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Text Box: Picatinny Arsenal submitted a long-term monitoring plan for Area C (June 2009).  Both NJDEP and the USEPA responded with comments to Picatinny Arsenal.  The PAERAB also provided comments.  Comments are cited below:

NJDEP Comments:  The NJDEP noted in its comments on the plan dated June 25, 2009 that 12 additional compounds should be included in the remedial action plan.  The following parameters are those required to be included by the NJDEP:

Carbon tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,2-Dichloroethene (total)
cis-1,2-Dichloroethene
1,4-Dichlorobenzene
Heptachlor epoxide
3-Nitrotoluene
Barium
Beryllium
Copper

  AREA C REMEDIAL DESIGN GETS THE ONCE-OVER

The NJDEP further noted in its comments the maximum amounts of each of the compounds detected in the Phase I Remedial Investigation (RI). Only three of these compounds (carbon tetrachloride, 1,2-dichloroethene [total], and beryllium) were indicated as exceedances on Figure 5 of the plan. The NJDEP also expressed a requirement for the plan to be made available to the board for comment.

 

RAB Comments: It is unclear why some of the compounds [as referenced by the NJDEP] were omitted from the monitoring plan.   Although theplan does note the following:

 

“Organic compounds that were sporadically detected and not confirmed in adjacent or subsequent samples were also eliminated via this criterion.” 

 

It is possible that some of the compounds were omitted based on sporadic detection, on absence of confirmation in adjacent samples, or on absence of detection in subsequent samples. However, given the sensitive location of this area it is imperative to create an all encompassing parameter list. The aquifer offsite represents the water source

 

 

 SRS VS. RISK-BASED APPROACH….AGAIN

The issue of New Jersey Soil Standards versus risk-based cleanup standards has reappeared - again. This issue has come up periodically in recent years.  NJ’s legal promulgation of several SRS (Soil Remediation Standards) in 2008 seemed to put this issue to rest.

 

 Prior to the June 2008 rulemaking the Army had refused to accept NJ’s existing soil cleanup standards for certain contaminants precisely because those standards had not been properly legally promulgated. The army deemed those standards to not be legally enforceable and therefore they were only considered guidance. However, this argument is seemingly no longer valid now that those soil cleanup standards have finally been officially  promulgated by the State of New Jersey. 

 

While the USEPA has approved three feasibility studies (FSs) – for Sites PICA 001, PICA 013, and PICA 204 – the NDEP has not approved any of them. The Army asserts that it has not yet received comments from the NJDEP concerning PICA 001. Elaborating the Army further explains that although the NJDEP has not yet provided written approval of the PICA 013 FS nor of the PICA 204 FS it has deemed them acceptable at technical meetings. Minutes of the recent September 17, 2009 technical meeting note that the NJDEP is concerned that its SRS are not being selected as cleanup levels. The NJDEP is reportedly not aware of any CERCLA sites using a risk-based approach and neglected the SRC. The USEPA reportedly offered to inquire about this matter in regard to other New Jersey CERCLA sites.

Further discussion at the meeting supposedly focused on sites with unacceptable risks.  Minutes state the following: 

 

The current approach is to remove media with contaminants of concern that drive an unacceptable risk and address any residual risks through LUCs.  Both USEPA and NJDEP expressed some hesitations with this approach and will take it into further consideration.” 

 

Further inquiry in to the matter resulted in prompt clarification on the subject from both the USEPA and the NJDEP and finally a response from Picatinny Arsenal indicating that the subject is still a matter of deliberation between the regulators and the Army.

for tens of thousands of people – while

currently not developed in immediate proximity to Picatinny Arsenal there are still plans under consideration for developing a water source for Pondview Estates (a proposed subdivision) that would also be used by Rockaway Township. Progress on the subdivision has been stalled out for years over the issue of a potable water source that is not threatened by contamination. The proximity of a major groundwater withdrawal well so close to Picatinny Arsenal raised concerns about the potential for contamination to be drawn into the capture zone of the well.

The plan contains a formulation for reducing the frequency of monitoring or eliminating monitoring based on the frequency of detection and the concentration of the compounds. While the plan appears to have numerous checks built in to assure that monitoring continues for a reasonable time period the RAB would like to be informed of any potential changes in the monitoring

 

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