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such large numbers of unaddressed sites is the potential spread of contamination and potential health impacts along with the diminished use of those properties. Commissioner Jackson noted the following areas in need of reform: |
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The Army issued a statement about the more recent incident that was intended for dissemination to the RAB and is provided on page 11. The following relevant guidance is in section 202.1 of Subpart A on page 27618 of Vol. 71, No. 92 of the |
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1. Licensing of environmental consultants 2. Ability of the NJDEP to select remedies |
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32 US Code of Federal Regulations (CFR) Part 202 : “…(b)Purpose and scope of responsibilities of RABs. The purpose of a RAB is to provide: … (4) A forum for addressing issues associated with environmental restoration activities under the Defense Environmental Restoration Program (DERP) at DoD installations, including activities conducted under the Military Munitions Response program (MMRP) to address unexploded ordnance, discarded military munitions, and the chemical constituents of munitions“. On page 27611 in A.202.1 Purpose, Scope, Definitions, and Applicability the |
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CONTINUED ON P. 11 |
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8. Address dry cleaning facilities As mentioned previously (see article on page 2) the effort at Picatinny Arsenal has often been plagued with delays perhaps partly due to the inability of the NJDEP to adequately staff for project oversight to meet the tremendous demand for review of documents related to the cleanup. The full text of Commissioner Jackson’s testimony can be found at http://www.nj.gov/dep
The issues discussed by NJDEP Commissioner Jackson in her April 15, 2008 testimony (discussed above) are further enumerated at http://www.nj.gov/dep/srp |
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3. Permanence of remedies 4. Finality and protection against remedy failure 5. Additional incentives for Brownfields Redevelopment |
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6. Expanded notification to local officials 7. Additional controls on underground storage tanks and financial assistance |