1999 CPEO Military List Archive

From: Steven Pollack <themissinglink@eznetinc.com>
Date: Wed, 5 May 1999 10:25:01 -0700 (PDT)
Reply: cpeo-military
Subject: All Remediation Flows From Characterization
 
Inadequate characterization is a charge I hear resonating from the many
different stakeholders on this list, and from the ARC Ecology meeting I
attended, and from my own experiences at Fort Sheridan.  If the
characterization is inadequate, then all analysis which follows is muddied
and subject to plausible denial of the dangers to human health and the
environment.  Is this a strategy of see no evil on the part of the DoD?

Back to Landfill 7, the waste was never characterized through intrusive
testing.  Instead, leachate sampling was conducted, exclusively, to
determine the risks and thus the analysis of options in the FS.  Leachate
sampling is not a comprehensive assessment of the waste contained in the
landfill.  The toxic LEVELS, not the toxic constituents, were argued by
the Army to preclude the necessity of full characterization of the waste.  
In other words, the incomplete characterization of the waste from leachate
sampling was used to validate not conducting more comprehensive sampling.
And don't get the idea from this that I am making a mountain out of a
molehill, Landfill 7 is highly toxic even from the standpoint of the
leachate testing alone.

Then, in the FS, the lack of complete characterization of waste was used to
throw up a cloud of uncertainty as to the cost of excavation($36million if
typical of MSWLF, $136 million if hazardous, and $711 million if so
hazardous as to trigger land disposal restrictions) versus the known($36
million) cost of capping.

The catch 22 took effect when the Army was not called to task, initially,
for not completely characterizing the waste.  Where I got involved was when
I read the local coverage of this FS determination.  I was shocked that
there was a possibility that the waste COULD be so hazardous as to trigger
land disposal restrictions yet the determination was being made to cap
without this knowledge.  Toxic waste so hazardous as to trigger land
disposal restrictions to be left in an unlined ravine on a geologically
unstable bluff next to Lake Michigan?

This caused me to read the many environmental documents until it became
clear that this catch 22 was purposeful and was to the benefit of the lower
cost cleanup alternative.

This should be the beachhead of environmental activism.  Forcing, through
the courts if necesarry, a complete characterization as the first step to a
successful remediation.  A complete charaterization leads to a complete
cleanup.

Steven Pollack
http://www.familyjeweler.com/fortweb.htm


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