DISCHARGE OF SAMPLING WATER - CREATE NO NEW CONTAMINATION

The USEPA countered with the following:

‘Arcadis's FSP states: "Pre-sample water will be containerized in a portable polyethylene tank and transported to a central storage area, secure  temporary area, or treated at the well head if analytical results for the subsurface soil samples indicate potential  contamination. If there is no indication of potential contamination, the purge water will be disposed of downgradient of the monitoring well on a grassy surface if it will not present a nuisance to day-to-day arsenal activities. The containerized purge water will be sampled and disposed of after consultation with PTP EAO."  (Section 3.6.4, e) This, I think, is fairly close to what our hydrologist was asking for. That is, due diligence before discharging groundwater onto the surface.’

There was no further reply from Picatinny but the topic did come up again at the April 8, 2009 technical meeting. It was reported that Mr. Joe Marchesani of the NJDEP summarized the NJDEP’s policy which is focused on not contaminating otherwise clean soil or aquifer materials. Based on the correspondence it appears that water may not have been handled in accordance with the FSP -but

it is unclear for how long and at which sites. To determine which sites have been affected would require a review of field sampling logs for past groundwater sampling events.

Mr. Ted Gabel provides the following comments:

‘a. Throughout the years our contractors have been observed by regulatory inspectors while sampling, while conducting environmental tests and while participating in  development construction  at the Arsenal. The activities of our contractors were observed by numerous inspectors of the USEPA

and — especially — by those of the NJDEP. None of these inspectors ever insinuated that proper procedures were not being followed or that the methods used would “create new contamination.”

b. No party — whether associated with a regulatory agency or with the Army or with a contractor — has proposed that a review of sampling logs would be necessary to determine which sites have been affected. Presumably this is because our methods have heretofore always been considered environmentally appropriate. ’   

SAMPLE COUNT RISING AT PICATINNY ARSENAL

According to the Arcadis database which includes results of environmental sampling at Picatinny,  the total number of all environmental samples related to the cleanup is

over 12,000.  The breakdown is as follows:

· 6,017 — Soil samples

· 4,598 — Groundwater                                 samples

· 988 — Sediment samples

· 824 — Surface-water                        samples

Picatinny Arsenal was placed on the National Priorities List (NPL) in 1990.