Final Action Memorandum for November 2020 for Ou3 for the Mcguire Air Force Base #1 Site

Final Action Memorandum for McGuire – OU3 LF019 MEC TCRA

Joint Base McGuire-Dix- Lakehurst, New Jersey

November 2020

Department of the Army Tulsa District, Corps of Engineers

Final Action Memorandum

McGuire – OU3 LF019 MEC TCRA Joint Base McGuire-Dix-Lakehurst, New Jersey

Contract No. W912BV-19-C-0023

November 2020

Final Action Memorandum

McGuire-OU3 LF019 MEC TCRA Thomas Crone Project Manager Joint Base McGuire-Dix-

Lakehurst, New Jersey

Prepared for: Larry Fowler Department of the Army Deputy Project Manager Tulsa District, Corps of Engineers

Prepared by: Seres-Arcadis 8(a) JV, LLC Karan Holmes 498 Wando Park Blvd Suite 175 Senior Environmental Scientist Mount Pleasant, SC 29464 Our Ref.: Contract No. W912BV-19-C-0023 Arcadis Project: 30028498

Date: November 2020

This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this document is strictly prohibited.

Table of Contents

1. Purpose 1

2. Site Conditions and Background 2

2.1 Site Description 2

2.1.1 Physical Location 2

2.1.2 Background 2

2.2 Site Characteristics 3

2.2.1 Release or Threatened Release into the Environment of Hazardous Substance, or Pollutant, or Contaminant 3

2.2.2 National Priorities List Status 4

2.3 Other Actions to Date 4

2.3.1 Previous Actions and Investigations 4

2.3.2 Current Actions 5

2.4 State and Local Authorities’ Roles 5

3. Threats to Public Health, Welfare, or the Environment 6

4. Endangered Determination 7

5. Proposed Action and Estimated Costs 8

5.1 Proposed Action Description 8

5.1.1 Preparation 8

5.1.2 TCRA Field Activities 8

5.1.2.1 MEC Removal and Disposal 8

5.1.3 Waste Management and Disposal 9

5.1.4 MC Sampling Rationale and Analytical Methods/Data 10

5.2 Contribution to Remedial Performance 10

5.3 Applicable or Relevant or Appropriate Requirements 11

5.4 Project Schedule 12

5.5 Estimated Costs 13

6. Expected Change in the Situation Should Action be Delayed or Not Taken 14

Table of Contents

7. Outstanding Policy Issues 15

8. Authorizing Signature 16

9. References 17

Figures

Figure 2-1 JB MDL – McGuire Site Location

Figure 2-2 Site Location Map

Appendices

Appendix A ARARs and TBCs

Table of Contents

Acronyms and Abbreviations

ARAR applicable or relevant and appropriate requirements

cartridge cases 106 millimeter recoilless rifle cartridge cases

CERCLA Comprehensive Environmental Restoration, Compensation and Liability Act

EM United States Army Corps of Engineers’ Engineer Manual

EOD explosive ordnance disposal

EPA United States Environmental Protection Agency

ESS Explosive Safety Submission

FFA Federal Facility Agreement

ft feet or foot

IRP Installation Restoration Program

JB MDL Joint Base McGuire-Dix-Lakehurst

LF landfill

LUCIP Land Use Control Implementation Plan

MC munition constituents

MD munitions debris

MDAS materials documented as safe

MEC munitions and explosives of concern

mm millimeter

MPPEH Material Potentially Presenting an Explosive Hazard

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NJDEP New Jersey Department of Environmental Protection

OU Operable Unit

QASP Quality Assurance Surveillance Plan

SSFR Site Specific Final Report

iii

Table of Contents

SUXOS Senior Unexploded Ordnance Supervisor

TBC to be considered

TCRA Time-Critical Removal Action

U.S. United States

UFP-QAPP Uniform Federal Policy - Quality Assurance Project Plan

USACE United States Army Corps of Engineers

USAF United States Air Force

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

1. Purpose

The purpose of this Action Memorandum is to document the approval of a Time-Critical Removal Action (TCRA) described herein for a potential disposal area observed at Landfill (LF) 019 at McGuire Operable Unit (OU) 3, Joint Base McGuire-Dix-Lakehurst (JB MDL), McGuire, New Jersey. This TCRA will be conducted on behalf of the United States (U.S.) Air Force (USAF) by the U.S. Army Corps of Engineers (USACE). Work will be administered under the Installation Restoration Program (IRP) which follows 40 Code of Federal Regulations Part 300 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The U.S. Environmental Protection Agency (EPA) and the New Jersey Department of Environmental Protection (NJDEP) are supporting agencies as defined in the NCP, CERCLA, and the Federal Facility Agreement (FFA) for the McGuire Area of JB MDL.

This Action Memorandum outlines the measures needed to protect human health and the environment by removal of munitions and explosives of concern (MEC), material potentially presenting and explosive hazard (MPPEH) and munition constituents (MC) at LF019 located in the swale and landfill face (partially and fully buried).

This Action Memorandum was prepared under the Performance Based Contract Number W912BV-19-C-0023 in accordance with EPA Office of Solid Waste and Emergency Response and Superfund Removal Guidance for Preparing Action Memoranda (EPA 2009). This Action Memorandum is intended to be the decision document for the TCRA.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

2. Site Conditions and Background

2.1 Site Description

JB MDL is an active military facility located in Burlington and Ocean Counties in south- central New Jersey; about 18 miles southeast of Trenton (see Figure 2-1). The McGuire Area of JB MDL is comprised of approximately 3,600 acres of land consisting of open grassland, runways, aircraft facilities, building complexes and peripheral tracts of mixed hardwood and softwood forests. LF019 is located in the eastern portion of the McGuire Area.

2.1.1 Physical Location

LF019 is a 5.5-acre parcel of land located between the intersection of the former wastewater treatment plant access road (Station Road) along its southwest, South Run Road and a fairway of the JBMDL-McGuire golf course to its northwest, the South Run stream to its northeast, and an unnamed tributary to South Run to its southeast (Figure 2-2). The landfill is generally bisected by a drainage swale that conveys runoff from the road and surrounding area to South Run, separating the landfill into northeastern and southeastern lobes.

The landfill is relatively level with surface elevations ranging from 90 to 100 feet (ft) above mean sea level. The area where LF019 borders South Run is characterized by a steep 15 to 25 ft embankment descending sharply to the stream bank. The drainage swale, that bifurcates the landfill, wraps along the northern portion of the southeastern lobe of the landfill for several feet before separating from the landfill and discharging to South Run. A grass area separates the drainage swale and eastern foot of the landfill in the area of the discarded munition from the South Run Tributary.

2.1.2 Background

LF019 was operated as a landfill from approximately 1970 to 1973. Historical records indicate the landfill was primarily used for the disposal of coal ash, wood, and waste metal. Surface evidence suggests the landfill was also used for the disposal of construction debris, domestic waste, and spent artillery casings. The landfill was closed in 1973 and covered with native soil. Debris can be observed protruding through the surface in several locations throughout the landfill. Refuse generally consists of the following landfill material: concrete slabs, scrap metal, rusted and disintegrated 55-gallon drums and metal cans, slag, ash, automobile parts, domestic waste, and burnt wood. The base of the material is encountered about 8 to 12 ft below ground surface, resting on the former ground surface. About two feet of tan, fine to medium sand of the original

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

cap covers most of the western portion of the landfill. The original sandy soil cover supported abundant vegetation (grass, shrubs, and trees) until clear zone requirements necessitated removal of most trees and shrubs from LF019 in 2012.

MPPEH was identified at LF019 in a densely vegetated landfill face and drainage swale bifurcating the landfill during the December 2017 topographic survey to establish baseline topographic conditions of the landfill. The drainage swale is located between two lobes of the landfill and extends to a depth of approximately 10-feet below surrounding landfill grade. MPPEH has been observed along the landfill face which serves as the eastern drainage swale wall (i.e., closest to the runway landing lights) along with other metallic non-MPPEH debris. The MPPEH was identified as 106 millimeter (mm) recoilless rifle cartridge cases (here after referred to as “cartridge cases”) by the Senior Unexploded Ordnance Supervisor (SUXOS) embedded with the topographic survey team. The cartridge cases appear to have been dumped from the top of the landfill and are now partially buried from years of erosion on the landfill face. The SUXOS performed a cursory field inspection of the cartridge cases and determined they did not have attached projectiles and did not appear to be loaded with propellant. The SUXOS was not able to determine whether the cartridge primers and ignition (i.e., flash) tubes were expended based on the field inspection.

The JB MDL-McGuire explosive ordnance disposal (EOD) team responded to the discovery and removed 40 cartridge cases from the drainage swale and landfill face in December 2017. The removed items were transported by EOD to an active EOD range on JBMDL-Dix and destroyed. The EOD team reported that additional cartridge casings (approximately 200 casings) remain in the gully in the near surface and subsurface. EOD recommended that the site be turned over for remediation by a contractor.

2.2 Site Characteristics

2.2.1 Release or Threatened Release into the Environment of Hazardous Substance, or Pollutant, or Contaminant

The presence of potential MEC in the surface, and partially buried on the landfill face LF019 poses an immediate hazard to human health and safety if the munitions are detonated. An accidental encounter resulting in an unintentional detonation could result in a catastrophic (lethal) or critical (severe injury) to a receptor.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

2.2.2 National Priorities List Status

The EPA added McGuire (EPA identification: NJ0570024018) to the National Priorities List on 22 October 1999, due to the presence of several hazardous chemicals in soil, surface water, and groundwater. On 10 September 2009, the Department of the Air Force signed an FFA with the EPA Region 2 to ensure that the environmental impacts associated with past and present activities at McGuire, including OU3, are investigated and remediated, as necessary, to protect the public health, welfare, and the environment.

2.3 Other Actions to Date

2.3.1 Previous Actions and Investigations

The following previous remedial actions and investigations have been performed at LF019:

• Field Exploration Program (1991). Groundwater, surface water, sediments and soil were sampled for the full target compound list (TCL) of analytes. Cadmium was detected in groundwater; cadmium and lead were detected in some soil samples.

• Remedial Investigation Report (1998) and Final Remedial Investigation Report Addendum (2013). Compiled analytical data from previous investigations, performed a Baseline Ecological Evaluation.

• Draft Summary Report Groundwater, Sampling Round, Long Term Monitoring Program Report (multiple landfills) (2002). Summarized results of 2001 groundwater sampling.

• Final Time-Critical Removal Action Report Operable Unit-3 (2014). Described work performed included consolidating waste, grading and capping the southern portion of the southeastern landfill lobe located south of the runway lighting. Work included removing waste from a 330-foot length along South Run to create a 20-foot wide shelf between LF019 and South Run. This work was performed within 60 feet of the planned TCRA and no munitions were observed during this action.

• Erosion Maintenance Memo (2018). Described maintenance activities performed to repair erosion features along the eastern lobe and South Run at the landfill.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

• MPPEH Observations at LF019 During Pre-Design Investigation Baseline Topographic Survey (2018). Summarized the field activities performed during the LF019 site topographic survey and prior EOD removal action.

2.3.2 Current Actions

LF019 is currently used as open space at the perimeter of a runway and activities are limited to grounds maintenance (mowing operations). Intrusive activities within the area are controlled by the JB MDL Land Use Control Implementation Plan (LUCIP) which prohibits intrusive activities at the former landfill per the controls outlined in Section 3.0 of the LUCIP.

2.4 State and Local Authorities’ Roles

This TCRA will be conducted on behalf of the USAF as the lead agency at this site. The EPA is the lead regulatory agency pursuant to the McGuire FFA and NJDEP is the support regulatory agency. This Action Memorandum has been provided to the EPA and NJDEP for review and comment.

JB MDL holds quarterly Restoration Advisory Board meetings which include local community members and regulators to discuss progress and solicit community input on IRP projects.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

3. Threats to Public Health, Welfare, or the Environment

MEC is present on the surface and in the subsurface at LF019. The potential exists for interaction with MEC on the surface resulting from erosion exposing subsurface MEC. The potential risk of exposure to explosive items is a factor justifying undertaking a Removal Action pursuant to NCP Section 40 Code of Federal Regulations 300.415(b)(2)(vi).The area of the landfill where the cartridge cases are located is accessible by installation personnel, authorized contractors, and authorized site visitors (not trespassers); therefore, there is potential for interaction with potential MEC on the ground surface.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

4. Endangered Determination

Accidental exposure or contact to MEC could potentially result in a catastrophic event including loss of life, significant injury and/or property damage. MEC, if not addressed by implementing the response action selected in this Action Memorandum, presents an endangerment to the health or welfare of current and future commercial/industrial workers and site visitors. Response actions provided in this Action Memorandum are required to identify, reduce, and manage the risk to current and future uses of this site.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

5. Proposed Action and Estimated Costs

5.1 Proposed Action Description

5.1.1 Preparation

Planning documents associated with this TCRA will be prepared including this Action Memorandum, Quality Assurance Surveillance Plan (QASP), Explosive Safety Submission (ESS) and a Uniform Federal Policy Quality Assurance Project Plan Uniform Plan (UFP-QAPP) addendum. Input from the project delivery team will be solicited through the Technical Project Planning process.

Public involvement will be coordinated in accordance with the 40 Code of Federal Regulations 300.820 and the JB MDL Community Relations Plan. The Administrative Record/Information Repository for McGuire Area is maintained at the Burlington County Library, 5 Pioneer Boulevard, Westampton, New Jersey and online at the following URL: https://ar.afcec-cloud.af.mil/. Information related to the TCRA will be available in the Administrative Record/Information Repository within 60 days of initiating on-site activities at LF019 and a public comment period of not less than thirty days from the time the Administrative Record file is available for public inspection pursuant to the NCP

5.1.2 TCRA Field Activities

TCRA field activities are segregated into three primary tasks. Each task is described in the following subsections.

5.1.2.1 MEC Removal and Disposal

Current and future uses of LF019 include ground maintenance workers. As waste will remain in place, covered by at least 2 feet of soil, land use controls will be required and are administered as referenced in Section 2.3.2. The soil cover will be inspected and maintained annually mitigating any exposure to subsurface hazards. All ground disturbing actions potentially compromising the soil cover are managed by the LUCIP and will require dig permits from JB MDL.

An instrument-assisted surface and subsurface clearance will be performed at the LF019 106 (mm recoilless rifle cartridge casing Area of Concern (AOC). The AOC is approximately 50-feet x 50-feet in size and is located in the landfill drainage swale which bisects the landfill and includes the adjacent landfill face where cartridge casing has

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

been observed. The AOC boundary may be increased based on identification of 106 mm recoilless rifle cartridge casing on or near the planned boundary. The purpose of the clearance is to remove all MPPEH and munitions debris (MD) from the AOC to the depth of detection of approved instrumentation. Excavations will be performed to remove vegetation from the project area, and subsurface MPPEH items, if necessary.

Boundaries of the removal area will be marked to ensure full coverage and grids established for tracking and navigation. MEC and MD will be documented and photographed. MEC documentation will include the location (including depth), item type, condition, disposition and photograph.

Individual MEC items deemed safe to move will be relocated to an area within the clearance area boundary and as agreed upon by the Project Delivery Team. Demolition activities will be performed using engineering controls as applicable. Individual MEC items deemed unsafe to move will be destroyed using blow-in-place procedures. All demolition activities will be performed in accordance with the approved ESS and UFP- QAPP. All munitions related debris will be assessed to determine presence or absence of an explosive safety hazard. Items found to have an explosive safety hazard will be destroyed using approved detonation procedures within the clearance area boundary. Items found to be free of an explosive safety hazard will be certified as material documented as safe (MDAS) and smelted at an off-site facility prior to recycling in accordance with the requirements of USACE’s Engineer Manual (EM) 385-1-97, Paragraph I.11,C.

5.1.3 Waste Management and Disposal

All waste streams generated throughout the course of the TCRA will be characterized, managed, and disposed of at an off-site facility in accordance with the Waste Management Plan included in the UFP-QAPP. Waste streams requiring containerization, management and disposal could potentially include MDAS, MC contaminated soil, decontamination equipment, personal protective equipment/solid waste, and cultural debris/scrap. All waste will be handled in accordance with Department of Defense, USAF, State and USACE regulations and will be accounted for and tracked from recovery through disposal throughout the life of the project. Details of this accounting will be provided in the Site-Specific Final Report (SSFR).

MDAS will be segregated in locked containers for final disposition .where it will be smelted prior to resale or release in accordance with the requirements of EM 385-1-97, Paragraph I.11,C. Cultural debris (non-munitions-related debris) will be recycled.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

5.1.4 MC Sampling Rationale and Analytical Methods/Data

MC sampling will be performed in LF019 AOC and associated area(s) to determine whether MC poses a risk to human health and the environment. Five types of samples are planned for collection during the TCRA:

• Discreet soil samples beneath any compromised MEC/MPPEH;

• Pre- and post-detonation soil samples at unexploded ordnance detonation locations;

• Post excavation sidewall and floor samples;

• Surface water and sediment samples from South Run Creek adjacent to the removal area; and

• Waste samples.

The MC sampling rationale, analytical parameters for analysis, data evaluation and screening criteria, and data validation protocols will be detailed in the approved UFP- QAPP.

All TCRA activities at LF019 will be documented and project completion will be demonstrated in an SSFR.

5.2 Contribution to Remedial Performance

An SSFR will be prepared documenting and demonstrating completion of the TCRA for LF019. By conducting this action and its associated work, the following contribution will be made to the short-term and long-term remediation of the site:

• Removal of MEC and MPPEH from the LF019 AOC is consistent with the long-term cleanup objective of reducing explosive hazards at the McGuire Area.

• Removal of MEC and MPPEH from the LF019 AOC is consistent with the long-term cleanup objective of preventing human contact to all landfill waste.

• Removal of MEC and MPPEH from the LF019 AOC is consistent with the long-term cleanup objective of reducing the potential for ecological direct contact with buried waste material.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

Institutional controls established under CERCLA for LF019, including the JB MDL LUCIP, will remain in place following the TCRA. The LUCIP includes the Policy for Managing Munitions and Explosives of Concern, which applies to any ground disturbance on JB MDL and requires construction support for MEC.

Results of this TCRA will be used to assess and select a final remedy as part of the currently ongoing CERCLA remediation at LF019. Evaluation of residual risks at the conclusion of the TCRA will be performed in subsequent CERCLA documents and are not included as part of the scope of this TCRA.

5.3 Applicable or Relevant or Appropriate Requirements

Pursuant to Section 300.400(g)(3) and 300.415(j) of the NCP, a list of applicable or relevant and appropriate requirements (ARARs), other advisories, and criteria has been prepared to identify requirements that may apply to response actions. In accordance with CERCLA (as amended by the Superfund Amendments and Reauthorization Act) and the NCP, the development and evaluation of removal actions must include alternatives that meet ARARs to the extent practicable, considering the exigencies of the situation, and to ensure protection of public health and the environment.

ARARs are defined as follows:

• Applicable requirements – Those cleanup standards, standards of control, and other substantive environmental protection requirements promulgated under federal or state law that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site.

• Relevant and appropriate requirements – Those cleanup standards, standards of control, and other substantive environmental protection requirements promulgated under federal or state law that, while not applicable to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site, address problems or situations sufficiently similar to those encountered at a CERCLA site and that their use is well suited to the particular site.

ARARs are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups.

The NCP also identifies the To Be Considered (TBC) category, which includes non- promulgated federal and state criteria, strategies, advisories, and guidance documents.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

TBCs, while not promulgated, will be evaluated along with ARARs for each CERCLA site, and may be used to set protective cleanup level targets. Once incorporated as part of a response action, a TBC that is necessary for protection must be attained at the conclusion of the response.

ARARs and TBCs are divided into three general categories: chemical-specific, location- specific, and action-specific. ARARs and TBCs for the TCRA are presented in Appendix A, Tables A-1, A-2, and A-3.

The activities that would be conducted for this TCRA will comply with all location- and action-specific ARARs. CERCLA sites are exempt from obtaining permits or “permit equivalents” for onsite response actions (Office of Solid Waste and Emergency Response 9355.7-03 dated 19 February 1992, Permits and Permit “Equivalency” Processes for CERCLA On-Site Response Actions); however, the lead agency (i.e., USAF) must comply with the substantive provisions of local, State, or Federal permitting regulations that are determined to be ARARs.

Wetlands were delineated base wide at McGuire in 2005 to determine the extent of New Jersey State and federal wetlands and other waters of the United States. Freshwater forested/shrub wetlands are delineated in the area of the TCRA. N.J.A.C. 7:7A-5.5 General Permit 5 [Equivalent] -- Landfill Closures authorizes landfill closure activities in freshwater wetlands, transition areas and/or State open waters without subsequent mitigation (N.J.A.C 7:7A-5.5.d).

5.4 Project Schedule

TCRA activities are expected to occur from the date of award (26 September 2019) through 2 November 2020. TCRA fieldwork is anticipated to commence in June 2020.

The following provides a summary of the main project tasks and durations. Several of these tasks will be conducted concurrently with other tasks.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

Project Schedule Summary

Task Start Finish 1. Project Management Plan and QASP 9/27/2019 2/27/2020

2. TCRA Action Memorandum 9/27/19 10/3/2020 3. TCRA ESS 9/27/2019 6/23/2020 4. TCRA UFP-QAPP 11/10/2019 8/24/2020

5. TCRA Site Preparation, MEC Removal and Disposal, 9/4/2020 10/8/2020 and Site Restoration 6. SSFR 10/9/2020 2/22/20201

7. ESS After Action Report 10/9/2020 2/22/20201

5.5 Estimated Costs

The estimated cost of this action (sub-Contract Line Item Number 0001) is $547,385.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

6. Expected Change in the Situation Should Action be Delayed or Not Taken

A delay in action or no action regarding the TCRA at LF019 at JB MDL would result in continued potential for human exposure to MEC in the landfill AOC.

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

7. Outstanding Policy Issues

No outstanding policy issues are currently identified.

15 Time-Critical Removal Action Memorandum McGuire n LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

8. Authorizing Signature

This Action Memorandum represents the selected removal action at the site, developed in accordance with CERCLA as amended, and is not inconsistent with the NCP. This decision is based upon the Administrative Record for the site.

APPROVED:

Digitally signed by MAYER.GREGOR MAYER.GREGORY.C.11476468 24 11/11/20 Y.C.1147646824 Date: 2020.11.11 12:45:39 -06'00'

*/(*-/2 '% ,&2(/$ +5 '43$ 10&)$ .%( Date *89;:< Director, Environmental Management Air Force Civil Engineer Center "&)'('#

Time-Critical Removal Action Memorandum

McGuire – LF019 Landfill Joint Base McGuire-Dix- Lakehurst, New Jersey

9. References

EPA, Office of Emergency Management, Office of Solid Waste and Emergency Response. 2009. Superfund Removal Guidance for Preparing Action Memoranda. Washington, D.C. September 2009.

17 Figures

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ARARs and TBCs

Table A-1 Chemical-Specific ARARs and TBCs

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement State Soil New Jersey Applicable: Establishes residential and non-residential The action will comply with these Regulatory Department of NRDCSRS and health-based standards based on more requirements by comparing the Requirement Environmental RDCSRS (where a stringent ingestion/ dermal or inhalation results of the munitions Protection NRDCSRS is not pathway. constituent sampling effort Residential Direct available) ingestion/ against the RDCSRS and Contact Soil dermal pathway (Note: Inhalation pathway standards are NRDCSRS. Remediation standards Not Applicable or Relevant and Standards Appropriate) A CERLCA action for LF019, (RDCSRS) and Non- which includes a soil cover, will Residential Direct be documented in a separate Contact Soil ROD in 2020 following Remediation completion of the TCRA. Standards (NRDCSRS); New Jersey Administrative Code 7:26D- 4.2 and 4.3 Notes: ARAR - applicable or relevant and appropriate requirement TBC - to be considered

Table A-2 Location-Specific ARARs and TBCs

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement Federal Regulatory Wetland and Statement on To Be Considered This Statement of Procedures sets forth The action will take into Requirement Floodplain Procedures on Agency policy and guidance for carrying out consideration the potential effects Floodplain the provisions of Executive Order 11990. of any action on floodplain Management and management and wetland Wetlands Protection; protection at Operable Unit 3 40 Code of Federal (OU3). Regulations (CFR) 6 Appendix A Federal Non- Wetland Protection of To Be Considered Federal agencies are required to minimize The action will take into Regulatory Wetlands Executive the destruction, loss, or degradation of consideration wetlands protection Requirement Order (EO); EO wetlands and to preserve and enhance and management at OU3. 11990 natural and beneficial values of wetlands. However, as some wetland areas have developed on the landfills, wetland disruption is unavoidable in some areas. Federal Regulatory Wetland Clean Water Act; Applicable Under this requirement, no activity that Under Comprehensive Requirement Section 404; 40 CFR adversely affects a wetland is permitted if a Environmental Restoration, 230.41, 230.74, practicable alternative that does not affect Compensation and Liability Act 230.91, 231.2(e), wetlands is available. If no other practicable (CERCLA), permits are not 232.2, 232.3, and alternative exists, impacts on wetlands required for on-site remedial 233.71 must be mitigated. activities, but the action will comply with Substantive requirements of otherwise required permits for wetlands at OU3. State Regulatory Wetland Freshwater Wetland Applicable This act regulates activities that disturb Under CERCLA, permits are not Requirement Protection Act; New wetlands and vernal pools, including those required for on-site remedial Jersey Administrative that are located on top of landfill covers activities, but the action will Code (N.J.A.C.) 7:7A, such as within OU3. Under N.J.A.C. 7:7A- comply with substantive New Jersey Statute 7.5 General Permit 5 – Landfill Closures, requirements of otherwise required Annotated there is no acreage limit to activities that permits for wetlands at OU3. (N.J.S.A.)13:98-1 disturb wetlands located on top of the landfill, or on the intermediate or permanent cover of the landfill. Mitigation is not required for the wetlands located on the landfills and disturbance of wetlands beyond the landfill covers is not anticipated as part of the remedy for OU3

Table A-2 Location-Specific ARARs and TBCs

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement Federal Regulatory Biota Endangered Species Applicable This requirement establishes standards for No endangered or threatened Requirement Act ; 16 United States the protection of threatened and species were identified at OU3. If Code (U.S.C.) 1531 endangered species. No species of special such species or habitats are et seq.; 40 CFR 400 concern or endangered species were identified at OU3, the action will observed onsite. Recently, the northern incorporate Necessary mitigation long-eared bat was identified as a steps. Clearing of vegetation will threatened species in Burlington County. be scheduled to avoid peak The action is not expected to harm any roosting times. endangered or threatened species or critical habitat. Federal agencies are required to work with the United States Fish and Wildlife Service (USFWS) to determine if mitigation steps are required. Federal Regulatory Biota Migratory Bird Treaty Applicable The action must be executed in a manner The action will be implemented in Requirement of 1918; 1 U.S.C. 03 that avoids the taking or killing of protected a manner that avoids harming et seq. migratory bird species, including individual protected migratory birds. birds or their nests or eggs. The action is not expected to harm protected migratory Any fieldwork that starts after April birds. 1 and requires removal of trees/vegetation would require a field survey to ensure there are no migratory birds nesting in the trees/vegetation prior to removal. State Regulatory Biota New Jersey Relevant and This act protects and conserves No endangered or species of Requirement Endangered and Appropriate endangered and nongame species. No special concern were observed Nongame Species species of special concern or endangered onsite. If such species are Conservation Act; species were observed onsite. Recently, identified at OU3, the action will N.J.S.A. 23:2A-1-15 the northern long-eared bat was identified incorporate Necessary mitigation as a threatened species in Burlington steps. Clearing of vegetation will County. The selected remedy is not be scheduled to avoid peak expected to harm any endangered species roosting times. or species of special concern. Federal agencies are required to work with the USFWS to determine if mitigation steps are required. State Regulatory Biota New Jersey Relevant and This act protects endangered plant species. No endangered plant species were Requirement Endangered Plant Appropriate No endangered species were observed observed onsite. If such species Species List Act; onsite. The action is not expected to harm are identified at OU3, the action

Table A-2 Location-Specific ARARs and TBCs

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement N.J.A.C. 7:5B and 7 any endangered species, species of special will incorporate necessary :5C-5.1 concern, or critical habitat. mitigation steps. State Regulatory Pinelands New Jersey Relevant and The Comprehensive Management Plan The action will be in substantial Requirement Pinelands Appropriate (CMP) contains the rules and regulations of compliance with the CMP. The Comprehensive the New Jersey Pinelands Commission action will meet the substantive Management Plan (NJPC). The CMP is designed to preserve requirements of potential permit (CMP) ; N.J.A.C. 7:50 and protect the significant and unique equivalents that may be required resources of the Pinelands. Federal by NJDEP for wetlands at OU3. installation master plans and any remediation undertaken within the Pinelands will be in substantial conformance with the minimum standards and guidelines contained in the CMP. The CMP prohibits most development, including clearing and land disturbance, in wetlands. The NJPC administers New Jersey Department of Environmental Protection’s (NJDEP’s) general permit program in the Pinelands, which is required for general development within 300 feet of freshwater wetlands in the Pinelands. However, the wetlands at OU3 that may be potentially impacted by remedial activities are in previously disturbed and cleared areas. The Commission’s review of the Proposed Plan concluded that “the selected alternative is in compliance with the requirements of the CMP” (Pinelands Commission, 2017). Notes: ARAR - applicable or relevant and appropriate requirement TBC - to be considered

Table A-3 Action-Specific ARARs and TBCs

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement Federal Military 40 Code of Federal Applicable Regulates unused munitions, munitions used for Identify when military munitions Regulatory Munitions Regulations (CFR) intended purposes, and used or fired munitions. become a solid waste; and, if these Requirement Part 266: 40 CFR wastes are also hazardous under 262.11 and 266.203 this subpart or 40 CFR Part 261, identify the management standards that apply to these wastes Federal Wastes Resource Applicable Describes standards applicable to generators of The action will comply with these Regulatory Conservation and hazardous wastes. requirements if any hazardous Requirement Recovery Act wastes are generated onsite. Standards Applicable to Generators of Hazardous Wastes; 40 CFR 262 State Regulatory Wastes New Jersey Applicable This regulation describes methods for The action will comply with these Requirement Hazardous Waste identifying hazardous wastes and lists known requirements if any hazardous Regulations - hazardous wastes. This regulation will be wastes are generated onsite, or Identification and applicable to the identification of hazardous treated, stored, or disposed in New Listing of Hazardous wastes that are generated, treated, stored, or Jersey. Waste; New Jersey disposed in New Jersey during remedial Administrative Code activities. (N.J.A.C.) 7:26G-5 State Regulatory Soil/ Sediment/ New Jersey Soil Relevant and This act outlines the requirements for soil Sediment and erosion control Requirement Water Erosion and Sediment Appropriate erosion and sediment control measures for any measures will be implemented prior Control Act; N.J.A.C. disturbance exceeding one acre at federal to initiating field activities. 2:90 installations. State Regulatory Soil Burlington County Soil To Be A soil erosion and sediment control plan is Compliance with the substantive Requirement Conservation District; Considered required by the local soil conservation office for requirements will be considered Soil Erosion and any project that disturbs more than one acre at prior to initiating field activities. Sediment Control federal installations. Action will disturb less than 1 acre. Plan; N.J.A.C. 2:90 State Regulatory Waste New Jersey Relevant and These regulations establish rules for the All remedial activities must adhere Requirement Hazardous Waste; Appropriate operation of hazardous waste facilities in the to these regulations while handling N.J.A.C. 7:26C state of New Jersey. hazardous waste during remedial operations, if hazardous waste is identified and treated/stored onsite. Notes: ARAR - applicable or relevant and appropriate requirement TBC - to be considered 1