RAWP-NorthParcel-BMAD_20160811_FO.pdf

Submitted to U.S. General Services Administration 100 S, Independence Mall West Philadelphia, PA 19106

Submitted by

AECOM

30 Knightsbridge Road, Suite 520 Piscataway, New Jersey 08854 August 2016

Remedial Action Work Plan for the North Parcel of the Former Belle Mead Army Depot, Hillsborough, New Jersey

SRP-ID No. 013003/ LSR No. 120002

AECOM Remedial Action Work Plan – North Parcel BMAD i

August 2016

1 Introduction ................................................................................................................................................................. 1-1

1.1 Remedial Action Goals and Objectives .................................................................................................................. 1-1

1.2 Variance and Deviations ....................................................................................................................................... 1-2

1.2.1 Variances ..................................................................................................................................................... 1-2

1.2.2 Deviations .................................................................................................................................................... 1-3

1.3 Regulatory Timeframes......................................................................................................................................... 1-3

2 Background ................................................................................................................................................................. 2-1

2.1 Operational History ............................................................................................................................................... 2-1

2.2 Site Ownership and Re-use Status ........................................................................................................................ 2-1

3 Summary of Remedial Investigation Activities ........................................................................................................... 3-1

3.1 Summary of Areas of Concern .............................................................................................................................. 3-2

3.1.1 Remediation Standards ................................................................................................................................ 3-2

3.1.2 AOC 1-1 Rail Yard......................................................................................................................................... 3-4

3.1.3 AOC 9 Geophysical Area #1 ......................................................................................................................... 3-6

3.1.4 AOC 10-2 Former Bermed Area (Former Pistol Range) .................................................................................. 3-6

3.1.5 AOC 15 Incinerator Area and Burn Pit ........................................................................................................... 3-6

3.1.6 AOC 17 Former Jerry Can Area .................................................................................................................... 3-7

4 Physical Setting ........................................................................................................................................................... 4-1

4.1 Site Description .................................................................................................................................................... 4-1

4.2 Topography .......................................................................................................................................................... 4-1

4.3 Soils ..................................................................................................................................................................... 4-1

4.4 Geology ................................................................................................................................................................ 4-2

4.5 Hydrogeology ....................................................................................................................................................... 4-2

4.6 Hydrology ............................................................................................................................................................. 4-3

4.7 Wetlands .............................................................................................................................................................. 4-3

5 Remedial Action Selection .......................................................................................................................................... 5-1

5.1 Proposed Remedial Action.................................................................................................................................... 5-1

5.2 Protectiveness of Remedial Alternative................................................................................................................. 5-2

6 Remedial Action Work Plan ......................................................................................................................................... 6-3

6.1 Description of Remedial Action ............................................................................................................................. 6-3

6.2 Pre-Remedial Activities ......................................................................................................................................... 6-4

6.2.1 Permits & Certifications ................................................................................................................................ 6-4

6.2.2 Site Access .................................................................................................................................................. 6-4

6.2.3 Pre-Construction Surveys ............................................................................................................................ 6-4

6.2.4 Mark-out ...................................................................................................................................................... 6-5

6.3 Remedial Action.................................................................................................................................................... 6-5

6.3.1 Site Controls ................................................................................................................................................ 6-5

6.3.1.1 Security & Safety ..................................................................................................................................... 6-5

6.3.1.2 Air Monitoring Procedures ....................................................................................................................... 6-5

6.3.1.3 Dust Control Procedures ......................................................................................................................... 6-6

6.3.1.4 Odor Control Procedures ......................................................................................................................... 6-6

6.3.1.5 Noise Control Procedures ......................................................................................................................... 6-6

6.3.1.6 Health and Safety Plan ............................................................................................................................. 6-6

Table of Contents

AECOM Remedial Action Work Plan – North Parcel BMAD ii

6.3.1.7 Quality Assurance Project Plan ................................................................................................................ 6-7

6.3.2 Clearing ....................................................................................................................................................... 6-7

6.3.3 Excavation ................................................................................................................................................... 6-7

6.3.4 Confirmation Sampling for Soil Excavations ................................................................................................. 6-7

6.3.4.1 Sampling Frequency ................................................................................................................................. 6-7

6.3.4.2 Sample Collection and Analysis ................................................................................................................ 6-8

6.3.5 Backfilling .................................................................................................................................................... 6-9

6.4 Post-Remedial Monitoring Plan ............................................................................................................................. 6-9

6.5 Soil Management and Fill Use Plan ...................................................................................................................... 6-10

6.5.1 On-Site Fill Source ..................................................................................................................................... 6-10

6.5.2 On-Site Fill Tracking ................................................................................................................................... 6-10

6.5.3 Clean Fill .................................................................................................................................................... 6-10

6.6 Site Restoration Plan .......................................................................................................................................... 6-10

6.7 Remedial Schedule ............................................................................................................................................. 6-11

7 Post-Remediation Closure Reporting ......................................................................................................................... 7-1 8 References .................................................................................................................................................................. 8-1

AECOM Remedial Action Work Plan – North Parcel BMAD iii

List of Appendices Appendix A Remedial Investigation Report –North Parcel of the Belle Mead Army Depot Appendix B Pre-Design Investigation Report Appendix C Impact to Groundwater Study Memorandum Appendix D Bid Specification and Remediation Construction Design Drawings (Submitted Separately) Appendix E Permits Appendix F Air Monitoring Plan Appendix G Health and Safety Plan Appendix H Quality Assurance Plan

List of Figures Figure 1 Site Location Map Figure 2 Site Plan and AOCs Figure 3 AOC 1-1 Sampling Results Map, Polycyclic Aromatic Hydrocarbons Figure 4 AOC 1-1 Sampling Results Map, Arsenic Figure 5 AOC 1-1 Sampling Results Map, Eastern Property Boundary at Northwest Corridor Area Figure 6 AOC 1-1 Sampling Results Map, Eastern Property Boundary Figure 7 AOC 1-1 Sampling Results Map, Southeast Property Boundary Figure 8 AOC 9 Sampling Results Map, Geophysical Area 1 Figure 9 AOC 10-2 Former Pistol Range, Sampling Results Map Lead Figure 10 AOC 10-2 Former Pistol Range, Sampling Results Map PAHs and Arsenic Figure 11 AOC15 - Burn Pit Area, Sampling Results Map PAHs and EPHs Figure 12 AOC15 - Burn Pit Area Sampling Results Map Metals (except Arsenic) Figure 13 AOC15 - Burn Pit Area, Sampling Results Map Tables (PAHs, EPHs and Metals) Figure 14 AOC 17 – Jerry Can Area, Sampling Results Map Figure 15 Soil Classification Figure 16 Surficial Geology Figure 17 Primary Geologic Formations Figure 18 Summary of Site Proposed Remediation Figure 19 Post Excavation Sample Grid Areas

List of Tables Table 1- Variances ............................................................................................................................................................ 1-2 Table 2 - Deviations ........................................................................................................................................................... 1-3 Table 3 - Soil Remediation Standards ................................................................................................................................ 3-3 Table 4 - Sediment Remediation Standards ........................................................................................................................ 3-4 Table 5 - Permit Status ...................................................................................................................................................... 6-4 Table 6 - Site Specific Alert and Action Levels .................................................................................................................... 6-6 Table 7 – Minimum Soil Analysis ........................................................................................................................................ 6-9

AECOM Remedial Action Work Plan – North Parcel BMAD iv

List of Acronyms

AOC Area of Concern ARS Alternative Remediation Standard BMAD Belle Mead Army Depot COC Concaminanats of Concern EPH Extractable Petroleum Hydrocarbon FS Feasibility Study GSA U.S. General Services Administration HASP Health and Safety Plan HPLLC Hillsborough Properties, LLC IGWSSL Impact to Groundwater Soil Screening Levels IRM Interim Remedial Measure IRMWP Interim Remedial Measures Work Plan LSRP Licensed Site Remediation Professional mg/kg Milligrams per kilogram MOU Memorandum of Understanding NJ New Jersey N.J.A.C. New Jersey Administrative Code NJDEP New Jersey Department of Environmental Protection NRDCSRS Non-Residential Direct Contact Soil Remediation Standard PAH Polycyclic Aromatic Hydrocarbon PCE Tetrachloroethylene PDI Pre-Remedial Design Investigation PM10 Particulate Matter with a diameter of 10 micrometers or less QAPP Quality Assurance Project Plan RA Remedial Action RAP Remedial Action Permit RAR Remedial Action Report RAWP Remedial Action Work Plan RCRA Resource Conservation Recovery Act RDCSRS Residential Direct Contact Soil Remediation Standard RI Remedial Investigation RIR Remedial Investigation Report SCIA Somerset Couty Improvement Authority SESCP Soil Erosion and Sediment Control Plan SI Site Investigation SPLP Synthetic Precipiation Leaching Procedure SRRA Site Remediation Reform Act SRS Soil Remediation Standard µg/m3 micrograms per meter cubed USEPA United States Environmental Protection Agency USGS United States Geological Survey

AECOM Remedial Action Work Plan – North Parcel BMAD 1-1

On behalf of the United States General Services Administration (GSA), AECOM has prepared this Remedial Action Work Plan (RAWP) for a portion of the former Belle Mead Army Depot (BMAD) known as the North Parcel (North Parcel BMAD)1. The former BMAD consists of approximately 800 acres and has been divided into two main areas including the North Parcel BMAD and the South Parcel BMAD. The North Parcel BMAD is approximately 339 acres (SRP-ID No. 013003 / LSR No.

120002). The property is located in Hillsborough Township, Somerset County, New Jersey (NJ). Please refer to Figure 1 for a regional site location map.

Remedial activities at the North Parcel BMAD are being conducted to address the NJ Site Remediation Reform Act (N.J.S.A.58:10C; SRRA), the NJ Technical Requirements for Site Remediation ( N.J.A.C.7:26E), and the professional judgment of the Licensed Site Remediation Professional (LSRP). Remedial activities conducted have included Site Investigations (SI), Remedial Investigations (RI), a Feasibility Study (FS), and a Pre-Design Investigation (PDI), which have identified environmental media (including soil and sediment) at the North Parcel BMAD requiring a remedial action.

This RAWP has been prepared to describe the strategy for the remedial action at the North Parcel BMAD. A separate remedial action was completed at six residential properties adjacent to the eastern property boundary of the North Parcel BMAD; this action is discussed in a separate RAWP that was submitted in November 2015. A description of the RIs conducted to delineate the affected environmental media at the North Parcel BMAD is provided in the AECOM 2015 Remedial Investigation Report (RIR) (Appendix A) and AECOM 2015 PDI (Appendix B).

1.1 Remedial Action Goals and Objectives

The goal of the remedial action is to remediate soil and sediment at the North Parcel BMAD for constituent concentrations exceeding:

· NJ Department of Environmental Protection (NJDEP) Remediation Standards (N.J.A.C.7:26D) including the Residential and Non-Residential Direct Contact Soil Remediation Standards (RDCSRS and NRDCSRS);

· the NJDEP Default Impact to Groundwater Soil Screening Levels (IGWSSL);

· site-specific Impact to Groundwater Soil Remediation Standards (IGWSRS); and/or,

· site-specific risk based ecological remediation standards.

Soil and sediment exhibiting constituent concentrations in excess of applicable standards will be excavated and either disposed offsite or placed in an onsite Consolidation Area under a protective engineering cap with an institutional control.

Further discussion of the specific remediation standards for each compound is discussed in Section 3.1.1.

1 Previous documents refer to the North Parcel and Outlying Parcels which is now being referred to as the Northwest Corridor.

The Northwest Corridor is part of the North Parcel section of the BMAD; as such this North Parcel RAWP addresses the North Parcel and the Northwest Corridor.

1 Introduction

AECOM Remedial Action Work Plan – North Parcel BMAD 1-2

1.2 Variance and Deviations

As part of this RAWP variance to NJDEP regulations and deviations to guidance documents have been submitted. These variances and deviations are listed in the sections below.

1.2.1 Variances

The following variances will be utilized as part of the RAWP:

Table 1- Variances Regulatory Citation Variance Rational

N.J.A.C.7:26D-4.2 Alternative Remediation Standard (ARS) for Vanadium

The ARS for vanadium utilized the new USEPA reference dose for vanadium which was updated from 0.001 to 0.005 mg/kg-day. As a result the RDSRS for vanadium changed from 78 milligrams per kilogram (mg/kg) to 390 mg/kg.

N.J.A.C. 7:26E-5.C

Like-on-Like and 75th Percentile calculations are not required as described in Section 6.5 of the

RAW.

This variance is based on the NJDEP 2015 Fill Material Guidance for SRP Sites, which notes that the NJDEP will allow exceptions to the Like-on-Like and 75th Percentile Requirements if:

· A clean area or clean areas meet both the residential and impact to groundwater soil remediation standards are created or enlarged

· Areas of concern with the same contaminants can be consolidated as long as the overall areal extent of the contaminants is decreased.

For the proposed remedial action at the site, clean areas will be created based on the excavations and the overall extent of the contaminants on site will be decreased.

Additional detail is described in Section 6.5.

AECOM Remedial Action Work Plan – North Parcel BMAD 1-3

1.2.2 Deviations

The following deviations will be utilized as part of the RAW

Table 2 - Deviations Regulatory Guidance Deviations Rational

NJDEP Technical Guidance for SI of Soil, RI of Soil, and Remedial Action Verification Sampling of Soil Section 6.3.2 requirement of post excavation samples to be collected every 30 feet for sidewall samples and 900 square feet for base samples.

Post-excavation sampling frequency will be reduced from the guidance document as discussed in Section 6.3.4.

Approximately 400,000 square feet of soil will be excavated as part of the proposed remediation. Due to the size of the remedial activities a decrease in sampling frequency can be implemented without greatly impacting the effectiveness of the remediation. Additionally in sensitive areas and along the perimeter of the site post excavation sample frequency will be increased to be consistent with NJDEP Technical guidance.

NJDEP Technical Guidance for SI of Soil, RI of Soil, and Remedial Action Verification Sampling of Soil Section 6.3.1 requirement of post excavation samples to be collected from the top and bottom of each sidewall

One sidewall sample will be collected per side of each excavation grid

Due to the shallow nature of contamination at the site (generally less than one foot below ground surface) and overall extent of excavation, one sidewall sample is sufficient in demonstrating compliance to remediation standards.

Development of site-specific Impact to Groundwater Soil Remediation Standards Using SPLP – Section II

Three samples are required per AOC for SPLP analysis. Only one mercury SPLP analysis was used in determining IGWSRS

Only one mercury SPLP sample was used for determining the IGWSRS due to multiple samples for mercury SPLP not being detected. With the relatively small size of the mercury above the default IGWSSL and the non-detect analytical results the developed IGWSRS is protective of the groundwater in the vicinity of the samples.

Ecological Screening Criteria

ARS have been developed to replace the NJDEP Ecological Screening Criteria for Freshwater Sediment

An evaluation of the Ecological Screening Criteria was conducted and included as part of the 2015 RIR. The evaluations looked into background conditions and potential ecological impacts and determined new remediation goals for PAHs and select metals. An updated ARS form has been included with this RAWP with the ecological criteria for fresh water sediment.

1.3 Regulatory Timeframes

The North Parcel BMAD is subject to the RI Statutory Timeframe Established by SRRA N.J.A.C. 58:10C-27a(3). The RIR for the North Parcel BMAD was initially due for submittal May 7, 2014, a date which was extended to May 7, 2016. The RIR for the North Parcel BMAD was submitted to the NJDEP on November 6, 2015, ahead of the May 7, 2016 deadline. Based on NJDEP’s Summary of Regulatory and Mandatory Timeframes for Remediation, the May 7, 2019 Remedial Action Statutory Deadline applies for the completion and submittal of a Remedial Action Report for the site.

AECOM Remedial Action Work Plan – North Parcel BMAD 2-1

2.1 Operational History

The former BMAD, originally known as the Bound Brook Defense Aid Depot, was assembled from the purchase or condemnation of 30 properties previously used for agricultural purposes. Construction of the BMAD began on April 28, 1942, and the BMAD was activated on August 10, 1942. The BMAD was operated by the US Army Supply Services Network from 1942 through 1958. GSA operated on the BMAD from 1958 to 1991. The majority of the structures on the BMAD were removed and demolished during the 1960’s, and the BMAD was permanently closed in 1991.

The BMAD included barracks, storage warehouses and sheds, railroad sidings, pistol ranges, petroleum storage tanks, a gasoline decanting facility, open air storage, and a wastewater treatment plant. The BMAD contained more than 19 miles of roads and approximately 44 miles of railroad tracks. Storage space included over 2.1 million square feet of enclosed storage space and over 8 million square feet of open storage space, which was used for the storage of various commodities. Materials previously stored by GSA included paper products, batteries, paint, petroleum products, propane, pesticides, solvents, strategic metals, and metal ores. With the exception of two reported pistol ranges, there is no history of ordnance being stored or used onsite. Beginning in 1951, ore and other strategic materials were stored in the rail yard area and in enclosed warehouses. The stockpiled materials in bulk included ferromanganese, ferro-chromium, manganese and chromite ores, and processed ferro-chromium. In 1962 and 1963, GSA demolished 57 of the 192 structures at the facility, including most of the former cantonment area (i.e., barracks). Since then, most of the remaining surplus or unusable buildings have been removed.

The northernmost part of the former BMAD (approximately 70-acres) was donated to Hillsborough Township in 1986 and is now the Ann Van Middlesworth Park. A portion of the northeast corner of that property was transferred to Somerset County, and has been used as a police pistol range, which does not appear to be in use at this time. In early 2009, ownership of 369 acres of the southern portion of the Depot was transferred from GSA to the Somerset County Improvement Authority (SCIA) for development of open space and park.

The remaining 339-acre tract of land in the central portion of the BMAD (the subject of this report) contained a salvage yard, burn pit, flammable material storage sheds, a pistol range, jerry can storage area, and cosmoline coating areas as well as a water tower. Structures (now mostly demolished) associated with these areas included former buildings, concrete pad foundations asphalt paved roads, and approximately 10-miles of railroad bedding that formerly contained railroad tracks. A strip of land extending from the northwest corner of the property to the nearby Conrail right-of-way is identified as the “outlying parcels” or “outparcels”. The Northwest Corridor was formerly used to connect the main portion of the BMAD to a main railroad line. These parcels are bisected by portion of Royce Brook and its tributaries as well as two major roadways.

Other than rail access, no BMAD-related operations are known to have been conducted in the Northwest Corridor. The majority of the structures were removed and demolished during the 1960’s, and the BMAD was permanently closed in 1991 and has remained vacant since.

2.2 Site Ownership and Re-use Status

As the result of several transactions, GSA no longer owns the property that was formerly the BMAD. In 1986, GSA transferred title to the northernmost approximately 70-acre portion of the BMAD (Block 175.06, Lot 1.01) to Hillsborough Township, which developed that parcel into Ann Van Middlesworth Park. In 2009, GSA sold the southern approximately 369 acres (Block 175, Lots 39.01 and 39.03; Block 177, Lots 23.01, 23.02, and 23.04) to the SCIA, which accepted responsibility to conduct cleanup affected media on that parcel while it was being redeveloped into a county park. The remaining 339-acre northern portion of the former BMAD (Block 175, Lot 39.02, Block 175.18, Lot 39.04, Block 177, Lot 23.02, and Block 12, Lot 13, “the North Parcel BMAD”) was sold to a private developer on April 10, 1987, and through several transactions, the property was purchased at auction in 2003 by Hillsborough Properties, LLC (HPLLC).

2 Background

AECOM Remedial Action Work Plan – North Parcel BMAD 3-1

In 1988, GSA began conducting environmental investigations of the BMAD to assess the potential environmental concerns at the site. Investigations were focused on the southern and northern parcels of the BMAD, excluding the Ann Van Middlesworth Park. Prior investigations include: a preliminary investigation of soils, sediment and surface water within the Depot and at offsite locations (SEC, 1993); an analysis of potential responsible parties and identification of Areas of Concern (AOCs) (Woodward-Clyde, 1994); SI of soil and groundwater (Rust, 1994); investigations relating to underground storage tanks on the southern portion of the former BMAD (GTS, 1998) and aboveground storage tanks (AAC, 1997). These reports identified several areas of potential environmental concern. The reports ultimately recommended additional soil sampling and analysis to delineate areas where concentrations of regulated compounds exceeded NJDEP Remediation Standards.

In 2000, GSA entered into a Memorandum of Understanding (MOU) with the NJDEP that defined GSA’s cleanup obligations for the BMAD. The transfer of the South Parcel BMAD in 2009 moved the remaining cleanup obligations for that parcel from GSA to the SCIA, leaving the environmental obligations related to the HPLLC-owned parcel (i.e., the North Parcel BMAD) remaining.

Subsequent to executing the MOU, AECOM (formerly ENSR) conducted soil, groundwater, and ecological investigations at the North Parcel BMAD between October 2000 and October 2005. These investigations focused on soil and groundwater and included ecological evaluations of nearby Royce Brook. These investigations identified the following:

· The soils investigations conducted during these studies show exceedances of the NJDEP soil standards for metals and polycyclic aromatic hydrocarbons (PAHs) that appeared to be distributed across most of the site, and extend to the vicinity of property lines.

· The ecological evaluation determined that potential for ecological risk due to site-related constituents could not be eliminated, and that further investigation was warranted to better characterize the extent of potential contamination associated with contaminant migration from the site in the vicinity of the Burn Pit Area.

· Groundwater investigations recommended further groundwater studies to determine if the presence of metals in groundwater is related to background conditions and/or facility operations.

In 2009, New Jersey passed the SRRA, N.J.S.A.58:10C, establishing a new paradigm for site cleanup, moving oversight from the responsibility of the NJDEP to individual LSRPs. To comply with SRRA regulations, GSA contracted AECOM in 2011 to complete the necessary investigations and reporting requirements as required under the SRRA program. These investigations were built upon prior investigations and provided the supplemental information necessary to complete GSA’s obligations under the SRRA. AECOM has been conducting investigations on the North Parcel BMAD since this time (Appendix A) (AECOM, 2015a).

Based on the results of the pre-2005 RIs, the NJDEP required “hot spot” remediation within the Royce Brook Tributary A, as well as “hot spot” source remediation within the Burn Pit area (a part of the Incinerator Area AOC). Thus, in October 2009, AECOM submitted a RI Work Plan to NJDEP that proposed additional soil and ecological sampling for PAH and metals to assess potential migration of these constituents to surface water or across the Burn Pit Area to the Royce Brook Tributary A. NJDEP conveyed their approval of this plan in September 2010, and the investigation was completed between 2010 and early 2011.

Analytical data from this investigation failed to clearly identify a “hot spot;” however, the few samples collected near a visibly black, unvegetated area at the location of the burn pit show the greatest concentrations of PAHs, with evidence of off-site migration of this material. Thus, this area was defined as the “hot spot.”

3 Summary of Remedial Investigation Activities

AECOM Remedial Action Work Plan – North Parcel BMAD 3-2

NJDEP concurred with this finding, and directed GSA to prepare and submit an Interim Remedial Measures Work Plan (IRMWP) for the Burn Pit area to mitigate offsite migration of PAHs into to the adjacent Royce Brook Tributary A. An IRMWP for the Burn Pit area was submitted to NJDEP as part of a Technical Memorandum dated October 14, 2011. NJDEP issued their approval of the Technical Memorandum in a letter dated January 10, 2012.

Subsequently, Interim Remedial Measures (IRMs) were implemented at the former Burn Pit Area in September 2013. These measures consisted of placing a 6-inch thick stone cap on the ground surface, erecting stone sediment barriers within selected drainage ditches, and installing silt fences around the three sides of the Burn Pit where drainage could cross. Silt fence was also installed along portions of the northern and eastern boundary of the edges of the larger (encompassing) Incinerator Area (AOC 15). These measures were completed to address direct contact and potential migration concerns.

The IRMs are being inspected and maintained until the final remedy, which will be implemented under this RAWP.

During the IRM, one sample of tar-like material observed in the vicinity of the Burn Pit Area in AOC 15 was collected and was submitted to a laboratory for petroleum fingerprinting analysis. The forensic report provided by the laboratory indicated that sample exhibiting a coal tar like substance based on its mid to heavy molecular weight range in a chromatogram. This pattern is indicative of Coal Tar/Creosote. Total petroleum hydrocarbon results indicate the presence of a significant concentration of petroleum hydrocarbon.

AECOM conducted a PDI (AECOM, 2015b) to aid in the design of the remedial action for affected environmental media (soil and sediment) present within the North Parcel BMAD. The PDI provided supplemental information to support the decision-making required for design of remedial action for the North Parcel BMAD.

The data compiled and interim remedial actions documented within the AECOM 2015 RIR and the AECOM 2015 PDI were used as the basis for this RAWP.

3.1 Summary of Areas of Concern

As presented in numerous previous reports, AECOM has conducted extensive soil investigations at North Parcel BMAD.

The results of these investigative activities indicate evidence of soil constituents at concentrations in excess of the NJDEP RDCSRS and IGWSSL. The investigations on the North Parcel BMAD are summarized in the 2015 RIR (Appendix A), which documents the presence of five contaminated AOCs:

· AOC 1-1 Railyard;

· AOC 9 Geophysical Area #1;

· AOC10-2 Pistol Range;

· AOC 15 Incinerator Area and Burn Pit; and,

· AOC 17 Jerry Can Area.

Locations of these AOCs are shown on Figure 2.

3.1.1 Remediation Standards

The tables below identify the contaminants of concern and applicable remedial standards for each area of concern. Table 3 shows the soil remediation standards and Table 4 shows the sediment remediation standards that will apply only within the stream channels to be remediated. The soil remediation standards are based on the RCSRS, NRDCSRS, and the site-specific IGWSRS. The site-specific IGWSRS results are discussed in greater detail in Appendix C.

AECOM Remedial Action Work Plan – North Parcel BMAD 3-3

Table 3 - Soil Remediation Standards

Compound RDCSRS NRDCSRS Site-Specific

IGWSRS

Remediation Standard Applied to RAWP

Associated AOC

PAHs benzo(a)anthracene 0.6 2 0.8 D 0.6 AOC 1-1 and AOC 15 benzo(a)pyrene 0.2 0.2 0.2 D 0.2 AOC 1-1 and AOC 15 benzo(b)fluoranthene 0.6 2 2 D 0.6 AOC 1-1 and AOC 15 benzo(k)fluoranthene 6 23 25 D 6 AOC 1-1 and AOC 15 chrysene 62 230 80 D 62 AOC 1-1 and AOC 15 dibenzo(a,h)anthracene 0.2 0.2 0.8 D 0.2 AOC 1-1 and AOC 15 indeno(1,2,3-cd)pyrene 0.6 2 7 D 0.6 AOC 1-1 and AOC 15 pyrene 1,700 18,000 840 D 840 AOC 1-1 and AOC 15

Naphthalene* 6 17 25 D 6 AOC 1-1

Pesticide

4,4-DDT 2 8 11 D 2 AOC 9

Metals arsenic 19 19 91.5 19 AOC 1-1 lead 400 800 90 D 90 AOC 9, AOC 15, and AOC 17 mercury 23 65 0.4 0.4 AOC 1-1 and AOC 9 selenium* 390 5,700 11 D 11 AOC 15

Volatile Organic Compounds tetrachloroethylene (PCE) 2 5 0.005 D 0.005 AOC 9

EPH

EPH 5,100 54,000 NA 5,100 AOC 15

Notes:

1. All values are reported in mg/kg.

2. Site-specific IGWSRS values are based on IGW memo findings. Those with a superscript “D” are NJDEP default impact to groundwater screening levels.

3. * Spot excavation areas. Does not apply to entire AOC.

4. ** ARS submitted in the 2015 RIR.

5. Bolder results are bases for RAWP Specific Cleanup Goal.

6. NA – Non applicable

AECOM Remedial Action Work Plan – North Parcel BMAD 3-4

Table 4 - Sediment Remediation Standards

Detected Analyte Sediment ESC (a) Draft PRGs (b)

SBRRT RB RBT

LEL SEL Benthic

Invertebrates Wildlife

PAHs 2-methylnaphthalene 0.0202 NV 0.0202 NC X X acenaphthene 0.00671 NV 0.00671 NC X X Acenaphthylene 0.00587 NV 0.00587 NC X X X anthracene 0.0572 370 4.6 NC X benzo(a)anthracene 0.0108 1,480 4.0 NC X X X benzo(a)pyrene 0.15 1,440 15 NC X X X benzo(b)fluoranthene 10.4 NV 10.4 NC X benzo(g,h,i)perylene 0.17 320 7.4 NC X benzo(k)fluoranthene 0.24 1,340 18 NC X X X chrysene 0.166 460 8.7 NC X X dibenzo(a,h)anthracene 0.033 130 2.1 NC X X X fluoranthene 0.423 1,020 21 NC X fluorene 0.0774 160 3.5 NC X X indeno(1,2,3-cd)pyrene 0.2 320 8.0 NC X X X naphthalene 0.176 NV 0.176 NC X phenanthrene 0.204 950 14 NC X X pyrene 0.195 850 13 NC X X

Metals arsenic 6 33 14 14 X X X barium 0.7 NV 0.7 NC X X chromium 26 110 53 NC X X copper 16 110 42 28 X iron 20,000 NV 20,000 NC X X lead 31 250 88 139 X X X manganese 630 1,100 832 NC X X nickel 16 75 35 17 X X vanadium 57 NV 57 NC X zinc 120 820 314 NC X X

Notes:

1. All values are reported in mg/kg.

2. Bold results are bases for applied sediment remediation standard for this RAWP.

3. SBRRT - South Branch Raritan River Tributary at Northwest Corridor.

4. RB - Royce Brook and Royce Brook Tributary at Northwest Corridor.

5. RBT - Royce Brook Tributary Near OU15.

6. ESC - Ecological Screening Criteria.

7. LEL - Lowest Effects Level.

8. NC - Not calculated.

9. NV - No Value.

10. PRG - Preliminary Remediation Goals.

11. SEL - Severe Effects Level.

12. (a) LEL and SEL screening values obtained from NJDEP Ecological Screening Criteria (ESC) Table (March 2009). When multiple ESCs are provided for the same analyte the most conservative criterion is used.

13. (b) Draft PRG is geometric mean of LEL/SEL or NOAEL/LOAEL sediment concentration. When no SEL available, LEL used.

3.1.2 AOC 1-1 Rail Yard

Soil investigations completed for the RI across the North Parcel BMAD and at select offsite properties has shown the presence of PAH and arsenic in surface soil (no deeper than about 1 foot), and the extent of the presence of PAH and arsenic in soil at concentrations greater than NJDEP RDCSRS is limited to areas near railroad beds, roads, former buildings, and debris piles, as well as in areas where storm water collected from these areas is channeled and discharged. Soil analytical data from AOC 1-1 support the conceptual model that soil affected by PAHs and arsenic is limited to the surface

AECOM Remedial Action Work Plan – North Parcel BMAD 3-5 soil and area related to surficial deposition from coal-burning locomotives and other vehicles as well as application of arsenical pesticides to control rodents along boundaries and access ways (i.e., rails and roads). Delineation of these affected soils extend approximately 230 acres, where former roads and railways were present at the site. Based on depth and extent of the delineation, approximately 400,000 square feet of soil is affected within AOC 1-1 and will be addressed as part of this RAWP.

Specifically, soil sampling conducted on the Northwest Corridor and several adjacent offsite properties to delineate the extent of PAH- and arsenic-affected soil show:

· PAHs and arsenic are present in onsite soil (i.e., within the boundaries of the Northwest Corridor at concentrations above the RDCSRS, and, where these onsite exceedances occur, the samples are located in the vicinity of the former railbed and immediate vicinity (Figures 3 and 4).

· The extent of PAHs and arsenic-affected soil in the Northwest Corridor (i.e., where concentrations of PAH and/or arsenic exceed the RDCSRS) has been delineated, and, with one exception, is limited to the North Parcel BMAD property boundary (Figures 3 and 4).

· Figure 5 depicts the soil sampling results for one area of the Northwest Corridor (near offsite Block 12- Lot 16.03), where PAH affected soil has been delineated offsite. This soil was likely affected from runoff from the railway and potentially from an offsite road drainage source near Lot 37, which is collecting in a wetland area adjacent to the rail bed. Topography of this area includes a low-lying area generally consistent with the presence of a wetland with areas outside of this wetland at higher elevations. Thus, the conceptual model is that soil affected by North Parcel BMAD-related activities would be limited to this low-lying area along the former railroads.

Surface soil sampling conducted on properties located offsite (to the east) and immediately adjacent the North Parcel BMAD provides delineation of PAHs and arsenic affected soil (see Figure 6):

· PAH and arsenic concentrations in soil are below the RDCSRS on adjacent properties located in the northern portion of the residential development, which was developed in the 1990s.

· PAH and arsenic concentrations in soil are above the RDCSRS for six properties located in the southern portion of the residential development, which was developed in the 1970s. Exceedances of the RDCSRS are generally confined to within 30 feet of the BMAD boundary with one exception at Lot 38, where the area extends to approximately 60 feet of the BMAD boundary.

Surface soil sampling conducted in the southeast corner of the North Parcel BMAD provides delineation of the horizontal and vertical extent of PAH- and arsenic-affected soil (see Figure 7):

· Observed PAH and arsenic concentrations above RDCSRS at offsite Block 179 -Lot 34.06 are not related to the

BMAD.

· PAH- and arsenic-affected soil observed in the eastern portion of this area (i.e., at the boundary of the BMAD and Block 177Lot 24.11) are considered delineated to the eastern property boundary.

· Based on the compiled data for arsenic and PAHs across the remaining North Parcel BMAD and within AOC 1-1, the following conclusions can be made: Approximately 90 acres to the west of AOC 15 can be excluded from this remedial action because COCs are not present at concentrations above the applied Remediation Standards described in Section 3.1.1.

· Approximately 20 acres in the Northwest Corridor can be excluded from this remedial action because COCs are not present at concentrations above the applied Remediation Standards described in Section 3.1.1.

· The presence of PAH and arsenic at concentrations above the applied Remediation Standards described in Section 3.1.1 has been delineated within the remaining area of the site, in the vicinity of the former rail and road beds (i.e., AOC 1-1).

· Vertically, these COCs appear limited to the top one foot of soil in AOC 1-1.

· Horizontally, these COCs are delineated; these COCs are present on the former North Parcel BMAD and on several offsite properties at concentrations exceeding the applied Remediation Standards described in Section 3.1.1.

AECOM Remedial Action Work Plan – North Parcel BMAD 3-6

· The presence of PAH and arsenic at six off-site residential properties (located adjacent to the eastern property boundary of the North Parcel BMAD) is addressed in a separate RAWP, the Offsite Residential RAWP, 2015. The excavated soil from the six residential properties is staged on the North Parcel for inclusion into the consolidation pile.

3.1.3 AOC 9 Geophysical Area #1

AOC 9 is a raised mound on the west portion of the site that was investigated for the potential to contain buried drums or other debris. Analytical results from the RI for AOC 9 provide delineation of lead, 4,4’-DDT, and mercury concentrations in excess of the applied Remediation Standards described in Section 3.1.1 at this AOC (Figure 8). The area of delineation is approximately 22,000 square feet. However, the area of debris is closer to one-acre in size. Boring logs identify debris to approximately four feet, suggesting that this area was raised from surrounding grade by the dumping of debris and soil from other areas of the site. A total of 65,000 cubic yards of mixed debris and soil is estimated to be present at this AOC with confirmed concentrations of COCs in excess of applied Remediation Standards present in approximately 16,000 cubic yards of soil.

3.1.4 AOC 10-2 Former Bermed Area (Former Pistol Range)

The soil analytical data collected for this AOC confirm that lead is present in soil at this AOC at concentration above the applied Remediation Standards described in Section 3.1.1 and the presence of lead-affected soil is limited to a relatively shallow portion of the front-facing side of the berm (Figure 9). This affected area is linked to the area where bullets from historic use as a firing range are present. Lead-affected soil associated with the presence of bullets has been shown to be a RCRA hazardous waste based on Toxicity Characteristic Leaching Procedure testing results, and extends to 2-feet into the berm resulting in a total volume of affected soil of approximately 3,400 cubic yards. It is estimated that approximately 47,000 bullets are present in the backstop.

Soil sampling data from the berm also confirms the presence of PAH in soil at concentrations exceeding applied Remediation Standards described in Section 3.1.1, indicating that the berm was likely constructed from onsite backfill material during BMAD’s operational years (Figure 10). Thus, berm material outside of bullet- and lead-affected soil should be addressed within the AOC 1-1 remedial action.

3.1.5 AOC 15 Incinerator Area and Burn Pit

Based on evaluation and review of RI sampling data available from AOC 15, the presence of PAH and metals in soil and drainage pathways (sediment) at concentrations above RDCSRS are delineated (Figures 4, 11 to 13). These media were likely affected as a result of incineration and open burning activities in the “burn pit” area, as well as a result of vehicle exhaust and degrading road surfaces. PAH-affected soil and sediment are fairly widespread throughout the AOC 15 area, while metals-affected soil appears to be more localized. The overall extent of AOC 15 is approximately 26 acres.

The “burn pit”, which is approximately 1.5 acres in size, is considered a “hot spot” due to the presence of a tar-like material believed to be a result of the open burning activities conducted in this area. The tar-like material contains PAHs and EPH at much greater concentrations than reported elsewhere onsite. This area provides an ongoing source of PAHs as weathering of hardened tar-like material may be transported in overland storm water flow as suspended solids. Transportation of the material has resulted in offsite migration of affected sediment to the Royce Brook Tributary A, located east of the site.

Concentrations of EPH in soil outside the burn pit area have been delineated to the applied Remediation Standards close to the burn pit indicating that EPH affected soils did not migrate or were attenuated quickly once removed from the source area. In 2013, an IRM was conducted at the burn pit, which consisted of applying a 6-inch thick stone cover across the burn pit, surrounding the area with silt fence, and installing three stone sediment traps in drainage ditches that discharge storm water from this area to the offsite Royce Brook Tributary A. The IRM was completed to prevent direct contact and reduce the potential for further migration of material from the source area.

The offsite area of PAH-affected soil is delineated (Figure 11):

· Along the eastern/northeastern boundary of AOC 15, it is believed that the weathering of the tar material facilitated migration of sediment in surface water runoff that transported PAH-affected soil/sediment in drainage ditches, which lead to wetlands and discharge locations where storm-water entered the Royce Brook Tributary A at the

AECOM Remedial Action Work Plan – North Parcel BMAD 3-7 northeast corner of the North Parcel BMAD. A portion of these drainage features and Royce Brook are included within the affected area.

· Along the northern boundary of AOC 15, surface runoff from the AOC appears to have affected a portion of the adjacent property owned by Somerset County.

Arsenic-affected soil at this AOC appears similar in nature to the arsenic-affected soil found in other areas of the site (Figure 4). Arsenic-affected soil was primarily in locations near former buildings and drainage features. Lead-affected soil was identified near the former building foundation in the northwest corner of the AOC, and in the vicinity of debris and drainage features. One manganese exceedance of the applied Remediation Standards was noted at a sample location within the low-lying area of AOC 15, which receives much of the surface runoff at this AOC.

The results of the Ecological Assessment reported in the RI indicated environmental affects in the Royce Brook tributary due to the migration of affected soil in AOC 15 via storm water runoff (Appendix A).

Based on the evaluation of soil samples in AOC 15, one sample location (PL05) contained concentrations of selenium in excess of the applied Remediation Standards.

3.1.6 AOC 17 Former Jerry Can Area

One soil sample location reported concentrations of lead at this AOC greater than the RDCSRS (Figure 14). However, based on the compiled analytical data for the lead in soil at AOC 17, it does not appear likely that this occurrence is related to former storage and decanting of gasoline in the Jerry Can Area but may be related to a debris pile noted in the vicinity of the affected soil samples.

AECOM Remedial Action Work Plan – North Parcel BMAD 4-1

4.1 Site Description

The North Parcel BMAD as defined by the property boundaries consists of 339acres of land across the central portions of the former BMAD, which is currently owned by HPLLC (Figure 1). The North Parcel BMAD formerly contained a salvage yard, burn pit, flammable material storage sheds, a pistol range, jerry can storage area, cosmoline area, housing for military personnel, and approximately 10-miles of railroad, which connected to nearby rail spurs at the northwestern and southeastern corners of the property.

Currently, the greater portion of the North Parcel BMAD is inactive and largely overgrown. A portion of the Ann Van Middlesworth Park extends onto the northern portion of the North Parcel BMAD. Abandoned structures including concrete foundations and slabs of former buildings, rail sidings comprised of track ballast and rail ties (steel rails had been removed), asphaltic and unimproved dirt/gravel roadways that have significantly degraded, and a former, inactive water tower remain.

The locations of previously demolished structures are generally identifiable from residual foundations. The remainder of the North Parcel BMAD is largely unpaved and wooded with scrub/shrub (primary and secondary succession) vegetation consisting of red cedar, scattered olive, hickory, oak, grasses, and miscellaneous shrubs.