Text Box: At the February 22, 2011 technical meeting held amongst representatives of the USEPA, the NJDEP, the Army Corps of Engineers, Arcadis, and Picatinny Arsenal some of the meeting was directed at the impasse on land use controls (LUCs) that has arisen between the USEPA and Picatinny Arsenal. At that meeting Picatinny Arsenal agreed to prepare a letter detailing their understanding of the situation. In a subsequent e-mail (dated March 10, 2011) the USEPA noted that they did not agree that a letter from the Army would be useful and that “we are certainly aware of the Army’s position and do not need a letter to remind us.” The comment from the USEPA arrived too late – the Army had already prepared a letter dated March 10, 2011 that provided a written summary of the Army’s “position regarding CERCLA drivers for actions at sites included in the ‘multisite Feasibility Studies’ at Picatinny Arsenal.” The letter from Mr. James D. Daniel, Chief of the Army Cleanup and Munitions Response Division, was addressed to Ms. Angela Carpenter, Chief of the USEPA Special Projects Branch. The Army noted their good faith negotiations with the NJDEP and the USEPA and that “such negotiations and discussion have been required as most sites [all except the 5-Site FS sites] fall within the generally accepted risk range for the current and reasonably anticipated future user, yet have constituent concentrations observed above

POINTS OF INTEREST:   

· The last PAERAB meeting was held on Thursday, March 3, 2011th at the Hilton Garden Inn in Rockaway, New Jersey. 

 

· The next PAERAB meeting will be held on Thursday, June 16, 2011 at the Hilton Garden Inn in Rockaway, New Jersey.  The meeting will be held from 6:30 to 8:30 pm.  Members of the public are invited to attend.

 

· A Picatinny Arsenal technical team meeting was held on April 19, 2011 concerning the   Mid-Valley area. Another was conducted on May 5, 2011 as a teleconference about the  MMRP Non-Time Critical Removal Process and the use of interim land use controls (LUC) at Picatinny Arsenal.

This is the army take

1

In the field

1

Comments on RAR

2

MMRP action

2

Document approvals

4

Change of staff

4

Training

4

Mid-valley musings

5

Land use cert report

5

Tilcon 3 tcra

6

site 78

7

ITRC

11

vapor intrusion intro

11

Spring 2011

Volume 10, issue 2

Text Box: Draft Environmental Happenings At Picatinny Arsenal Text Box: IN THE FIELD….. Text Box: Recent field activities for March through May 2011 included the following: Area B – Collect passive diffusion bags (PDBs); collect surface water samples (March). Collect total organic carbon (TOC) samples (May). Text Box: Area D – Collect PDBs; collect surface water samples (March).

This Is The Army Take On It….
Text Box: Editorial Reviewers David Forti, Michael Glaab Technical Advisors Ted Gabel, William Roach, Gregory Zalaskus Image of 2 Star General Text Box: the NJDEP Soil Remediation Standards [SRS].” The USEPA’s cleanup approach is driven by risk assessments – any sites with a human health risk greater than 10-4 are candidates for a remedial action. The NJDEP utilizes fixed remediation standards (for soil) that are based on a risk of 10-6. Therein lies the rub….two different approaches based on fundamentally different risk levels. Until now the Army and the agencies have made various concessions on satisfying both cleanup triggers. The Army notes the following: “In an attempt to move cleanup forward, further negotiations in December 2009 resulted in the Army agreeing to refer to the NJDEP SRS as ARARs in our Feasibility Study documents under the provision that the agreed remedies would not change (generally Land Use Controls, to Image of Man In Forest

Area E – Collect sample PDBs (March).

CONTINUED ON P. 3

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