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Text Box: Volume 8, issue    3

In correspondence dated August 6, 2009  the USEPA  responded to Army comments submitted July 20, 2009 concerning EPA comments on the PICA 001 Feasibility Study. Many of these comments had been resolved with the settlement of the Mid-Valley dispute and with the promulgation of NJ soil standards. The Army’s July 20, 2009 comments were approved by the USEPA with the exception of the Army’s response to BTAG (Biological Technical Assistance Group)


comment number 8 concerning ecological issues. 


The USEPA justified this exception with the statement that “there are significant uncertainties with field investigations (bird nesting survey and  rodent sperm analysis.)”


The USEPA noted that the

predominantly terrestrial species

used in ecological receptor


studies were not an appropriate representation of what would be exposed to the contamination.” They further noted that the bird nesting surveys focused on species whose diet had the greatest exposure to soil. Because of these deficiencies the USEPA concluded that field investigations may not be suitable for evaluation of sediment. The USEPA reports that the Phase III and Phase I 2A/3A Sites Baseline Risk Assessment states that lead and PCBs in sediment




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semi-consolidated sediments, layer 2 appears  typical of saturated sediments and may represent moderately weathered/fractured rock in places.” Layer 3 was identified as being typical of slightly weathered to unweathered bedrock.  The three layer model was developed from the refraction survey.


The subject work plan is intended to test a revised CSM for the southern portion of the TCE plume:


  The geophysical review


and results of the pre-design investigation suggest that the southern TCE plume in Mid-Valley is a bedrock plume, located both within highly weathered bedrock and competent fractured bedrock and centered along Robinson Run through the central portion of Mid-Valley. At higher elevations within Mid-valley, the weathered bedrock zone is located in the unsaturated zone, and the TCE plume exists within shallow competent fractured bedrock. Additionally, the thickness of the weathered bedrock

zone may be related to the Mount Hope fault, which parallels Robinson



Run in locations and may in part control deep groundwater flow.” 


The reason it is so important to resolve the discrepancies is that

the “hydrogeological properties of weathered bedrock can be quite different from channel fill and could preclude implementation of the preferred recirculation well and in-well stripping remedy proposed in the 2009 Final FS.” Additional monitoring wells, borings, and sampling will be utilized in the investigation. As for the upgradient investigation, to determine the upgradient


extent of elevated TCE, additional borings and monitoring wells will be installed between Monitoring Well 171MW-2 and Building 3109 (identified as a potential former source area for the southern TCE plume).


The spring 2009 study included analysis of four surface-water samples collected from Robinson Run which resulted in a detection of RDX. The maximum RDX



A recent US Fish and Wildlife Service (USFWS) advisory reports that bog turtles are being affected by an unknown agent in New Jersey, New York, Massachusetts, and Pennsylvania. Bog turtle habitats exist on Picatinny Arsenal. The USFWS has

asked for the voluntary cooperation of bog turtle surveyors and researchers to submit fresh-dead bog turtles, carcasses, and shells to either Federal (fresh-dead) or State agencies (carcasses and shells) and to document occurrences of affected bog turtles. Dead and diseased turtles have been

reported in several areas in the northeast US. Affected turtles exhibit a grayish or whitish substance or discoloration.  Bog turtles are already a listed endangered species. In recent months the Indiana bat, which also makes its home at Picatinny Arsenal, has

been affected with a fungus that has resulted in high mortality to the bat populations.

are of greatest concern and may be a source of contamination to Green Pond Brook and therefore, further evaluation of this site should be conducted. A response has not yet been provided by the Army. However, if additional investigation involving wildlife studies is required then further progress on the PICA 001 site may be delayed - unless those studies can be conducted concurrently with other PICA 001 activities. It is uncertain what impact the impending winter season will have on such wildlife studies.

Image of Turtle
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