At the January 10, 2008 technical meeting conducted by Arcadis the approach for Picatinny Lake was discussed before the group consisting of representatives of the USEPA, the NJDEP, Picatinny Arsenal, the Army Environmental Command, and the Army Corps of Engineers.  The TAPP consultant, Subsurface Solutions LLC, was present on behalf of the RAB.

Previous work at the site had focused on the preferred alternative of bioremediation to address RDX and TNT in groundwater at Area of Concern (AOC) 7.  However, at this meeting Arcadis proposed the use of Monitored Natural Attenuation (MNA) to address groundwater contamination.

Groundwater sampling results do show the presence of some degradation byproducts. These  byproducts are typically indicative of the occurrence of some natural degradation of contaminants. However, most of the apparent affect of decreasing concentration is likely due to the gradual movement of the RDX and TNT plume in to the lake – or “flushing” in to the lake.

 

 

 

 

Arcadis contended that because there are no surface water standards for RDX and TNT that there is therefore no risk and that this justifies a limited action. Such a limited action would probably incur a relatively small short-term cost. Unfortunately, such a limited action could also sacrifice the lake’s water quality and this might incur a larger long-term cost. However, Arcadis did offer a more tenable argument, if not a proven one, that bioremediation would mobilize metals in groundwater. 

Mr. Tim Llewellyn the Arcadis Project Manager provides the following explanation :“Arcadis is cognizant that surface water quality in Lake Picatinny needs to be considered. Indeed, the lake is included in Arcadis’ contract separately from PICA 079. Further, Arcadis considered the impacts to surface water before the cited technical meeting in January and Arcadis found no evidence that surface water or sediments are being impacted by groundwater discharges. Arcadis also agreed to sample surface water and sediment and provided that data during the March 2008 technical meeting. These data indicated no impacts to Picatinny Lake (surface water or sediment) resulting from groundwater discharges. It should be noted that Arcadis fully intended to complete an active remedy at this site, and initiated pre-design work, when it became clear that the concentrations had dropped substantially and an active remedy was no longer appropriate.”

 

 

According to Arcadis, analytical calculations of the impact of  “flushing” indicate that groundwater would attain a cleanup goal of 2.2 ppb for TNT in 11 years and a cleanup goal of 0.61 ppb for RDX in 9 years.  On that basis Arcadis proposes to consider MNA or no action.  The NJDEP did bring up the similarity of this area to Area D where a groundwater plume discharges to a surface water body.  In this case the lake quality seems to fall victim to a low cost “solution”   which appears to be a dilution of the pollution.

Fortunately both the USEPA and the NJDEP were present to voice objections with the NJDEP requesting that Arcadis prove no adverse impact on the lake.  The USEPA stated that the approach would not likely be accepted.

Mr. Glaab offers the following comments: “... the RAB has historically been acutely alert to water quality issues at the Arsenal. Picatinny Lake is of special concern to several board members. Indeed, this lake was a special concern of Mr. Wesley Ackerson who formerly represented Jefferson Twp. on our board. Therefore, although we would prefer it if

the principal environmental

restoration partners always cooperated amicably and never disagreed this may serve as an example of the inherent value of bringing disparate organizations with different

 

 

 

 

goals together into a conflict resolution forum

that is deliberately designed to promote their synergistic cooperation for the mutual benefit of all. In addition, the current absence of an  established surface water standard for RDX and TNT does not logically indicate that there is no unacceptable risk. It merely indicates that the appropriate agencies have not yet determined what that risk standard should be. Also RAB members have throughout the years frequently expressed a preference for the active removal of contaminants rather than for MNA which essentially involves waiting for contaminants to be degraded naturally  —  and usually slowly - by the environment .” 

On  the  shores  of  Picatinny  Lake  (PICA 079)