|From:||CPEO Moderator <firstname.lastname@example.org>|
|Date:||Thu, 30 Nov 2000 13:52:25 -0800 (PST)|
|Subject:||[CPEO-MEF] Mitretek Study Use of Stockpile Facilities for Non-Stockpile Chemical|
[This was posted to the list by Cal Baier-Anderson, <email@example.com>] Hi Lenny- Attached is a letter which we sent to the US Army Program Manager for Chemical Demilitarization which conveys our comments on a study by Mitretek on the feasibility of using stockpile facilities for the destruction of non-stockpile chemical materiel. These comments focus on the situation at Aberdeen Proving Ground (MD). We would appreciate it if you would post these on CPEO. A copy of the document summary, prepared by University of Maryland for the community, is also available on request. cal _____________________________ Cal Baier-Anderson, PhD University of Maryland, Program in Toxicology 100 N. Greene Street Baltimore, Maryland, 21201 Office Phone: 410-706-1767 Office Fax: 410-706-6203 _____________________________ Mr. James L. Bacon US Army Program Manager for Chemical Demilitarization Building E4585, ATTN: SFAE-CD-P Aberdeen Proving Ground, MD 21010-4005 November 27, 2000 Dear Mr. Bacon: The Aberdeen Proving Ground Superfund Citizens Coalition (APGSCC) is an organization that was formed to work with the Aberdeen Proving Ground (APG) in the cleanup of its hazardous waste sites. There are two designated Superfund sites at APG, with more than 300 individual contaminated areas. For more than a decade, we have monitored the cleanup of these contaminated sites and worked closely with the APG Installation Restoration Program (IRP) to address contamination issues. We would like to begin by thanking you for the opportunity to review the "Assessment of Using Stockpile Disposal Facilities to Process Selected Non-Stockpile Chemical Materiel". After careful consideration, we present the following comments. Please note that our comments are restricted to the situation at Aberdeen Proving Ground. COMMENT 1: The letter issued to "Stakeholders" on June 1, 2000 and signed by James L. Bacon, requested comment on the use of stockpile facilities for the destruction of non-stockpile CWM. At APG, the stockpile facility, which is under construction, is the Aberdeen Chemical Agent Disposal Facility (ABCDF). There was absolutely no mention of either the Chemical Transfer Facility (CTF) at APG, or the Chemical Agent Munitions Disposal Facility (CAMDS) at the Deseret Chemical Depot, Utah in this letter, yet both of these facilities were included in the study. How were the "stakeholders" supposed to comment on the study, when they were misinformed regarding the scope of the study? COMMENT 2: The Army requested Mitretek to evaluate the use of stockpile facilities to destroy non-stockpile CWM. This original mandate is fundamentally flawed because it ignores the question as to whether there are existing alternatives to using stockpile facilities for the destruction of non-stockpile CWM. The question of the technical feasibility of using stockpile facilities for this purpose could in fact be moot. The scope of Mitretek's study exceeded this original request by including additional facilities that are not part of the stockpile program. Once Mitretek decided to extend its evaluation beyond stockpile facilities, it had a responsibility to consider all of the new facilities and technologies, as they could, in theory greatly reduce, or even eliminate, the need for the use of stockpile facilities in the first place. In fact, we would welcome a study of this nature. As the report briefly notes, several facilities and technologies are, at APG, in the final stages of design/construction and testing, and should soon be available for use. For instance, there are two facilities under construction (the Prototype Detonation Test and Destruction Facility as well as the Munitions Assessment Processing System) and APG is also involved in the evaluation of the Explosive Destruction System (EDS) and Ballistic Tent and Foam. The fact that these facilities are not yet completed should not have been a deterrence to their inclusion, since the PDTDF and EDS will both be available before either the ABCDF or MAPS. COMMENT 3. APGSCC would like to know to whom the "Dear Stakeholder" letter was sent. Neither the APG Restoration Advisory Board (RAB), nor APGSCC received this letter. The RAB works very closely with APG to determine the best approach to handling of CWM at APG. The RAB should have been briefed on this subject prior to the June deadline for public comment. As the principal community organization that actively monitors and evaluates remediation efforts at APG for more than a decade, APGSCC should also have been contacted. Additionally, a public meeting should have been held to provide a comprehensive explanation as to the nature of this study. Notices should have been posted in the local and regional newspapers. In the absence of these efforts, there is absolutely no basis to comment on public acceptance. APGSCC finds the conclusion that public acceptance of the use of the CTF is "high" to be unacceptable and mystifying, since no one was informed that it was being considered for such use. The statements regarding public outlook must be retracted until the community receives a comprehensive briefing and will thus be in a position to offer educated opinions. COMMENT 4: The question as to how best to destroy the non-stockpile CWM is extremely complex. It hinges not only on the number and nature of the items, but a complete assessment of all facilities and technologies, either currently available or under development, and their potential for use at each facility. This simplistic report is a disservice to Congress, the Army and the community, in that it pre-selects remedies without a comprehensive assessment of all available options. The report appears, in the case of APG, to manufacture public acceptance, when there was no meaningful effort to inform the public as to the complex issues at hand. COMMENT 5: APGSCC stands firmly against the use of stockpile facility, ABCDF, to dispose of non-explosive mustard-filled rounds from the non-stockpile program. The community was repeatedly told that only stockpile inventory would be destroyed in this facility. To use it for the disposal of non-stockpile items is a breech of the public trust. COMMENT 6: APGSCC supports the use of the CTF for the disposal of non-explosive CWM-filled rounds. However, this decision should be viewed within the context of a comprehensive assessment of the CWM destruction capabilities at APG. This assessment must include all facilities and technologies under construction, development, testing or consideration. The PDTDF, MAPS, EDS, explosive containment "bang" boxes and Ballistic Tent and Foam must be evaluated in terms of technical feasibility as well as current and projected need. COMMENT 7: MAPS is a very expensive facility that could increase CWM destruction capacity beyond the needs of APG, which may lead the DoD to consider its use for the destruction of out-of-state CWM in order to justify its cost. We strongly oppose the importation of non-stockpile CWM for destruction at APG. Since the DoD prohibits the use of DERA funds to search for and remove UXO/CWM it is unlikely that APG will uncover significant numbers of explosive chemical-filled rounds. APGSCC strongly believes that MAPS should not be built unless the Army commits to an aggressive excavation of UXO/CWM at APG. COMMENT 8: Mitretek must retract statements regarding public support until the community has been fully briefed and advised on the complete proposal. We recommend that this be accomplished by holding a well-publicized public meeting. Advertising for the meeting should include a public notice submitted to local and regional papers. We would welcome the opportunity to discuss these comments. If you have any questions, please contact us through our technical advisor, Dr. Cal Baier-Anderson, University of Maryland, Baltimore, Program in Toxicology, (410) 535-9598, firstname.lastname@example.org. Sincerely, Christine M. Grochowski Aberdeen Proving Ground Restoration Advisory Board Community Co-Chair 435 Acadia Drive Joppa, MD 21085 Susan C. Rice Treasurer, APGSCC 517A Trimble Road, Joppa, MD 21085 Cc: Mitretek Systems, Inc Kenneth Stachiw, Director, APG Installation Restoration Program Senator Paul S. Sarbanes Senator Barbara Mikulski Representative Wayne T. Gilchrist Representative Robert L. Ehrlich Jane T. Nishida, Secretary, Maryland Department of the Environment Bradley Campbell, Administrator, US EPA Region 3 Steve Hirsh, US EPA Remedial Project Manager James Harkins, Harford County Executive ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ You can find archived listserve messages on the CPEO website at http://www.cpeo.org/lists/index.html. If this email has been forwarded to you and you'd like to subscribe, please send a message to: email@example.com ___________________________________________________________ T O P I C A http://www.topica.com/t/17 Newsletters, Tips and Discussions on Your Favorite Topics
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