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Text Box: Environmental Happenings
Text Box: In correspondence dated March 5, 2009, the USEPA expressed “concerns about what amounts to a 'general permit' to move contaminated soil from a CERCLA site to other non-CERCLA areas of Picatinny without notification to EPA and NJDEP.  Currently, the LUC language in RODs and RDs generally stipulates notification to regulators when construction activities take place and soil is disturbed or removed from the site. If the Army is contemplating revising this policy, it must document this in the RODs and RDs for the site.” Further discussion of the Picatinny Soil Management Policy took place at the April 8, 2009 technical meeting attended by representatives of Arcadis, Picatinny, USEPA, NJDEP, the US Army Corps of Engineers, and the US Army Environmental Command. According to the meeting minutes Mr. Ted Gabel, who is the Arsenal’s Environmental Restoration Project Manager and also the PAERAB’s DoD Co-chmn., declared that Picatinny’s position would be one of

  SOIL MANAGEMENT POLICY at picatinny arsenal

 “...using CERCLA Risk as the guiding principle so that soil from a site with acceptable risk under an industrial scenario can be moved to another site where landuse (industrial) would be the same and hence the risk from the contamination would be acceptable. 


Image of Truck Dumping Soil

MNA Time Frame for Mid-Valley

The final Mid-Valley Groundwater Feasibility Study (FS) was submitted by Picatinny Arsenal  to regulators in May 2009. Groundwater in the Mid-Valley area is contaminated primarily with trichloroethene (TCE) and RDX. The area affected by TCE comprises three different plumes with concentrations of TCE up to about 100 micrograms per liter (ug/L). The RDX plume is more localized and has concentrations of up to about 80 ug/L. Both the TCE and RDX plumes affect surface water. Monitored natural attenuation (MNA) was



selected as the remedial alternative (RA) for the RDX plumes. In situ treatment using in-well aeration with MNA polishing was selected as the alternative for the TCE plumes. The extremely long period of time that is expected to be required for MNA alone to achieve cleanup levels in the southern TCE plume is part of the reason for selection of an active remedy.

In order to evaluate potential remedial alternatives estimates of the timeframes to achieve a specific cleanup level (1 ug/L for TCE and 2 ug/L for RDX based on the Federal Health Advisory Level) were


calculated as part of the FS process. Based on a series of assumptions, as detailed in the FS, the estimates of time to achieve cleanup solely through MNA are as follows:


the meeting minutes the NJDEP “took exception to this suggested policy change, because it ignores the state numbers and is based on CERCLA risk, which NJDEP does not agree with.” Furthermore, the NJDEP was apparently concerned about the movement of contaminated soil to clean sites and thus the potential creation of new contamination sites. This issue has occasionally surfaced throughout the site cleanup at Picatinny with the Army seemingly at odds with either or both agencies. For example, because soil had apparently been mistakenly removed offsite by a contractor this has inspired concern about the efficacy of the base’s soil management policies and the ability of the Arsenal to control unauthorized and inappropriate movement  of soil — both around the base and offsite. According to the meeting minutes, a representative of USAEC “...clarified that the Army would not be moving impacted soils to an unimpacted area. The intent of the soil management policy is to allow the Army to move impacted soil among similarly impacted sites to aid in future construction projects. “ The Army currently states that the proposed policy change was not accepted at the April technical meeting and that its soil management policy at the Arsenal has not changed.


However, the group in attendance at the April meeting apparently was in agreement on the use of composite sampling of soil piles and on obtaining the approval of both agencies for soil reuse in future projects. Immediately at stake are the PHS&T project and the Gun Cotton Line proposal. PHS&T soils are to be taken to the Scat Gun Site along with soil from the Gun Cotton Line. The USEPA apparently expressed concern about the relocation of soil from the PHS&T project to the Scat Gun Site “because soil from a CERCLA site is moved to an active range (currently out of EPA’s control) without a ROD.” According to the Army the USEPA did agree to the PHS&T soil reuse in an e-mail dated April 9 of 2009. This



This would be based on a policy that would not consider NJDEP numbers if risk is determined as acceptable.” According to


Northern TCE plume – approx. 20 yrs.

Southern TCE plume – approx. 85 yrs.

RDX plume – approx. 35 yrs.

Utilizing the State of New Jersey non-promulgated guidance number of 0.5 ug/L for RDX results in an even longer MNA duration. 


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