1

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.

2

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

3

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

4

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

5

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

6

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.

7

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

8

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.

9

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

10

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

11

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.

12

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=rss_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=xyphWYQZmFM9FBfJ6wf6QQppnQWV21Lx7bcDJv5xQgJnphmkcFHF!-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

13

Appendix

14

Running head: [SHORTENED TITLE UP TO 50 CHARACTERS] 15

Running head: [SHORTENED TITLE UP TO 50 CHARACTERS] 16

17

18

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.