Page 9 of the PAERAB's Summer 2009 TAPP Contractor Newsletter

Text Box: Register on-line at www.itrcweb.org/ibt.asp. The USEPA Technology Innovation Program has internet courses scheduled as follows:

Text Box: “Green Remediation: Applying Strategies in the Field – Session 2 of 3,” November 12, 2009 from 1 to 3 pm “Green Remediation: Applying Strategies in the Field – Session 3 of

3,” December 15, 2009 from 1 to 3 pm

Internet courses may be archived at the respective websites for reference at the user’s convenience.

Text Box: The USEPA in correspondence dated July 8, 2009 determined that the 2008 Annual Land Use Certification Report is acceptable — with the condition

Text Box: that the three following corrective actions also be implemented: Reinstall missing sign at Site 183 stating “digging is not permitted”

Text Box: Repair one LUC sign at Site 25/26 Reinstall missing sign along Green Pond Brook stating “no fishing”

ANNUAL LAND USE CERTIFICATION OKAY

Text Box: On July 6, 2009 the USEPA sent the following confirmation to the Army: “EPA is pleased to inform the Army that the formal dispute raised by EPA over the Mid-Valley Groundwater Feasibility Study (FS) is over. EPA originally invoked dispute resolution over the FS due to our different approaches in addressing contaminated groundwater and

Text Box: surface water. Since the meeting of the Dispute Resolution Committee held on July 24, 2008 our respective staffs have worked on compromise language in the FS that would be satisfactory to both parties. Compromise language for the FS was approved by EPA in an April 15, 2009 e-mail from Ms. Carpenter, Chief, Special Projects Branch to Mr. Daniels,

Text Box: Chief of the Cleanup Division of the Army Environmental Command and a revised FS containing those revisions was received by this office on May 12, 2009. That being the case, EPA approves the Mid-Valley Groundwater FS and looks forward to the implementation of the remedy.” A number of sites were pending further action based on satisfactory resolution of the dispute.

MID-VALLEY DISPUTE LAID TO REST

parameters and/or monitoring

frequency for the sentinel wells. The RAB does not want to see monitoring of the sentinel wells discontinued prematurely given the potential for future intensive groundwater development in the southern boundary area. The RAB would also like to request that changes in groundwater usage in the area (i.e., the addition or subtraction of permitted groundwater withdrawal wells and/or changes in groundwater withdrawal volume) be considered at the time of each sampling event as part of the long-term

monitoring plan.

EPA Comment: Page 2-8, Section

2.3, 3^rd paragraph: The first sentence says:

‘“Long-term monitoring of the selected analytes will be terminated once the chemical-specific ARARs have been achieved, two years of semi-annual sampling have been performed, and statistical evaluation of the data indicates concentrations are decreasing over time.”

It is recommended that chemical-specific ARARs be achieved for all two years of semi-annual sampling (four rounds) before the decision is made to ceasing monitoring these constituents. This larger data set would help to insure that the plume for these constituents is actually decreasing and not just temporarily migrating away from selected

monitoring wells, especially as this is a sampling plan for the downgradient edge of the Picatinny site.’

In a document dated August 6, 2009 the Army responded with the following:

“...chemical-specific ARARs will be achieved for all two years of semi-annual sampling (four rounds) before a decision is made to cease monitoring these constituents.”

The Army/Arcadis assert that the NJDEP’s comments were discussed and resolved at the 9/17/2009 meeting and that the EPA approved the Remedial Design Workplan as per its 9/23/2009 letter.

AREA C REMEDIAL DESIGN CONTINUED FROM P. 2