Does the plant constitute a Should it be shut.docx
Picatinny2
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New Jersey’s Historic Superfund Site:
Picatinny Arsenal
By: Sara Chojna
Stockton University
Author Note
This report has been done in conjunction with the ENVL 4446 Remediation and Biotech class,
taught by Dr. Tait Chirenje. Most information in this report, regarding Picatinny Arsenal, has been taken
from documents published on EPA.gov website and the public documentation listed on the site profile.
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Table of Contents
TABLE OF CONTENTS 2
ABSTRACT 3
THE EVOLUTION OF CERCLA 3-5
PICATINNY ARSENAL 5
SITE INVESTIGATION AND INITIAL RECORD OF DECISION 5-7
POLLUTANTS 7-8
RI/RAS 9-10
DISCUSSION 10-11
REFERENCES 12
APPENDIX 13-18
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Abstract
Weapons manufacturing activities at the Army-operated facilities in Picatinny Arsenal have been
present in Dover and Morris County, NJ since the 1800s. Over time, these activities have led to the
contamination of groundwater, surface water, soil, and air. As a result and under the authority of CERCLA
(Comprehensive Environmental Response, Compensation, and Liability Act), the EPA has delegated that the
site’s cleanup is a national priority and human health risk must be prevented. The contaminants of concern,
Volatile Organic Compounds and various metals, have been shown to cause serious health risk to those
exposed. Under CERCLA and the Superfund Amendments Reauthorization Act (SARA), cleanup for the
most dangerous chemicals like TCE (Trichloroethylene) and Chromium VI (a known carcinogen) had been
enacted. Since the first Site Investigations started in 1989, both the Federal Gov’t and the Department of
Defense have covered the cost for the remedial actions on this site through today. Due to the excavation of
contaminated soil, and continuous groundwater monitoring, there are no serious health risks to cause public
concern. While using land-use controls to prevent human exposure to contaminants of concern, Picatinny
Arsenal has maintained its weapons development activities.
The Evolution of CERCLA
In 1962, the publication of biologist Rachel Carson’s "Silent Spring" brought national awareness to
the environmental and deadly effects of a commonly used pesticide (DDT). Seven years later, the Santa
Barbara oil spill caused a media uproar as an offshore oil drilling well had burst over 200,000 gallons of oil
through the ocean surface and onto surrounding beaches. (2) As if that wasn't enough, within that year
(1969) the Cuyahoga River had caught fire after decades of being damaged with polluted waste. Factories
were built by the dozens and industry was a top priority in Cleveland at the time. But even the citizens
helped pass a $100 million bond to clean up what they assumed was a pollution problem. (3) With all of the
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media coverage and overwhelming concerns surrounding these incidents, it is no surprise that the decade of
the 1970s had started an environmental movement.
Many organizations were formed during the 1970s, including the Natural Resource Defense Council
and Canadian born-Green Peace. President Richard Nixon declared himself the "environmental president",
and rightfully so, as he founded the EPA and signed many environmental laws including the Clean Air Act,
Clean Water Act, and the Endangered Species Act. In 1976, under President Ford’s administration, the Toxic
Substances Control Act was set forth requiring testing and reporting for specific harmful chemicals
including asbestos, radon, and lead-based paint. By 1980 the public was very concerned over the release of
hazardous substances from many abandoned waste sites. Most notably, the famous Valley of the Drums site
in Kentucky was regarded as the primary site to push CERCLA or the Comprehensive Environmental
Response, Compensation, and Liability Act. It is a 23 acre toxic waste site where 27,000 drums happened to
be buried. (8) Of course, the passing of CERCLA led to this site being on the National Priorities List.
Under CERCLA, the EPA received funding and authority to clean up sites like the Valley of the
Drums and many other seriously contaminated sites when responsible parties weren’t identified. The fund
came from a tax from a lot of the crude oil, imported petroleum, and hazardous chemical industries. Later
on, congress did not reinstate the Superfund taxes due to much Republican opposition. Because of this, the
clean-up money came from General Revenue which was a controversial way of paying in itself. In short,
industries did not have to pay such taxes and, even though this hindered the act in many ways, CERCLA
still provided many beneficial provisions. Several provisions of this act include a ranking system (such as a
National Priorities Listed site), a list of sites eligible for Superfund, a detailed contingency plan for
assessing a site for human health hazards, and a record of decision that details how the site is to be
remediated. (3) The most penalizing provision of this act is joint and several liability, which forces the
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generator of the waste, including each individual affiliated with the site’s contamination, to pay for the
entire cost of clean-up.
The Superfund Amendments and Reauthorization Act (SARA) provided an additional $8.5 billion
for cleanup of sites and accelerated the time for clean ups while including concrete remediation practices.
EPA was also allowed to enforce such acceleration and remediation practices for DOD and DOE
government facilities.
Picatinny Arsenal
First established in 1868 for the manufacturing of black powder for iron mines, Picatinny Arsenal
(formerly Dover Powder Depot) became a famous site for the production of various munitions and high
explosives during World War I. (6) The production of artillery, pyrotechnics, and other ordnance items
increased during World War II. While being a huge contributor to the sources of munitions during the
Korean and Vietnam Wars, Picatinny is home to the country’s largest research facility dedicated to weapons
development. The federal government exercised eminent domain to relinquish it of private property
ownership and designate it for U.S Army operations. Beginning in the year 1988, Picatinny Arsenals
weapons manufacturing activity has led to public health concerns associated with VOCs and Metals that
have contaminated groundwater, as well as surface water and air. This paper displays some of the remedial
actions that have taken place since the site has been placed on the EPA’s National Priorities List for
contaminated sites.
Site Investigation and Initial Record of Decision
In 1988, the Commanding General of Picatinny Arsenal received a letter from Christopher J. Dagget,
the EPA’s regional administrator for Mid-Atlantic States. He expressed his deep concerns of the
environmental concerns at the facility and went on to accuse the site of exhibiting “chronic non-
compliance”. (7) During the same year, the House Energy and Commerce Committee’s Oversight and
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Investigations Subcommittee named Picatinny as one of 16 Federal facilities with many various violations
with respect to hazardous materials handling. (5) Following this incident, the Preliminary Assessment or
Site Investigation (non-CERCLA at the time) was conducted in 1989 by Dames & Moore. It involved 33
study sites at Picatinny Arsenal. Their goal was to define the hydrogeology at the site and assess the
potential contaminants. The SI concluded that several sites appeared to have been affected by past and
present site activities. It also showed that hazardous substances were highly probable in surface/sub-surface
soil and groundwater at concentrations that exceed chemical-specific ARARs or TBC (Applicable or
Relevant and Appropriate Requirements or To-Be-Considered Criteria). They determined that this SI called
for an additional environmental investigation of the specifics of the contamination. While the SI was
conducted from 1987 to 1989, it resulted in the EPA’s placement of the site on the Superfund program’s
National Priorities List in February 1990. Picatinny Arsenal had a Hazard Ranking Score of 42.92. The EPA
assumed the role as regulator and performed oversight of Army Corps of Engineers (ACOE) studies. The
remedial efforts and clean-up of Picatinny Arsenal as an NPL site under CERCLA was part of an
Interagency Agreement (signed in April of 1991). Interestingly, RCRA regulations also applied this site.
Following the initial SI, ERC Environmental Services Co. started conducting the Engineering
Feasibility Study (in May of 1989). It outlined the need for interim groundwater remediation at Picatinny,
which was specifically for Building 24. In addition, the DEP prepared a “Remedial Action Concept Plan”
and a Final Report, which included results from a groundwater study completed by USGS from 1986 to
1988. (4) The DEP defined a contaminant plume that consisted primarily of trichloroethylene (TCE).
Because of the cause for concern with the contamination from certain piping into Green Pond Brook,
Picatinny Arsenal elected to implement interim remedial measures (including groundwater treatment) rather
than wait until the RI/FS activities were completed by ERC Environmental Services Co.
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By the September of 1989, a Record of Decision for the cleanup of groundwater as an interim
remedial action was sent to Colonel Richard M Gilligan, Jr. Commanding Officer of the USARMY
Armament R&D Command at Picatinny Arsenal. The letter was written by William J. Muszynski who was
the Acting Regional Administrator on behalf of the EPA. This notified the Commanding Officer that the
EPA had reviewed the ERC’s Engineering Feasibility Study, Draft Record of Decision, and EAS regarding
the interim remedial action for Building 24 Contamination Plume at Picatinny Arsenal. It outlined the
contaminants of interest as Volatile Organic Compounds (VOCs) and metals.
Pollutants
The two main contaminants of concern at Picatinny Arsenal were VOCs and metals. The following
is a brief description of each of these contaminants followed by a table (Table 1-1) describing the specific
environmental and health facts associated with them.
Trichloroethylene, or TCE, resulted from plating operations at Picatinny arsenal. It is a volatile
organic compound that is commonly used as a degreasing agent in the metal working industry. Volatile
organic compounds (VOCs) are a group of chemicals that are known to easily become gases while moving
quickly through the soil and entering buildings. Many VOCs are petroleum products like gasoline,
chemicals for dry cleaning (as solvents) and industrial products. Along with TCE, there were many other
VOCs found on the site (Appendix: Pg. 17).
In addition to VOCs, many heavy metals including Chromium, Lead, and Arsenic were found at the
site. Iron was found at the largest concentrations while the second highest average concentration at the site
was Zinc (Appendix: Pg. 17). The metal in the third highest concentration, that I’ve chosen to emphasize in
this report, was Chromium. It’s most commonly used in industrial manufacturing to make various metal
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alloys such as stainless steel. It’s released into the atmosphere by metal industries such as chrome plating
and steel production.
There are two main Chromium compounds including Chromium III (naturally occurring nutrient in
the environment) and Chromium VI (a known human carcinogen) (1). Of the 1,669 National Priorities List
sites identified by the EPA, Chromium has been found in 1,127 of them.
Table 1-1
Trichloroethylene (TCE) Chromium (III and VI)
Movement in Environment: Trichloroethylene easily
partitions from soil and water to air but it is able to
break down in air by photochemical reactions. It is
known to volatilize to air easier than it undergoes
photooxidation and hydrolysis. When it leeches into
soil it is not readily degraded. It has a low to
moderate tendency or bioaccumulation.
Human Health: The main concerns are TCE toxicity
that can damage the central nervous system, immune
system, kidney, liver, male reproductive system, and
developing fetus.
Exposure: Vapor intrusion can cause vapor intrusion
through cracks in homes that are built on TCE
contaminated soil. However, the most common
human exposure is through air and water. In
connection with the exposure on Picatinny Arsenal,
workers using degreasers that contain
trichloroethylene are at the highest risk of exposure.
Movement in Environment: Chromium does not stay in
the atmosphere; rather it is deposited into the soil and
water. It can easily change compound forms in water
and soil, depending on specific conditions these media
(CrIII to CrVI). Chromium has not shown
bioaccumulation within fish populations.
Human Health: Chromium (VI) can damage the nose
and cause cancer when humans are exposed to high
levels. Ingesting it may result in anemia or damage to
the stomach or intestines. Chromium (III) is not as
harmful as it is an essential nutrient but it does target the
respiratory and immunological systems.
Exposure: Ingesting contaminated food or drinking
water or breathing contaminated workplace air can
expose you to Chromium.
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RI/RAs
Argonne National Laboratory prepared a Remedial Investigation/Feasibility Study Concept Plan
later in 1991. It identified 156 potentially contaminated sites at Picatinny Arsenal. The plan used data
gathered by previous investigations (ERC Environmental Services Co) and reviews of production records at
Picatinny Arsenal. Dames and Moore also conducted a Remedial Investigation from 1993 to 1994. The RI
concluded that, in fact, TCE was found in the groundwater of 06 Area D Groundwater, 15 Mid-Valley GW,
and Building 24 GW (01). It was also found within the surface water of 15 Mid-Valley GW. TCE appears to
be in the unconfined aquifer and semi-confine aquifer. The general flow of groundwater containing TCE in
this area was straight down. (Appendix, pg. 14) The RI also concluded that Chromium was found in the
groundwater of 01 Building 24 GW (01), the sediment of 09 Area E GW & Site 22 (09), and the soil of 03
Burning Grounds (03). The remedial actions in this paper emphasize the following areas: 15 Mid-Valley
GW and 03 Burning Grounds (03).
The public meeting for the remedial action of the Burning Grounds (Site 34) was held on February
19th
2004. Requirements for RCRA were considered in addition with CERCLA requirements for the
Burning Grounds. The “Selected Remedy” for Site 34 was Remedial Alternative 4, which included capping
with an impermeable modified asphalt pavement. This action will go on for 30 years. Soils have been
contained under an extremely low permeability engineered asphalt cap. This is up to 2 times more efficient
than regular asphalt. The cap design prevents the infiltration of metals like Chromium while controlling
erosion and the transportation of soil from the surrounding sites and drainage areas. Such remedial action
protects human health by limiting exposure and, therefore, effectively reducing risk. The estimated capital
cost was $1, 621,000 but the total worth of this remedial alternative was $1,995,000.
The public meeting for the remedial action for 15 Mid-Valley GW was held on June 21, 2012.
“Selected Remedies” for 15 Mid-Valley GW were selected as in situ Enhanced Reductive Dechlorination
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ERD (Robinson Run plume near Building 3109), Monitored Natural Attenuation (MNA), soil removal
(excavation), and LUCs. Monitored Natural Attenuation includes sampling and analysis of both
groundwater and surface water. LUC objectives for risk reduction include ensuring that no contact with
groundwater occurs by users and controlling possible changes in groundwater use at the site. These selected
remedies continue for 46 years. Groundwater contamination expected to reduce to concentrations lower than
the New Jersey Groundwater Quality Criteria. These remedies protect the human health and the
environment mainly because LUCs limit exposure. Also, exposure for site workers is limited by using
LUCs. The estimated cost of the remedies for 15 Mid-Valley GW for Response Action RDX-2 was
$1,141,000. The estimated cost of the remedies for 15 Mid-Valley GW for Response Action RDX-3 was
$2,003,000. The actual worth for RDX-2 turned out to be $1,778,577 while the actual worth for RDX-3
turned out to be $1,140,536.
It seems to be that the other alternative options for both the 15 Mid-Valley GW and Burning
Grounds were too costly for the public and the government to accept. As a prime example, excavation and
off-site disposal of contaminated soil including land-use restrictions (Alternative 8 of the Burning Grounds)
was estimated to cost over $6,000,000. Most other alternatives were not too far behind this expense.
Discussion
Picatinny Arsenal is still continuing the remedial actions for 15 sites and has not been taken off of
NPL status. Currently, activities that take place on this site consist of weapons development. I believe it
should stay this way, considering that such an activity is necessary for our nation’s security and military
readiness. Be that as it may, it is imperative that human exposure continues to stay limited and remedies
work as planned. The fourth and most recent, Post-SARA, 5-year review was completed in July 2011 and
now documented on the EPA’s website. There were no recommendations. It emphasized that the remedies
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have been functioning as planned and all contaminants have been reported under the SCL’s with the
exception of Cadmium. As for human risk, there has been no unacceptable level of exposure to the
contaminants reported. This is especially because of the continued LUCs on the site, which restrict site
access, mitigate exposure pathways, and prevent ground water from being used as drinking water.
The Superfund process worked, in this case, but the money for remedial action currently comes from
the Department of Defense’s budget. I believe that a small portion of the cleanup cost should come from the
original “Superfund”, which includes taxes on the industries manufacturing such chemicals for weapons in
the first place. Personally, I think it’d be fair to impose a 5% tax across the board. However, let us not forget
that if Picatinny Arsenal (weapons manufacturing operations) had been in compliance with regulations set
forth by the EPA back in the 1980’s, the cost for cleanup would be much lower and groundwater might be
safe to drink there.
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References
1.) Agency for Toxic Substances and Disease Registry. TOXICOLOGICAL PROFILE FOR Chromium
(September 2012). Retrieved March 02, 2016, from http://www.atsdr.cdc.gov/toxprofiles/tp7-p.pdf
2.) Corwin, M. (1989, January 28). The Oil Spill Heard ’Round The Country! Retrieved February 27,
2016, from http://www2.bren.ucsb.edu/~dhardy/1969_Santa_Barbara_Oil_Spill/Home.html
3.) Dykstra, P. (2008, December 15). History of environmental movement full of twists, turns. Retrieved
February 27, 2016, from
http://www.cnn.com/2008/TECH/science/12/10/history.environmental.movement/index.html?eref=rs
s_tech
4.) ERG Environmental and Energy Services Company (May 22, 1989). RECORD OF DECISION FOR
INTERIM GROUNDWATER REMEDIATION PLAN PICATINNY ARSENAL, NEW JERSEY
Retrieved March 03, 2016, from
https://semspub.epa.gov/src/collection/02/SC32608;jsessionid=xyphWYQZmFM9FBfJ6wf6QQppn
QWV21Lx7bcDJv5xQgJnphmkcFHF!-1624820432
5.) LaGrega, Michael D.; Buckingham, Phillip L.; and Evans, Jeffrey C. (2001). Hazardous Waste
Management, 2nd edition. New York: McGraw-Hill.
6.) Rutsch, E.S (September 1999). The Story Of Ironmaking Bloomery Forges At Picatinny Arsenal.
Retrieved March 01, 2016, from http://www.pica.army.mil/ead/cultural/docs/picatinny-
%20ironmaking_%20bloomery_%20forges.pdf
7.) Shabecoff, Phillip (June 14, 1988). Military Is Accused Of Ignoring Rules On Hazardous Waste.
Retrieved March 01, 2016, from http://www.nytimes.com/1988/06/14/science/military-is-accused-
of-ignoring-rules-on-hazardous-waste.html
8.) Toxic Legacy Revisited: Valley of the Drums, 30 years later. The Courier-Journal. Retrieved March
01, 2016, from http://courier-journal.newspapers.com/search/#query=valley+of+the+drums
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3 articles that pertain to Picatinny Arsenal:
http://www.cpeo.org/lists/military/2006/msg00641.html
http://www.amwater.com/ccr/picatinnyarsenal.pdf
http://www.paerab.us/wsb/html/view.cgi-about.html-.html
Contacts and What they said:
Bill R. (RPM): Superfund Sites take a long time because no one wants to agree on cleanup processes. Since 1991,
it’s been over 20 years since the cleanup process began. There are no human health concerns. There is a 10^ -4
probability that person exposed would contract cancer at the site (with the remedial activity selected). The State of
NJ has standard of 10 to the -6 (1/1,000,000 chance for human exposed to get cancer) for the same scenario. It
causes a lot of friction with the state’s expectations.
Doug P. (Senior RPM Manager): With respect to the Feasibility Study, it is mainly for budget cost and balancing
factors. This facility is responsible for funding of cleanup with the DOD budget. They have spent an enormous
amount of money on investigations alone.
Ted G. (Bill’s counter part): Unable to contact regarding Picatinny Arsenal.
