Page 6 of the PAERAB's Summer 2009 TAPP Contractor Newsletter

the NJDEP via e-mail on June 24, 2009. The response is provided below:

Army Response: “The commenter references the bank of Green Pond Brook which is over 200 feet from the ICM area and is not applicable to the surface clearance approach being used within the ICM area.

All MEC observed on the surface in the ICM area will be removed prior to placing the soil cover. Should a large unexpected MEC burial area be discovered during field activities, the Army will determine the appropriate measures to mitigate the hazard and/or document the condition. At this time both EPA and NJDEP will be notified, we plan to keep EPA and NJDEP aware of the action as we had done with the RCI project. The condition, if not mitigated during this phase will be discussed during the RI planning stage now funded for FY 10.”

Text Box: characteristics is Site 25/26. The soil cover for Site 25/26 is already in place. Supposedly these sites will be revisited as part of the MMRP (Military Munitions Response Program). Both the USEPA and the NJDEP have stated in the past that just because a capping remedy has been approved for contaminants other than MEC does not mean that the cap is a presumptive remedy for the MEC. The NJDEP expressed just this concern in their comments (May 28, 2009) on the TCRA Work Plan. NJDEP concerns about capping MEC in the area as follows: “NJDEP has concern that the project may result in the permanent burial of a large quantity of MEC that may eventually discharge explosives and other constituents to surface and ground water. This is because the Action Memorandum notes that a large quantity of MEC was observed protruding from the bank of Green Pond Creek in the vicinity of the project. At other sites DRMO facilities have been found to be the site of large MEC burials and this

Text Box: The Time Critical Removal Action (TCRA) at the Former DRMO Yard is nearly complete as of the end of September 2009. This TCRA was initiated because of the detection of Improved Conventional Munitions (ICMs) during pre-remedial activities at the site. Due to the extremely hazardous nature of ICMs the Army proceeded with a removal action. The USEPA approved the Time Critical Removal Action Work Plan (June 2009) on June 23, 2009 with a comment as follows: “EPA has expressed concern in the past on the potential for the release of explosives to groundwater by the corrosion of munition shells. Since munitions may be located under the cap to be installed over the ICM site and elsewhere in the DRMO yard, EPA suggests that groundwater in the vicinity of the former DRMO yard be monitored for explosives.” The problem of deterioration of munitions is a widespread one and should be of special concern in areas where there is a concentration of such munitions and where the remedy is a cap. Another area that has the same

Text Box: may be the case at the Picatinny DRMO because the site hasn’t been thoroughly characterized. NJDEP understands that this is an interim action and that the final action for the site will be determined in the future. However, it would be inefficient to bury a large quantity of MEC under a cap or reconstructed wetland only to have to remove these features in the future to investigate and remove MEC if that is required by the final remedy. To prevent this NJDEP requests that Picatinny Arsenal monitor the work for the purpose of identifying large MEC burials if they are discovered during this work. In this event, NJDEP further requests that work in that area be stopped while Picatinny Arsenal informs NJDEP to evaluate whether or not it would be beneficial to remove the buried MEC prior to capping or final construction of the interim action.” The Army response is dated June 19, 2009 and was transmitted to

RDX INVESTIGATION DATA REPORT GETS OK

Mr. Richard Krauser (ERRD / PSB /TST), the hydrogeologist who reviewed the RDX Investigation Data Report (April 2009) for the USEPA concluded the following:

“Based in the data provided for the groundwater, surface water and sediment, it appears that there is a small, source of RDX on-site (in the watershed of the small pond located at the headwaters of a sampled

stream in Site 11), that the RDX is being transported within the bedrock aquifer, that the transport is through fracture flow, that fracture flow varies as a result of seasonal rainfall, and that

the varying nature of the fracture flow causes the intermittent detections. The report’s conclusion of no further action (NFA) is appropriate.”