The status of the Mid-Valley Groundwater Investigation was the topic of February 22, 2011 technical team meeting.  The intended plan for the Mid-Valley area was also discussed at the March 3, 2011 PAERAB meeting.  At that time the intent was to develop a Feasibility Study (FS) Addendum report for the Army by March and to then submit it to regulators at some later date with approval of the addendum being a goal for July 2011.  The FS addendum has not yet been released to regulators. According to

the Army additional meetings with the NJDEP, USEPA and NJGS were held on April 19, 2011 to further discuss the addendum which has subsequently been submitted for internal Army review. It is currently anticipated that the addendum will be submitted to the NJDEP and USEPA sometime in June of 2011. It is unclear if the current Land Use Control (LUC) issue between the Army and the USEPA/NJDEP is delaying progress.  The FS addendum is expected to provide an updated conceptual site model, a hydrogeological model, and remedial time frame

estimates along with an evaluation of five alternatives for the southern trichloroethene (TCE) plume.  Arcadis has proposed the use of

MID-VALLEY MUSINGS

On April 21, 2011 the USEPA commented on the 2010 Annual Land Use Certification dated April 2011.  The USEPA noted that photos documenting land use controls (LUCs) were made when the ground was snow covered thus making it impossible to evaluate the condition of vegetative covers.  The agency requested that future photo documentation be obtained when the ground is not snow covered.  The USEPA also noted the absence of two signs prohibiting digging and requested that the signs be replaced (at PICA-020, Site 86 [PICA 095]) and also missing from PICA-020, Site 182 (PICA 099).   The USEPA also had the following comment:  “The checklist indicates that Building 5 has been demolished and a

parking lot has been constructed on the site.  The PICA-020 ROD states:  ‘A change in land use would include the re-evaluation of clean-up requirements and notification and concurrence of USEPA and NJDEP.’   EPA has no record of being notified about this change in land use or soil clearance notification that should have been involved with the construction of a parking lot at Site 182.  In addition, this change in land use is not described in Section 3.2.1.5 which describes Building 5 as still existing at the site.  It is requested that USEPA and NJDEP be notified in the future when land use changes involving construction and movement of soil at a site with a LUC remedy in place. “  This incident is of the type that both regulators and the community have expressed concern about in the past when considering the efficacy of LUCs.  Despite the implementation of  stopgap measures to avoid construction

 at certain sites and assurances that safeguards are in place mistakes can happen. Construction or demolition activities can inadvertently result in unanticipated changes occurring  without proper prior notification of  the appropriate authorities. Accordingly, the Army responded to the USEPA’s comment stating that the action had been discussed via e-mail in 2008 (no date mentioned) and at a November 12, 2009 technical meeting.  The Army contends that additional action was not required because the land use did not change (it remained industrial) and no soil was removed from the site (which was in conformance with the Picatinny soil management policy).  It was further stated that “Army personnel attempt to inform USEPA and NJDEP of

ongoing construction projects at the Arsenal as a courtesy; and, will meet all notification requirements when there is a change from the land use documented in the ROD (i.e., industrial to residential, or industrial to recreational).”  Other USEPA comments were noted by the Army which assured that it would be in compliance — with the exception of not posting a sign at the site that was converted to parking lot use.

emulsified vegetable oil (EVO) as part of the enhanced reductive dechlorination (ERD) alternative.