Interview background
On March 25th, a classmate and I spoke with Bill Friedmann from US EPA about the FAA Superfund site. My classmate is focusing on a different set of Operable Units at the FAA, but we decided to meet together because some of our interview questions overlapped. The summary provided below is based on that discussion and very quick notes taken over our two hour phone conversation.
Bill has been the EPA Remedial Project Manager for the FAA Tech Center Superfund and other US Military bases since 2019. He has thirty years of experience as an environmental consultant and geologist on military bases. The NJDEP Case Manager for this Superfund site recently retired.
We were very thankful for the chance to speak with Bill about the site. He provided additional resources following our conversation to aid in our research.
The outline of our discussion below includes general questions about the property and remediation. There was also a focus on specific operable units for my research on OU #1, 7, and U. My classmate researched OU #2, 9, and 11.
Bill has been the EPA Remedial Project Manager for the FAA Tech Center Superfund and other US Military bases since 2019. He has thirty years of experience as an environmental consultant and geologist on military bases. The NJDEP Case Manager for this Superfund site recently retired.
We were very thankful for the chance to speak with Bill about the site. He provided additional resources following our conversation to aid in our research.
The outline of our discussion below includes general questions about the property and remediation. There was also a focus on specific operable units for my research on OU #1, 7, and U. My classmate researched OU #2, 9, and 11.
Interview with the EPA Remedial Project Manager
Accessibility of the site:
The FAA facility is a municipal airport, but access to the base is restricted by security checkpoints and fences. Some of the OUs with groundwater contamination are open fields. Other sites are landfills. Google Earth shows the perimeter of the facility up to the first checkpoints. Signs and notices are posted for the sites. One of the OUs is visible from a public road, Amelia Earhart Blvd.
Remediation strategies:
The remedy for OU #29 includes heating water for VOCs with pipes in well points.
There is a quicker remediation timeline for sites that do not have scheduled activities. A lot of the remaining contamination is in the groundwater.
In the industrial area (OU #1/12), the soil was dug out, back-filled with clean soil, and paved over. During active treatment of the groundwater, the parking lot in the area was used.
Military bases often have landfills. For example, Lakehurst has decades of landfills that must be covered so they have been converted to solar farms. This is an option for repurposing Superfund properties.
Soil and land use contamination restricts access, especially soil access. There is a risk from touching contaminated soils or kicking up dust that can be inhaled. With groundwater contamination, a site can be repurposed in ways that don't touch the groundwater.
Exposure precautions:
There are no HAZWOPER requirements for site visitors. OSHA is for workers. After 30 or more days on site, you would need medical monitoring and training. Representatives of the FAA don't need training. [exposure time is limited].
Discovery of the site and OUs:
The discovery of Superfund sites is based on the presence of a hazardous waste. This can be conducted through desktop reviews and identification of historic spills. Phase I triggers more work at a site, such as a walk-through that reveals 50 rusted drums in a creek. Investigation or scoring is used to determine whether a site should be listed as an official site on the NPL federal register. Sites can be on NPL for decades.
At the FAA, 16 OUs were added overtime from investigations. The main site was classified first, then OUs slowly built up. The military response program became an operable unit and PFAs will likely become another unit. The EPA suggests creating a new OU because of funding or bookkeeping. Separating funding helps the process and sorts investigations, plans, and remedies.
When investigating a site, you would consider whether operations match up with contamination or are there other sources, like PFAs. PFAs are a new emerging contaminant that travels far reaches, creating a new area of contamination. New compounds are identified as a concern overtime. PFAs is used in fire-fighting foams and a growing list of sources we use daily. PFAs are being investigated for their potential impact on drinking water sources.
See the Federal Facility Agreement for areas first identified in the 1980s.
Cleanup:
Cleanup begins by identifying the risk and starting a feasibility study to look at options. At the FAA, risks are the soil and groundwater. Determine the technical criteria, short-term exposure, cost, and compare 3-6 alternatives. For example, if soil contamination is 3ft across 1/4 acre, it would be dug up. If soil contamination is 50 ft down, it may take 5-10 years or you can calculate degradation. Equations are used to determine the best practice and the FAA decides on the methods.
If soil contamination is not deep, options include:
For groundwater, common methods are
Cleanup involves monitoring over time to see if the methods are still working
treat the soil on site and return it, treat soils thermally and return, or permanent landfill if that is cheaper.
Lessons Learned
A lot of lessons are applied to new projects. Funding, management, time frame, why wasn't the technology more efficient, not enough data collected
Pump and treat was the original method for groundwater treatment, but no longer effective. Injection is replacing pump and treat methods.
First contamination event- 1940s
Best management practices were lacking prior to 1970
Other contamination sources and events
hazards: VOCs
material might be collected with disposal offsite
Triple F foam was last used in the 1970s-1980s
one area of groundwater contamination is managed by the Air National Guard
groundwater contamination must remain on site to control
immediate exposure concerns--public exposure potential
Area 41
Area 41 has been investigated overtime and is fully characterized. A remedy is in place.
Assessments and Reviews
Ecological risk assessments- multiple data collections, only a few weeks-months
Federal Facilities use subcontractors for planning and execution, almost always
The EPA does a review after that.
Screening Level Ecological Risk Assessment: SLERA--screening assessments if habitat exists
Some sites are on paved surfaces, landing areas, or open fields. These facilities have less of an impact on plants and animals. Where wildlife is present, the risk is that wildlife will feed on plants and toxic substances will spread through the foodweb.
Public Meetings and Technical Meetings
The FAA does not hold public meetings. As a Federal organization, they are not required to hold public meetings, however the remedy chosen has to be made public. There are internal, technical meetings with the NJ state Pinelands Commission and EPA about the status.
Resistance to Remediation
There is no resistance to remediation. In general, there is a state and public acceptance. There is no history of problems with the public, although running trucks through neighborhoods may be an issue.
Scheduling and Time Frame
Funding slows project schedules. Funding is the responsibility of the FAA. Schedules last years to decades. The emerging concern of PFAs is starting to be addressed now, but the schedule is uncertain based on the extent in soil, groundwater, and surface water. Emerging concerns require research into technology that can be used, data required, and less destructive ways to remediate.
Prevention Methods
Prevention methods and institutional controls reduce the likelihood of future spills and contamination events. State and Federal guidelines for spills both reduce incidents and establish plans for responding to spills. Facilities must also demonstrate that they are maintaining cleanups and provide Hazmat teams for facilities.
Documentation
Superfund decision documents are available on the EPA website and Google.
The FAA does not have documentation online yet, but a database will be coming soon.
Some sites may be listed on the EPA website, but documentation is not available yet.
OU #4 C, H, M
Area C had a fuel spill that has been undergoing cleanup for years. It has nearly reached the clean up goals.
Area H may be closed. No further action.
Area M was a gelled fuel testing area.
OU #9, Area A, J, N
Only Area A required cleanup. Research and development of a landfill. Currently finishing long-term monitoring and reaching acceptable levels.
FAA monitoring wells will stay in place when cleanup is complete to find PFAs and other emerging contaminants.
OU #11, Area 27, 56
Area 56 and Area R are undergoing long-term monitoring.
These areas are undergoing optimization for all existing data and geophysical anomalies. Data is being reviewed to see if monitoring can be tweaked or if other actions are needed.
OU Area U, Upper Reservoir
The North and South branch have mercury contamination. The US Army Corp. of Engineers is leading the investigation. It should take 3-5 years to select an remedy. Implementation of the remedy shall take several years. Cleaning will take decades. A decision will take 4-5 years.
MMRP Pistol Ranges
This area had explosives, but not enough history is known. There are funding delays for the investigation.
Area Y
This is a small area within OU#3 that is being re-investigated near other OUs. The site characterization report was conducted last summer. Area Y is moving to the remediation stage, with a few years remaining for a decision document.
Complications with Remediation at the FAA Facility
Active military facilities are hard to sample. There is lots of activity, conditions are challenging, and the areas are secure. There are limitations on clean up in active military sites. If a tarmac is contaminated, it cannot be ripped up. Facilities need to be worked around.
Groundwater wells around the upper reservoirs are becoming a concern. ACMUA relies on these wells for drinking water for Atlantic City, but they have been impacted by PFAs. There is active litigation and a lawsuit between ACMUA and the FAA. ACMUA uses wells 16, 17, 18, 19, 20, 21, 22, and 23.
Recommended further research:
-PFAs
-ESD- Explanation of Significant Differences
The FAA facility is a municipal airport, but access to the base is restricted by security checkpoints and fences. Some of the OUs with groundwater contamination are open fields. Other sites are landfills. Google Earth shows the perimeter of the facility up to the first checkpoints. Signs and notices are posted for the sites. One of the OUs is visible from a public road, Amelia Earhart Blvd.
Remediation strategies:
The remedy for OU #29 includes heating water for VOCs with pipes in well points.
There is a quicker remediation timeline for sites that do not have scheduled activities. A lot of the remaining contamination is in the groundwater.
In the industrial area (OU #1/12), the soil was dug out, back-filled with clean soil, and paved over. During active treatment of the groundwater, the parking lot in the area was used.
Military bases often have landfills. For example, Lakehurst has decades of landfills that must be covered so they have been converted to solar farms. This is an option for repurposing Superfund properties.
Soil and land use contamination restricts access, especially soil access. There is a risk from touching contaminated soils or kicking up dust that can be inhaled. With groundwater contamination, a site can be repurposed in ways that don't touch the groundwater.
Exposure precautions:
There are no HAZWOPER requirements for site visitors. OSHA is for workers. After 30 or more days on site, you would need medical monitoring and training. Representatives of the FAA don't need training. [exposure time is limited].
Discovery of the site and OUs:
The discovery of Superfund sites is based on the presence of a hazardous waste. This can be conducted through desktop reviews and identification of historic spills. Phase I triggers more work at a site, such as a walk-through that reveals 50 rusted drums in a creek. Investigation or scoring is used to determine whether a site should be listed as an official site on the NPL federal register. Sites can be on NPL for decades.
At the FAA, 16 OUs were added overtime from investigations. The main site was classified first, then OUs slowly built up. The military response program became an operable unit and PFAs will likely become another unit. The EPA suggests creating a new OU because of funding or bookkeeping. Separating funding helps the process and sorts investigations, plans, and remedies.
When investigating a site, you would consider whether operations match up with contamination or are there other sources, like PFAs. PFAs are a new emerging contaminant that travels far reaches, creating a new area of contamination. New compounds are identified as a concern overtime. PFAs is used in fire-fighting foams and a growing list of sources we use daily. PFAs are being investigated for their potential impact on drinking water sources.
See the Federal Facility Agreement for areas first identified in the 1980s.
Cleanup:
Cleanup begins by identifying the risk and starting a feasibility study to look at options. At the FAA, risks are the soil and groundwater. Determine the technical criteria, short-term exposure, cost, and compare 3-6 alternatives. For example, if soil contamination is 3ft across 1/4 acre, it would be dug up. If soil contamination is 50 ft down, it may take 5-10 years or you can calculate degradation. Equations are used to determine the best practice and the FAA decides on the methods.
If soil contamination is not deep, options include:
- treat the soil and return it
- treat soils thermally and return
- permanent landfill (if that is cheaper)
- treat with other chemicals
- treat with biological factors to reduce soil contamination
- in-situ injections with different compounds into the soil
For groundwater, common methods are
- draw contamination out of the groundwater, treat it, and discharge it to a waterway
- oxidation injections
- treat with compounds
- thermal options
Cleanup involves monitoring over time to see if the methods are still working
treat the soil on site and return it, treat soils thermally and return, or permanent landfill if that is cheaper.
Lessons Learned
A lot of lessons are applied to new projects. Funding, management, time frame, why wasn't the technology more efficient, not enough data collected
Pump and treat was the original method for groundwater treatment, but no longer effective. Injection is replacing pump and treat methods.
First contamination event- 1940s
Best management practices were lacking prior to 1970
Other contamination sources and events
hazards: VOCs
material might be collected with disposal offsite
Triple F foam was last used in the 1970s-1980s
one area of groundwater contamination is managed by the Air National Guard
groundwater contamination must remain on site to control
immediate exposure concerns--public exposure potential
Area 41
Area 41 has been investigated overtime and is fully characterized. A remedy is in place.
Assessments and Reviews
Ecological risk assessments- multiple data collections, only a few weeks-months
Federal Facilities use subcontractors for planning and execution, almost always
The EPA does a review after that.
Screening Level Ecological Risk Assessment: SLERA--screening assessments if habitat exists
Some sites are on paved surfaces, landing areas, or open fields. These facilities have less of an impact on plants and animals. Where wildlife is present, the risk is that wildlife will feed on plants and toxic substances will spread through the foodweb.
Public Meetings and Technical Meetings
The FAA does not hold public meetings. As a Federal organization, they are not required to hold public meetings, however the remedy chosen has to be made public. There are internal, technical meetings with the NJ state Pinelands Commission and EPA about the status.
Resistance to Remediation
There is no resistance to remediation. In general, there is a state and public acceptance. There is no history of problems with the public, although running trucks through neighborhoods may be an issue.
Scheduling and Time Frame
Funding slows project schedules. Funding is the responsibility of the FAA. Schedules last years to decades. The emerging concern of PFAs is starting to be addressed now, but the schedule is uncertain based on the extent in soil, groundwater, and surface water. Emerging concerns require research into technology that can be used, data required, and less destructive ways to remediate.
Prevention Methods
Prevention methods and institutional controls reduce the likelihood of future spills and contamination events. State and Federal guidelines for spills both reduce incidents and establish plans for responding to spills. Facilities must also demonstrate that they are maintaining cleanups and provide Hazmat teams for facilities.
Documentation
Superfund decision documents are available on the EPA website and Google.
The FAA does not have documentation online yet, but a database will be coming soon.
Some sites may be listed on the EPA website, but documentation is not available yet.
OU #4 C, H, M
Area C had a fuel spill that has been undergoing cleanup for years. It has nearly reached the clean up goals.
Area H may be closed. No further action.
Area M was a gelled fuel testing area.
OU #9, Area A, J, N
Only Area A required cleanup. Research and development of a landfill. Currently finishing long-term monitoring and reaching acceptable levels.
FAA monitoring wells will stay in place when cleanup is complete to find PFAs and other emerging contaminants.
OU #11, Area 27, 56
Area 56 and Area R are undergoing long-term monitoring.
These areas are undergoing optimization for all existing data and geophysical anomalies. Data is being reviewed to see if monitoring can be tweaked or if other actions are needed.
OU Area U, Upper Reservoir
The North and South branch have mercury contamination. The US Army Corp. of Engineers is leading the investigation. It should take 3-5 years to select an remedy. Implementation of the remedy shall take several years. Cleaning will take decades. A decision will take 4-5 years.
MMRP Pistol Ranges
This area had explosives, but not enough history is known. There are funding delays for the investigation.
Area Y
This is a small area within OU#3 that is being re-investigated near other OUs. The site characterization report was conducted last summer. Area Y is moving to the remediation stage, with a few years remaining for a decision document.
Complications with Remediation at the FAA Facility
Active military facilities are hard to sample. There is lots of activity, conditions are challenging, and the areas are secure. There are limitations on clean up in active military sites. If a tarmac is contaminated, it cannot be ripped up. Facilities need to be worked around.
Groundwater wells around the upper reservoirs are becoming a concern. ACMUA relies on these wells for drinking water for Atlantic City, but they have been impacted by PFAs. There is active litigation and a lawsuit between ACMUA and the FAA. ACMUA uses wells 16, 17, 18, 19, 20, 21, 22, and 23.
Recommended further research:
-PFAs
-ESD- Explanation of Significant Differences
References
Interview conducted with Bill Friedmann, US EPA Remedial Project Manager. (March 25, 2022).
