Page 10 of the PAERAB's Spring 2011 Community Update Newsletter

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Close to ROD for Site 78? ( continued from p. 9)

Text Box: considered that there is no need to further evaluate the potential presence of 1,4-Dioxane”. The Army answered each of the inquiries but at this time no additional response has yet been received from the NJDEP nor has a concurrence letter been forthcoming. Mr. Michael Glaab who is one of the two RAB Co-chairmen of the PAERAB, (Mr. Ted Gabel serves as the other RAB Co-chairman: he is its DoD Chairman while Mr. Glaab serves as the board’s Community Chairman.) offers the following comment: ‘...although it would be ideal if disagreements between the regulators and the Army never occurred it is unreasonable to expect this. It is almost inevitable that there will occasionally be some disagreement - even between consummate professionals. The environmental remediation “partnering” process appears

Text Box: to have been deliberately designed and legally established by congress to encourage federal and state environmental regulators to synergistically work together with the federal entity being regulated such that contaminated sites will be remediated by them collaboratively. In fact, it is encouraging that Mr. Putnam of the NJDEP is apparently attempting to thoroughly review the relevant documents and that he is trying to responsibly consider all possible significant ramifications with the presumed ultimate goal of safeguarding the environment and also the health, safety and welfare of those individuals who are employed at the arsenal, of those who reside on the premises of the arsenal and of those who live in close proximity to Picatinny Arsenal. In addition, it must be noted that many, if not most, community members of the PAERAB have repeatedly expressed, throughout

Text Box: the years, a preference for environmental remediation options that involve active cleanup measures rather than such passive measures as monitored natural attenuation (MNA). After all, MNA essentially involves permitting contaminants to remain on site until those contaminants are finally naturally dissolved, degraded or transformed into their less harmful constituents by the environment itself.’

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

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Text Box: which is part of the formal project record and no additional documentation is required by CERCLA guidance”.

Text Box: comment form is also being submitted. Regarding the final point of documenting the change in soil cap thickness through preparation of a brief addendum, it remains the Army’s position that the design revision is sufficiently documented in the USEPA approved Interim Remedial Action Report (IRAR)

- ( continued from p. 2)