Re: Off-Base Sampling

[Dick and Jill Miller <MMS@TheMillers.com>]

Thank you, Larry (Hourcle?), for that explanation.  I don't doubt that
it has merit, but it sounds nothing like the problems which SSCOM
mounted to discourage us from daring to look beyond the base borders. 
That wasn't "expensive" or "complex"; it was "impossible".  And other
such baloney.  In fact, SSCOM never DID sign the version which permitted
it.

I think we must accept the bureaucratic problems -- and your suggestion
in that regard is a good one -- but let's also acknowledge the now
well-documented bureaucratic maneuverings.  You're not just reading it
from me, or from here.

In this regard at least, let's not further disarm the community members!

Cheers from
--Dick Miller <MMS@TheMillers.com>
  Community Member, SSCOM RAB (U.S. Army Natick Laboratories)


lhourcle wrote (Tue, 3 Aug 1999 19:24:42 -0400):
> 
> Let me try to clarify why military bases tend to be reluctant to do off site
> sampling..having been in the Air Force and DoD when the program was created.
> 
> It frankly is a bureaucratic pain.  Most of the bases I dealt with would seek
> off site information easily if the adjoining land owner was willing to
> cooperate. Many times they aren't as they don't want confirmation that their
> property is also contaminated.
> 
> The last time I checked, DoD didn't have authority to force off site
> contamination like EPA and many states.  That means...the base needs to
> condemn an easement or use another real property type action to do that.
> Suffice it to say that process has never been streamlined.  It requires for
> active installations the Army Corps or NAVFAC to do the property work. (I'm
> not sure off hand if it may be different for base closure property.
> 
> I'd suggest that if it comes up, you ask the state to use their authority and
> ask for reimbursement by the military department under 10 USC 2701 which
> allows the DoD and military departments to acquire the services of a state or
> local government on a reimbursable or other basis.  I was there for the
> creation of DSMOA and my expectation was that it would be added as an
> additional task under those agreements.
> 
> To just expect most installation personnel to figure this out puts them in
> brain overload.
> 
> --Larry
> 
> 
> ===== Original Message From Dick and Jill Miller <MMS@TheMillers.com> =====
> >Lenny Siegel wrote (Sun, 01 Aug 1999 16:36:55 -0700):
> >>
> >> A question came up today at our meeting of community members from Army
> >> Ammunition Plants. It actually applies to all military installation.
> >>
> >> Where there are indications of possible contamination migration, does
> >> the installation in your area conduct off-site sampling,  of
> >> groundwater, surface water, and/or other media?
> >> --
> >>
> >> Lenny Siegel
> >> Director, Center for Public Environmental Oversight
> >> c/o PSC, 222B View St., Mountain View, CA 94041
> >> Voice: 650/961-8918 or 650/969-1545
> >> Fax: 650/968-1126
> >> lsiegel@cpeo.org
> >> http://www.cpeo.org
> >
> >Absolutely!  Although off-base sampling can be more hassle, it often
> >will be the key to greater success in analysis and remediation.
> >
> >This question was central to our RAB community-members' original
> >"contract" -- would our work be confined to on-base or not?  Our refusal
> >to agree to that caused months of claims by the Army that we "had to do
> >so".  But our EPA and Massachusetts agency representatives saw no such
> >problems, and we held firm.  Ultimately, the Army refused to sign OUR
> >simple wording and, changing its tune, said there was no reason to
> >require such a contract anyway!  We've proceeded well without one, for
> >years.
> >
> >Our base's toxic groundwater plumes extend beyond the base, and our
> >major focus of concern is town drinking wells a mile beyond the base.
> >NOT to test off-base would be irresponsible.
> >
> >If your RAB was talked into accepting an on-base constraint while there
> >are off-base concerns, lose that constraint!  Use examples such as our
> >RAB and the one at the Massachusetts Military Reservation.  Of course,
> >which off-site locations are suitable demands some thought.  But there's
> >no reason to have the important off-base tool be defined as off-limits.
> >
> >--A. Richard Miller <MMS@TheMillers.com>
> >  Community Member, SSCOM RAB (U.S. Army Natick Laboratories)

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