Usepa comments on pica 001 feasibility study
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The USEPA provided comments on the PICA 001 Feasibility Study (FS) dated October 8, 2008 that was prepared by Arcadis /Army. The comments were substantive in nature and describe some fundamental issues that have come up again and again in Army documents. Several of the comments are included below as they succinctly state the USEPA’s positions on the following points: 1) classification of groundwater as a drinking water source and as a sole source aquifer, 2) CERCLA actions, 3) land use controls (LUCs) 4) soil reuse. The issue of returning groundwater to drinking water standards had come up previously at Picatinny Arsenal as had the matter of LUCs. In the past the arsenal had restricted the use of some of its own water wells and certain wells were closed. In addition, in the 1990/91 timeframe concern that RDX might have migrated into private wells inspired the precautionary supplying of bottled water by Picatinny Arsenal to several adjacent residences at the following locations: Union Turnpike, Woodport Road. To mitigate against possible harm steps were taken to connect affected residences to the Wharton municipal water system by such public officials as Rep. Dean Gallo, then the district’s congressman, and the then presiding mayors of Rockaway Twp. ( former Mayor Lombardo ) and of Wharton ( former Mayor Shupe ). Soil reuse is also a potentially critical subject. Picatinny Arsenal maintains that it has a firm handle on soil management but on at least one past project contaminated soil was removed from the base to a private residence,
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apparently in contravention of the then existing guidelines. Based on the USEPA’s observation it is possible that contaminated soil related to PICA 001 may have been inappropriately utilized. The Army / Arcadis notes that it sought and received concurrence on the soil reuse from both the USEPA and the NJDEP and that the TAPP Consultant was also notified. Michael Glaab offers the following comments : “...such a breach of established protocols can be perceived to be a clear and definitive indicator of the usefulness and value of effective land use controls in general and specifically of appropriate LUCs that regulate the use of waste soil. Obviously reasonable measures must be taken to protect our communities and those individuals employed at - or even residing at - the Arsenal from needless exposure to improperly disposed contaminated soil. As for the groundwater issue, I believe that most, if not all, of the community members of the RAB are acutely aware of the importance of safeguarding the very groundwater sources that our communities depend upon. This is one of many reasons why a representative of Morris County serves on our board. The PAERAB is cognizant of the need to assure timely remediation of the groundwater and of the need to prevent the migration of water soluble contaminants off-base.” Sole source aquifer: The USEPA in its comments referred specifically to the first sentence of the executive summary of the PICA 001 FS which cites the human health risk assessment ( HHRA ) for PICA 001 in the following statement : “The results of the updated HHRA indicate that constituents in surface, subsurface soil, sediment, surface water, and groundwater do not pose an unacceptable risk or hazard to human health under current and |
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presumed future land-use scenarios for the sites addressed in this FS.” The USEPA comment on this is as follows: ‘Risk levels are only one measure to determine whether remedial action is necessary to address contaminated groundwater. Picatinny is located over a sole source aquifer; the designation does confer at least a Class IIA current source of drinking water groundwater classification. The NCP states: “EPA expects to return usable ground waters to their beneficial uses wherever practicable, within a timeframe that is reasonable given the particular circumstances of the site” (40 CFR Section 300.430(a)(1)(iii)(F)). Since all groundwater located below Picatinny is classified as a current source of drinking water, EPA expects that it will returned to drinking water quality standards within a reasonable timeframe.’ Refer to comment 6 below. Additional comments by the USEPA regarding groundwater are in reference to the latter part of the executive summary as follows: ‘Executive Summary, eleventh paragraph, page ES-4 – The third sentence states: “In addition, constituents that exceeded an LOC for subsurface soil, sediment, surface water, and/or groundwater but that were not identified as risk drivers under current and reasonably anticipated future uses were generally addressed by evaluation under Alternative SL-1SD-1 and SL-2SD-2.” Risk levels calculated based on exposure to contaminated groundwater is [sic] not the sole measure to determine whether a response action is necessary or not. The other measure is aquifer classification based on EPA Groundwater Policy. At Picatinny Arsenal all groundwater is classified as a sole source aquifer: the designation does confer at least a Class IIA current source of drinking water groundwater classification. The NCP states: “EPA expects to |
