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Natural Resources Defense Council, Inc.
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212 949-0049 Office Washington Office STREET 1350 NEW YORK AVENLE. N.W CALIF. 94108 SUITE 300
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CONFIDENTIAL ae
1 October 1985
Mr. David Cantor State House, Suite 330 Trenton, NJ 08625
Dear David:
As promised, I have examined the information you provided about contamination of groundwater arising from military hazardous waste disposal at the Lakehurst Naval Air Engineering Center. As you know, many of the substances detected at the facility may pose unacceptable long-term health risks to humans if ingested over a lifetime at reported concentrations. A presumption of unacceptable health risk is, therefore, appropriate in the absence of reasonably complete information describing the nature and degree of potential exposure risks. This letter sets forth issues which must be addressed to adequately characterize risks that may be associated with concentration levels of substances reported in the groundwater underlying the Naval facility and its environs.
--1. Some substances appear to be of toxicological concern at levels actually detected; do these levels occur in water actually used for drinking purposes?
--2. Some substances, though detected at relatively low levels, appear to have been disposed of in enormous quantities (e.g., "in excess of 2500 cubic yards of benzene" within 0 to 1 mile of a population of 3000 to 10,000 people); low levels may be the harbingers of high levels;
--3. Groundwater may move at a rapid rate of 5-6 feet per day, enhancing concerns about
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ay nt OCT 15 1985
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the dynamics of groundwater movement and aquifer contamination;
--4. Although groundwater is known to move rapidly in the vicinity of the Lakehurst facility, there appears to be inadequate information about the variability and directionality of groundwater movement and soil permeability to substances of concern;
--5. Aquifer maps delineating lateral and vertical boundaries of aquifers relative to population centers and sampling sites are needed to conceptualize the extent and degree of known contamination and infer its source(s);
--6. An inventory of substances having a history of disposal at the facility, and amounts disposed, is needed to define appropriate target substances for sampling and laboratory analysis;
--7. There is a need to develop a grid for placement of monitoring wells drilled to appropriate depths;
--8. There is a need to develop a program of regular sample collection and analysis to determine and model the dynamics of contaminant movement from source(s) to receptors;
--9. A program of sampling biota and other environmental media, such as air in household basements, is needed; and
--10. There is a need to make existing data more accessible by placing it in a single document and summarizing findings to date.
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The issues set forth above briefly outline an integrated environmental assessment program. In another situation -- Love Canal, New York -- such a program was conducted under a presidential declaration of an emergency, complete with evacuation of residents, under the Federal Disaster Assistance Act (later, the Federal Emergency Management Act) at a multimillion dollar cost. Ironically, the results were less definitive than would be expected given the resources devoted to the project; the findings, had they been available earlier, would not have justified the emergency evacuation. It is important to learn from this past experience; its lesson is,
I think, that we presume to have a basis of concern in the long run, but not a basis for panic in the short run.
If I can be of further assistance in this matter, please do not hesitate to contact me. We in the Toxic Substances Project are interested in maintaining our involvement and supporting your efforts as appropriate.
Very truly yours,
[Crloe$PM Le wee
Robert A. Michaels, Ph.D. Senior Project Scientist Toxic Substances Project
RAM/gr
Publication citation
Michaels, RA. Letter of 1 October 1985, Michaels to David Cantor, regarding groundwater contamination arising from the Lakehurst [New Jersey] Naval Air Engineering Center. In: Trenton, New Jersey General Assembly Public Hearing before the Special Committee to Investigate Hazardous Waste Disposal at Military Institutions, on Potential Sources of Groundwater Contamination Posed by Hazardous Waste Disposal at the Lakehurst Naval Air Engineering Center, Appendix, pages 103-5, https://rucore.libraries.rutgers.edu/rutgers-lib/42617/PDF/1/play/, 114 pages including Appendices, 17 October 1985;