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  Comments on the FINAL Remedial Action Report for the Former DRMO Yard ICM Site

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Non-Time Critical Removal Action for Munitions Response Sites (MRSs) at Picatinny

Representatives of the USEPA, NJDEP, the  Army Corps of Engineers, Picatinny Arsenal, and the RAB were participants in a conference call led by ARCADIS/Malcolm Pirnie (Malcolm Pirnie was acquired by ARCADIS in 2009) and the Army Environmental Center on May 5, 2011.  The subject of the conference call was the introduction of a new program that will address non-operational, on post MRS sites in a Non-Time Critical Removal Action (NTCRA) process otherwise referred to as the “Land Use Control Project.”   The NTCRA process is concerned with


the placement of interim land use controls (LUCs) at some sites to minimize the risks to humans associated with those sites.  ARCADIS/Malcolm Pirnie provided participants with a series of 30 slides to accompany the speakers for the conference call.   The timeframe for MRS sites, now in the Remedial Investigation stage, to reach the response action phase could be many years.  The Army wants to mitigate potential threats to human health from the potential presence of Munitions and Explosives of


Concern (MEC) and/or Munitions Constituents (MC) through the use of LUCs until the  final remedial  action is implemented.

absence of corrections to these discrepancies may be due to a simple oversight.  However, Mr. Pastorick discusses the problem with the wholesale rejection of one of the comments:  “According to this precedent USEPA is required to duplicate and support NJDEP’s regulatory comments in order for Picatinny to recognize the comment as valid and worthy of action.”  He explains that the intent of the NJDEP comment was to request a brief addendum to the action memorandum so that readers would be able to understand that the change from a 4-foot thick cap to a 2-foot thick cap was agreed to by all the regulators.  He states, “The fact that USEPA didn’t make the same request isn’t justification for not addressing the substance of this comment.  NJDEP believes this comment is valid and requests an Army response that addresses the technical issue involved:  how someone reviewing the project in the future will be able to easily

The NJDEP used the services of a contractor who is tasked with focusing  exclusively on UXO issues: Mr. Jim Pastorick of UXOPro (Alexandria, Virginia). Mr. Pastorick was tasked with review of the Remedial Action Report for the former DRMO Yard ICM site.  His first comments, dated October 23 of 2010, were primarily editorial in nature. For example, he noted some discrepancies between statements in different parts of the text.  Since then Mr. Pastorick reviewed the final copy of the Interim Remedial Action Report. In this review he noted that several previous comments had been entirely disregarded in the final version of the document and that another comment was entirely rejected solely because “the USEPA approved the final draft of the document and didn’t have a similar comment….”  The following discrepancies had been cited by Mr. Pastorick in his initial review: an inaccurate table in which data differed from that described in the text, missing photos in an appendix, and the use of abbreviations that were not identified in the document. The seeming

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understand that this change was considered by the regulators and approved.” In response, the Army provided the following clarification:


“To address these comments, the Army is providing replacement pages of Table 3-1 and the Abbreviation List. The supposedly missing photos were included in the original report; however the response to comment form references the incorrect Appendix. Therefore a revised response to

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