The Feasibility Study (FS) for PICA 001 sites was released as a draft final version in September 2009 with a title change for the document.  The FS that had been referred to as that for the PICA 001 Remedial Action Sites was reissued and denoted as the FS for PICA 011, 085, 091, 097, and 108. In accordance with Federal regulations (the NCP and CERCLA) some of the sites that are included in the document require remedial action because their risk assessment results exceeded either a threshold cancer risk level or a non-cancer hazard risk level. Other sites have been included as a result of regulatory input during extensive discussion between the Army and environmental regulators

 

 

 

about a previous version of the

document which focused on land

use control (LUC).  The sites are as follows:

 

· Site 122/PICA 011 – Satellite Waste Accumulation Area

 

· Site 149/PICA 085 – Propellant Plan (Former building 541)

 

· Site 131/PICA 091 – Building 266, Former Ordnance Manufacturing

 

· Site 118/PICA 097 – Pesticide Storage and Former Oil/Water Separator

 

· Site 138/PICA 108 – Buildings 404, 407, and 408, Chemical Lab and Propellant Plant

 

 

 

Five alternatives are proposed within the FS as follows:

 

SL-1  No action

 

SL-2  LUCs

 

SL-3  Soil cover with LUCs

 

SL-4  Asphalt cover with

           LUCs

 

SL-5  Removal and off-site disposal with LUCs

 

In regard to a favored option the report states the following: 

 

“Although it is recognized that the remedy selection does not occur until the Proposed Plan stage, this report recommends Alternative SL-5 – Removal and Off-Site Disposal with LUCs for the five sites.”

 

 

FORMER PICA 001 REMEDIAL ACTION SITES FS

On October 19, 2009 Picatinny Arsenal notified the NJDEP and the USEPA that a portion of the Apple Tree Recreational Area (Site 192) was being considered for a “dog-walk area.”  Picatinny stated that the results of the risk assessment for the site had indicated that exposures for an industrial research worker, an on-site visitor, and a residential child were “all within EPA’s risk range.”  But because there were some exceedances of NJDEP soil

standards theArmy suggestedthat a “grass cover would be an adequate engineering control for this land use.”  The USEPA requested a diagram delineating the dog pound and the walk area in reference to the arsenic contamination. Based on the diagrams that were provided by the Arsenal, the USEPA approved “the use of the Apple Tree Rec area for this use [dog walk area].” with the recommendation that

the grass be maintained in the area to prevent exposure to the arsenic-contaminated soil. The EPA also suggested installing signs around the area to restrict the digging of soil without the approval of the Environmental Affairs Office since “...the General and anyone else who uses the Apple Tree Rec Area ... should be made aware of the contaminated soil in the area.”Since then the Army has decided  to place the proposed dog-walk

The report concludes its recommendation with the following statement:

 

“Alternative SL-5 provides the optimum balance among considered alternatives with respect to the evaluation criteria and represents the most effective means of risk reduction at the sites. This alternative is implementable, effective in meeting essentially all of the RAOs, and is reasonable with respect to present-worth cost.”

 

  The RAB has generally favored permanent options such as removal over options which leave contamination in place and require extensive monitoring and/or other regulation (LUCs) in perpetuity.

site at the fenced garden area near the ball field by the front gate.

Request for reduced sampling/analysis at area D  (cont’d from p. 2)

The stable or decreasing  VOC concentrations along with geochemical conditions that “are not expected to change significantly over the course of the MNA program,” and “little seasonal variability” are the reasons

 

 

provided for reducing sampling frequencies. Michael Glaab, the PAERAB’s RAB Community Co-chmn. comments: “Ideally sampling should perhaps be quarterly for timely detection of seasonal

 

 

variations. Just sampling annually risks imposing a seasonal weather bias on data. A five year gap between samples may result in a very large delay before a potential deviating anomaly is detected.

 

 

It seems logical to sample at least frequently enough to assure useful current data for inclusion in the USEPA’s  five year reviews”.