[CPEO-MEF] Picantinny: Committed to Cleanup?

[CPEO Moderator <cpeo@cpeo.org>]

[This message was posted to the listserve by Michael Glaab, 
<michaelglaab@worldnet.att.net>.  Michael asked us to make it clear that 
this is his own opinion, not necessarily that of the Picatinny Arsenal 
Environmental Restoration Advisory Board.]

Lenny:

Your E-mail concerning the Defense Department's committment to 
environmental remediation was very interesting and sobering.

Unfortunately I cannot say with conviction that I believe that the 
DEFENSE DEPARTMENT is in fact COMMITTED TO CLEANUP.

With respect to Picatinny Arsenal, it is unclear to me just which
agency is most responsible for the deviation from what appears to
be the more environmentally responsible course.

The precedent setting challenge to the state of New Jersey's cleanup 
standards appears to have been precipitated by a reevaluation conducted 
by the USACHPPM (US Army Center for Health Promotion and Preventive 
Medicine).

Prior to their reevaluation, a remediation action for site 20/24 had 
already been agreed upon and funded. This action initially consisted of 
undertaking a removal action of contaminated soils. Principal 
contaminant appears to be PCB. However, there is also a considerable
presence of such diverse substances as lead, beryllium, barium, cobalt, 
arsenic, dioxins - and interestingly enough the strontium-90 and 
Cesium-137 isotopes. Apparently the strontium-90 isotope is in 
insufficient quantities to merit it being considered a COPEC (chemical 
of potential ecological concern). This is very fortunate
considering the following quote:

    "One of the most dangerous radioactive isotopes
    produced when a nuclear bomb explodes is
    strontium-90..."

    Chemical Principles - Masterton, Slowinski, 3rd. edition

Assuming I recollect correctly, the strontium-90 is allegedly derived 
from helicopter gauges/instrumentation.

The Environmental Office at Picatinny Arsenal had asked for and received 
the RAB's approval of the removal action. However after Mr. Lawrence 
Tannenbaum, a (Biologist) Risk Assessor in the Environmental Health Risk 
Assessment and Risk Communication Program of USACHPPM, issued his (April 
22, 1998) report the removal action was postponed and eventually 
cancelled. The RAB was informed that the earlier promulgated cleanup 
standards were inappropriate and also that the mathematical formulae 
which were used to compute risk were inapplicable and that they would 
not be used. The RAB was then asked to approve the new cleanup standards 
which were less restrictive than those of the state (NJ) and apparently 
of the EPA. It was argued that the state legislature had not properly 
promulgated its cleanup standards and that therefore the army was not 
required to conform to them. The RAB declined to approve the less 
restrictive standards.

The RAB then asked for an appraisal from the US Dept. of Health and 
Human Services - Public Health Service Agency for Toxic Substances and 
Disease Registry Div. of Health Assessment and Consultation. It was 
forthcoming and it concerns the REVISIONS to the exposure and toxicity 
assumptions (i.e. cleanup standards, averaging the degree of 
contamination over a larger area, etc.) cited in the "Addendum to the 
Phase I Remedial Investigation Human Health Assessment for Picatinny 
Arsenal"  which resulted from the USACHPPM report:

        "HEALTH CONSULTATION - Review of Picatinny
         Arsenal PCB Health Risk Assessment Assumption -
         Picatinny Arsenal
         Dover, Morris County, New Jersey
         CERCLIS NO. NJ3210020704
         January 21, 1999"

        Some statements of note in the ATSDR document
        are, on page 11:

            a.  "ATSDR does not concur with the assumptions
                 made when intermediate or acute exposures
                 and noncancer health risks are considered. The
                 PCBs in soil north and southwest of the gravel
                 pad in the western half of the grid area pose a
                 potential public health hazard ..."

            b. "No, the conclusion of 'no further action' is not
                appropriate. The PCBs in soil north and
                southwest of the gravel pad in the western half
                of the grid area pose a potential public health
                hazard on the basis of risk for immune and
                developmental effects."

Eventually the RAB decided to ask its local federal legislators to 
intercede. Our local Congressman, Rodney Frelinghuysen, publicly 
supported adherance to the state cleanup standards. To my knowledge, our 
Senators Lautenberg and Torricelli have done nothing remotely similar.

Shortly after this the EPA representative announced that he had been 
informed that his superiors had cited to him an internal memo which they 
interpreted such that the EPA would no longer oppose conformance to the 
less restrictive standards. Needless to say, this was
not helpful with the local media.

Shortly after this Sen. Torricelli sent a representative to one of our 
RAB meetings who, (Mr. Joe Tyrrell) citing the  ATSDR  concerns above, 
actually seemed to recommend "Capping" as an immediate action intended  
to avoid a short term public health hazard. He stated to the RAB that he 
would intercede with the state and federal authorities to facilitate the 
speedy approval and implementation of a
"Capping"  action and implied that there would then be real remedial 
followup action. Privately, he informed me that he intended that the 
contaminated soils even be first "Capped" and then later excavated as 
necessary. However, my contacts with environmental authorities inform me 
that this would be atypical and that they normally do not approve such 
actions. Since then neither Mr. Tyrrell nor anyone from Sen. 
Torricelli's office has been available. Telephone calls are not even 
returned.

Now the Army asserts that "Capping" a "Natural Attenuation,"  with as 
yet undefined "engineering/institutional"  controls, will be adequate to 
achieve the less restrictive cleanup levels.

Michael Glaab
Citizen Co-chairman PAERAB

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