBs for high occupancy areas and the state cleanup level for PCBs (0.2 mg/kg PCBs). Soil samples were collected to assess levels of lead and PCBs present around the drip line and five feet horizontally from the dripline at the equipment building in accordance with the September 2019 FAA Sampling Guide. The sampling conducted and results are summarized as follows:

The results for the four soil samples collected at the dripline around the EG building shelter range from 210 mg/kg to 440 mg/kg lead. The results for the four step-out soil samples collected five feet from the drip line samples at the EG building range from 120 mg/kg to 660 mg/kg lead. Two (2) lead in soil results are above the USEPA residential limit and the state cleanup level for lead (400 mg/kg).

PCBs were reported at concentrations of 0.053 mg/kg to 0.085 mg/kg and therefore all PCB in soil results are below the TSCA limit of 1 mg/kg PCBs for high occupancy areas and the state cleanup level for PCBs (0.2 mg/kg PCBs).

5.0 CONCLUSIONS

The QPI RCAG site is located in a forested/residential area and approximately 0.12 miles away from a wetland area per the National Wetlands Inventory Map. No sites of concern were identified in the EDR radius search, and no history of industrial or commercial operations were noted on the subject site or adjoining properties from a review of historic aerial photographs.

Several domestic water supply wells were within 500 feet of the site, so the property is considered to be within a wellhead protection area.

Paint samples collected from the exterior of the equipment building and EG building were determined to be classified as LBP. Lead concentrations in six (6) soil samples exceeded the USEPA residential limit and the state cleanup level for lead (400 mg/kg). No PCBs were detected in the surface samples above the FAA ECU screening criteria of 50 mg/kg for classification as PCB Bulk Product Waste. PCBs were detected in one (1) soil sample below the TSCA limit of 1 mg/kg PCBs for high occupancy areas, but above the state cleanup level for PCBs (0.2 mg/kg PCBs).

6.0 RECOMMENDATIONS

Because soil samples with elevated concentrations above their respective screening levels for lead and PCBs were identified during the course of this PA/SI, Parsons recommends that further investigation be conducted, and that the QPI RCAG facility be submitted to the FAA Environmental Cleanup Program for further action.

7.0 REFERENCES

1. UIS GIS database (http://uisgis/Welcome.aspx):

a. Facilities Service and Equipment Profile (FSEP)

b. Delphi Asset database

c. UIS Assets database

d. NAP entries

e. Joint Acceptance Inspection (JAI) database

f. Real Estate Management System (REMS)

2. ArcGIS topographical maps (https://www.arcgis.com/home/webmap/viewer.html )

3. U.S Fish and Wildlife Service-National Wetlands Inventory

(https://www.fws.gov/wetlands/ )

4. Environmental Data Resources Inc. (EDR) “Basic” Record Review Package (refer to

Appendix B) for subject site at Lat: 40.370895; Long: -74.220954 in Marlboro Township, NJ:

a. EDR Radius Map Report

b. Historical Aerial Photos

5. USEPA References

a. USEPA Regional Screening Levels – Generic Tables https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables

6. State of New Jersey Records & References

a. New Jersey Site Remediation Program https://www.nj.gov/dep/srp/guidance/rs/

7. Interviews were conducted with the following FAA personnel:

a. Jason Browning, SSC Manager, 862-400-0068

b. Gary Hall, SSC Coordinator, 609-743-4494

TABLE 1: SITE INFORMATION

Site Address Nearest Address: gate to Triple Farms, intersection of Reids Hill Road and

Beacon Hill Road, Morganville, NJ Nearest Intersection: Reids Hill Road and Beacon Hill Road 40.370895y: Frederick Coordinates 40.370895°, -74.220954°

Site Elevation 372 ft. above mean sea level Construction Date Buildings and one (1) tower (NW): 1974; one (1) tower (SE): 1957

Earliest REMS Date 1974 FSEP Commissioned Date 1957

FSEP SWAP Out Date Unknown Ownership Site is government owned

Access road Lease No. 69435Z-19-L-00100 Non Restoration (6.3.18)

Co-Located No

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED

☒ Engine Generator: Yes ☒ Air Conditioning (A/C) Units: One (1) ☐ Sewage: N/A; none found during site survey

☐ Floor Drains: N/A ☒ Antifreeze and Oil: Gallon containers in cabinets ☒ Drinking Water: well inside pump pit ☐ Chemical Storage and Hazard Communication: N/A ☒ Batteries: Two (2) 12-V Batteries

☐ Staining or Releases: N/A ☒ UST or AST: 500 gallon AST. Drawings show former UST; see closure report in Appendix of Site

Survey Report ☒ Exterior Transformers/Equipment: Pole-mounted transformer located outside perimeter fence.

☐ Interior Transformers/Equipment: N/A ☐ Pesticides: N/A ☒ Lead in Soil: Elevated lead present in soil samples collected

☒ Lead in Paint: Lead based paint identified on the two buildings

☒ PCBs in Soil: One (1) soil sample with elevated PCBs above the state cleanup level

☐ PCBs in Building Materials: No PCB Bulk Product Waste detected ☒ Asbestos in Building Materials: ACM detected in the EG building (refer to Site Survey Report)

☐ Other: N/A

HISTORY AND/OR EVIDENCE OF RELEASE(S)

☒ No evidence of mismanagement ☐ Evidence of mismanagement

Sample ID Lab ID Structure Location Description Result Total Lead % by weight

05 202010767-0005 Equipment building Exterior door/metal Gray paint 2.50%

06 202010767-0006 Equipment building Exterior awning/metal Gray paint 0.12%

07 202010767-0007 Equipment building Exterior louver/metal Gray paint 2.00%

05 202010764-0005 EG building Exterior louver Gray paint 0.52%

06 202010764-0006 EG building Exterior window frame Gray paint 1.4%

Sample ID Lab ID Structure Location Depth Below Gravel

Layer Lead (mg/kg)

01 202010765-0001 EG building Dripline 0-6 inches 440

02 202010765-0002 EG building Dripline 0-6 inches 260

03 202010765-0003 EG building Dripline 0-6 inches 210

04 202010765-0004 EG building Dripline 0-6 inches 220

05 202010765-0005 EG building 5 ft. 0-6 inches 660

06 202010765-0006 EG building 5 ft. 0-6 inches 120

07 202010765-0007 EG building 5 ft. 0-6 inches 250

08 202010765-0008 EG building 5 ft. 0-6 inches 180

09 202010765-0009 Equipment building Dripline 0-6 inches 12,000

10 202010765-0010 Equipment building Dripline 0-6 inches 86

11 202010765-0011 Equipment building Dripline 0-6 inches 510

12 202010765-0012 Equipment building Dripline 0-6 inches 630

13 202010765-0013 Equipment building 5 ft. 0-6 inches 190

14 202010765-0014 Equipment building 5 ft. 0-6 inches 940

15 202010765-0015 Equipment building 5 ft. 0-6 inches 250

16 202010765-0016 Equipment building 5 ft. 0-6 inches 230

17 202010765-0017 Tower #1 Dripline 0-6 inches 130

18 202010765-0018 Tower #1 Dripline 0-6 inches 59

19 202010765-0019 Tower #1 Dripline 0-6 inches 170

20 202010765-0020 Tower #1 Dripline 0-6 inches 67

21 202010765-0021 Tower #1 5 ft. 0-6 inches 51

22 202010765-0022 Tower #1 5 ft. 0-6 inches 94

23 202010765-0023 Tower #1 5 ft. 0-6 inches 120

24 202010765-0024 Tower #1 5 ft. 0-6 inches 98

25 202010765-0025 Tower #2 Dripline 0-6 inches <40

26 202010765-0026 Tower #2 Dripline 0-6 inches <40

27 202010765-0027 Tower #2 Dripline 0-6 inches <40

28 202010765-0028 Tower #2 Dripline 0-6 inches <40

29 202010765-0029 Tower #2 5 ft. 0-6 inches <40

30 202010765-0030 Tower #2 5 ft. 0-6 inches <40

31 202010765-0031 Tower #2 5 ft. 0-6 inches 68

32 202010765-0032 Tower #2 5 ft. 0-6 inches 68 400 mg/kg

Notes: U.S. EPA Hazard Standard for Lead in Paint is 5,000 mg/kg lead, or 0.5% by weight

U.S.EPA Lead in Soil Action Level and State Cleanup Level (400 mg/kg)

EPA/State Screening Level

TABLE 2. SUMMARY OF ANALYTICAL RESULTS

Samples Analyzed for Lead in Paint

Samples Analyzed for Lead in Soil

Preliminary Assessment / Site Investigation -QPI RCAG

Sample ID Lab ID Sample

Location Description

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Result-PCBs (mg/kg)

162023941-

Equipment building Exterior Window <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 Non-Detect

162023941-

Equipment building Exterior Caulk <0.13 <0.13 <0.13 <0.13 <0.13 0.24 <0.13 <0.13 <0.13 0.24

162023941-

Equipment building Exterior louver <0.16 <0.16 <0.16 <0.16 <0.16 2.9 <0.16 1.6 <0.16 4.5

162023941-

Equipment building Exterior wall <0.097 <0.097 <0.097 <0.097 <0.097 1.6 <0.097 1.3 <0.097 2.9

162023938-

EG building

Exterior window frame

<0.17 <0.17 <0.17 <0.17 <0.17 13 <0.17 <0.17 <0.17 13

162023938-

EG building Exterior window glazing <0.12 <0.12 <0.12 <0.12 <0.12 3 <0.12 <0.12 <0.12 3

50 mg/kg

Sample ID Lab ID Structure Location Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Result-PCBs

(mg/kg)

012013045-

EG building Dripline <0.050 <0.050 <0.050 <0.050 <0.050 0.085 <0.050 <0.050 <0.050 0.085

012013045-

EG building Dripline <0.048 <0.048 <0.048 <0.048 <0.048 0.053 <0.048 <0.048 <0.048 0.053

012013045-

EG building Dripline <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 Non-Detect

012013045-

EG building Dripline <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 Non-Detect

012013045-

EG building 5 ft. <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 Non-Detect

012013045-

EG building 5 ft. <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 Non-Detect

012013045-

EG building 5 ft. <0.11 <0.11 <0.11 <0.11 <0.11 <0.11 <0.11 <0.11 <0.11 Non-Detect

012013045-

EG building 5 ft. <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 Non-Detect

012013045-

Equipment building Dripline <0.19 <0.19 <0.19 <0.19 <0.19 0.51 0.37 <0.19 <0.19 0.88

012013045-

Equipment building Dripline <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 Non-Detect

012013045-

Equipment building Dripline <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 Non-Detect

012013045-

Equipment building Dripline <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 Non-Detect

012013045-

Equipment building 5 ft. <0.067 <0.067 <0.067 <0.067 <0.067 <0.067 <0.067 <0.067 <0.067 Non-Detect

012013045-

Equipment building 5 ft. <0.052 <0.052 <0.052 <0.052 <0.052 0.059 <0.052 <0.052 <0.052 0.059

012013045-

Equipment building 5 ft. <0.053 <0.053 <0.053 <0.053 <0.053 0.059 <0.053 <0.053 <0.053 0.059

012013045-

Equipment building 5 ft. <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 Non-Detect

012013045-

Tower #1 Dripline <0.058 <0.058 <0.058 <0.058 <0.058 <0.058 <0.058 <0.058 <0.058 Non-Detect

012013045-

Tower #1 Dripline <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 Non-Detect

012013045-

Tower #1 Dripline <0.230 <0.230 <0.230 <0.230 <0.230 <0.230 <0.230 <0.230 <0.230 Non-Detect

012013045-

Tower #1 Dripline <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 Non-Detect

012013045-

Tower #1 5 ft. <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 Non-Detect

012013045-

Tower #1 5 ft. <0.260 <0.260 <0.260 <0.260 <0.260 <0.260 <0.260 <0.260 <0.260 Non-Detect

012013045-

Tower #1 5 ft. <0.063 <0.063 <0.063 <0.063 <0.063 <0.063 <0.063 <0.063 <0.063 Non-Detect

012013045-

Tower #1 5 ft. <0.097 <0.097 <0.097 <0.097 <0.097 <0.097 <0.097 <0.097 <0.097 Non-Detect

012013045-

Tower #2 Dripline <0.049 <0.049 <0.049 <0.049 <0.049 <0.049 <0.049 <0.049 <0.049 Non-Detect

012013045-

Tower #2 Dripline <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 Non-Detect

012013045-

Tower #2 Dripline <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 Non-Detect

012013045-

Tower #2 Dripline <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 Non-Detect

012013045-

Tower #2 5 ft. <0.100 <0.100 <0.100 <0.100 <0.100 <0.100 <0.100 <0.100 <0.100 Non-Detect

TABLE 2. SUMMARY OF ANALYTICAL RESULTS

Samples Analyzed for PCBs in Paint

Threshold for Bulk Waste

Samples Analyzed for PCBs in Soil

Sample ID Lab ID Structure Location Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Aroclor

Result-PCBs

(mg/kg)

012013045-

Tower #2 5 ft. <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 Non-Detect

012013045-

Tower #2 5 ft. <0.150 <0.150 <0.150 <0.150 <0.150 <0.150 <0.150 <0.150 <0.150 Non-Detect

012013045-

Tower #2 5 ft. <0.091 <0.091 <0.091 <0.091 <0.091 <0.091 <0.091 <0.091 <0.091 Non-Detect

1.0 mg/kg/0.2 mg/kg

Notes: FAA ECU Screening Criteria for PCBs in paint is 50 mg/kg for classification as PCB Bulk Product Waste.

Toxic Substances & Control Act (TSC) limit for PCBs in soil is 1 mg/kg (or 1,000 μg/kg) PCBs for high occupancy areas.

New Jersey limit for PCBs in soil is 0.2 mg/kg for residential use.

Limits for PCBs in soil (TSCA/NJ)

Appendix A – Site Photographs

Appendix B – EDR Radius Search and Historic Aerial Photos

Appendix C– Contractor Summary Reports & Laboratory Analysis