Text Box: A recent letter (January 6, 2006) from Ted Gabel, the Picatinny Arsenal project manager for environmental restoration, to the USEPA requested a meeting or conference call to address some issues that have been rehashed time and time again and were seemingly laid to rest several years ago. A series of communications between the Army and the NJDEP in 1999 covered some of the same ground. A letter dated August 5, 1999 from Brigadier General John Geis to Bruce Venner of the NJDEP seemed to lay out an approach that satisfied NJDEP’s requirements and was acceptable to the Army. Now some of the same ground is to be covered again with the USEPA. In addition there are new issues regarding the NJDEP’s requirement for a Classification Exception Area at the site and on the CERCLA exclusion for pesticides. An attachment to Mr. Gabel’s letter was prepared by the Army Environmental Center and laid out the “Discussion Topics with EPA at Picatinny Arsenal.” The attachment is reproduced in its entirety below. “1. Army’s use of the term “acceptable risk” versus EPA’s preference for “target risk range” when discussing risks that fall within the 1 x 10 – 4 to 1 x 10 –6 risk range. Text Box: The Army is required to select remedies that attain a degree of clean up which assures protection of human health and the environment. Unacceptable risk following the CERCLA approach is defined as risk that exceeds a risk range of 1 x 10 – 4 to 1 x 10 – 6. The Army position is risk that is identified within this risk range is acceptable and/or manageable. USEPA has commented that it prefers the use of the term “target risk range” versus the Army referring to the range in which risk is termed “acceptable”. The specific comment from USEPA references language in OSWER Directive 9355.0-30, which states “EPA uses the general 10 (-4) to 10 (-6) risk range as a target range within which the Agency strives to manage risks as part of a Superfund Clean up.” However, OSWER Directive 9355.0-69, page 8 (August 1997) references the range of 1 x 10 (-4) to 1 x 10 (-6) as the “acceptable risk range.” The statement made by USEPA, “The description of the carcinogenic risk range of 1 x 10-6 to 1 x 10-4, as unacceptable is not accurate,” seems to be inaccurate itself based on EPA’s own guidance. Text Box: OVER AND OVER AGAIN…..

POINTS OF INTEREST:

· The next RAB meeting will be held on March 30, 2006 from 6:30 to 8:30 pm at the Hilton Garden Inn in Rockaway, New Jersey.  The meeting topics will include a briefing on the Phase I and Phase II Ecological Risk Assessments and updates on the community relations plan and Installation Restoration Prorgram.  The public is welcome to attend the meetings.  For further details contact Elaine Comings at 973/724-8010.

· The report of testing in the Fall of 2005 at Pondview Estates has reportedly been submitted to the Township of Rockaway (the water allocation permit applicant).

 

Training

2

Mid-valley FS

3

Out with the old

3

Mouse study

4

 

PBC Status

4

 

Site 180

5

IAG

6

MONEY WOES

6

Text Box: The Picatinny Arsenal Environmental Restoration Advisory Board’s TAPP Contractor presents Text Box: WINTER 2006 Text Box: Volume 3, issue 1 Text Box: Environmental Happenings At Picatinny Arsenal Text Box: IN THE FIELD….. Text Box: Recent field activities for October, November, and December 2005 and January 2006 included the following: Southern Boundary Area: Groundwater sampling at the following monitoring wells: SB3 series Text Box: wells along Route 15 near the truck entrance gate, SB4 series wells at Pondview Estates, and SB1 series wells near the visitors center. (October) Area E: Groundwater sampling of various monitoring wells within Area E. (October) Text Box: Site 180: Collection of soil samples. (November) Site 148: Collection of surface soil and sediment samples from Picatinny Lake near former Building 527. (November)

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