2002 CPEO Military List Archive

From: CPEO Moderator <cpeo@cpeo.org>
Date: 28 Oct 2002 21:08:45 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] letter to Whitman
The following letter was sent to the US EPA Administrator, Christine
Todd Whitman, from the President of the Aberdeen Proving Ground
Superfund Citizens (APGSCC), Glenda Bowling.


October 24, 2002

Christine Todd Whitman
Administrator, US Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue NW
Washington, DC 20460

Dear Ms. Whitman:

The chemical perchlorate has been detected in seven of the eleven City
of Aberdeen Production (CAP) wells that straddle the boundary of
Aberdeen Proving Ground in Maryland. Since July 2002 the detected
concentrations in the wells have ranged from 0.55 to 5 ppb. Although the
concentrations of perchlorate in the finished water do not currently
exceed the State of Maryland health advisory limit of 1 ppb (1), there
is now clear evidence that there is perchlorate in the finished water at
concentrations ranging from 0.61 to 1 ppb. We at Aberdeen Proving Ground
Superfund Citizens Coalition (APGSCC) believe that there is clear
consensus that sufficient scientific data exists to justify immediate
action to protect human health. We are now concerned that the delay in
action will result in unnecessary human exposures.

The perchlorate is thought to derive from historic and current training
activities in the vicinity of Camp Stanton, Aberdeen Proving Ground,
although no single incident or source location can be pinpointed.  Given
the complexity of the aquifer in the Aberdeen Area and the extent of the
contamination it is difficult to predict if and when well concentrations
will increase. Thus, we are faced with a completed exposure pathway and
are relying solely on dilution to protect the health of local citizens.
APGSCC believes this is unacceptable.

Despite consensus at the local level that the perchlorate issue must be
addressed, it is the current policy of the Department of Defense to
oppose action to remediate perchlorate contamination in the absence of
enforceable standards (2). It is our understanding that both EPA Region
III and the state of Maryland are reviewing options to insure that APG
addresses this contamination.

We have specifically recommended the implementation of an emergency
interim remedial action. This action must include the installation of
temporary, portable treatment systems on each CAP well containing
perchlorate contamination. This should be followed by the installation
of a permanent treatment system to treat all CAP wells.  We have
petitioned both EPA and the state to use the regulatory powers
established by CERCLA and SDWA to require APG to undertake an immediate
interim remedial action. Such action would serve to ensure the
protection of public health.

We have been told that EPA and MDE have been reviewing enforcement
options for over three weeks. While we appreciate that it is essential
to produce the necessary legal justification for action in the
administrative record, we are concerned that the delay in action is
sending the wrong message to the DOD.

The residents of the City of Aberdeen need your leadership in addressing
this issue. APGSCC has been involved in the oversight of the Superfund
cleanup process at APG for more than a decade. Given the history of APG
and the lessons we learned from the unnecessary public exposures to
trichloroethylene in the adjacent Perryman well field, we need to be
more proactive in our response to this latest threat.

Thank you for your time and attention on this important matter. We look
forward to discussing this issue further at your earliest convenience. I
may be contacted at (410) 272-5925.  APGSCC?s technical advisor, Dr. Cal
Baier-Anderson, from the University of Maryland, Baltimore, can be
reached at her home office, (410) 535-9598.


Glenda Bowling
President, APGSCC
198 Sunnyside Drive
Aberdeen, Maryland 21001

 (1) Letter from Robert M. Summers, Director, Water Management
Administration, Maryland Department of the Environment to Peter A.
Dacey, City Manager, City of Aberdeen, Maryland, dated August 20, 2002.

(2) Memorandum for Deputy Assistant Secretary of the Army (Environment,
Safety, and Occupational Health) Deputy Assistant Secretary of the Navy
(Environment) Deputy Assistant Secretary of the Air Force (Environment,
Safety, and Occupational Health) Staff Director, Environment and Safety,
Defense Logistics Agency Support Services (DSS-E). Subject: Interim
Guidance on Sampling for Ammonium Perchlorate Contamination, Signed by
John Paul Woodley, Jr., Assistant Deputy Under Secretary of Defense

Donald S. Welch, EPA Region III, Regional Administrator
Steven Hirsh, EPA Region III, Remedial Project Manager
Frank Vavra, EPA Region III, Remedial Project Manager
Richard F. Pecora, Secretary, Maryland Department of the Environment
Richard Collins, Director, Hazardous Waste Division, Maryland Department
of the Environment

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