[CPEO-MEF] MUNITIONS, REGULATION: Camp Bonneville (WA) Superfund petition

[Lenny Siegel <lsiegel@cpeo.org>]

Submitted by Dvija Michael Bertish <dmb88@iinet.com>:



PUBLIC PETITION FOR PRELIMINARY ASSESSMENT

Elin Miller, Regional Administrator	
Michelle Pirzadeh, Acting Regional Administrator   February 3, 2009
United States Environmental Protection Agency, Region X
1200 Sixth Avenue, Suite 900
Seattle, WA 98101								Fax: 206-553-1809
206-553-1234

Under the authority of CERCLA Section 105 (d), as amended, the petitioner,

(Name) : Dvija Michael Bertish, Rosemere Neighborhood Association, 
Columbia Riverkeeper
(Address) : Box 61471, Vancouver WA, 98666
(Telephone Number) : 360-281-4747

We hereby request that Region X of the United States Environmental 
Protection Agency conduct a preliminary assessment of the known and 
suspected release of a hazardous substances, pollutants, or contaminants 
at the following location:

Camp Bonneville, Former US Military Installation, Clark County, WA (just 
outside Vancouver, WA)

Petitioners are affected by the [release (or) threatened release] 
because: Camp Bonneville, a surplus military property, is the subject of 
a dirty transfer from the US Dept. of Defense (DoD), to Clark County 
Government, via a non-profit "nature conservancy" known as the 
Bonneville Conservation, Restoration and Renewal Team (BCRRT). The 
property is currently under a cleanup program with supervision by 
Washington State Dept. of Ecology. EPA Region X staff are very familiar 
with the issues (both known and unknown) at the site. EPA was formerly 
involved with the clean-up project, but in an extremely rare occurrence, 
EPA opted out of the project in July 2003 citing a lack of adequate site 
assessment and a lack of collaboration on the US Army's part. Given 
various circumstances that have occurred since 2003, members of the 
public firmly believe that this project requires EPA to re-engage and 
list this site on the National Priorities List to achieve a higher level 
of oversight and to ensure public health and safety. As a former member 
of the Camp Bonneville Restoration Advisory Board, the petitioner is 
very concerned about ongoing groundwater contamination that has not been 
successfully mitigated. Landfill 4 was evacuated - military ordnance and 
great amounts of soil were removed and clean fill replaced. Ecology 
stated clearly that post evacuation increases in groundwater contaminant 
levels would indicate additional (unidentified) sources. Ammonium 
perchlorate concentrations have increased to above 500 ppb, and there 
are additional concerns with TCE, and RDX. RDX has a 100 year lifespan 
in the environment. The groundwater contamination plume abuts and flows 
toward Lacamas Creek, a salmon bearing stream that feeds into Lacamas 
Lake, and then into the Columbia River. Lacamas Creek flows through the 
heart of Camp Bonneville, including the Central Valley Floor where new 
pollutant discoveries have been made since the project ensued. The 
surrounding residents all use well water as their potable water supply, 
however the water on site is unsafe for human consumption. The site 
exists within the EPA designated Troutdale Sole Source Aquifer System, 
and petitioners are concerned that federal dollars being expended on 
this project are not being used to sufficiently protect against further 
damage to the vulnerable aquifer system and offsite migration of 
contamination. Since there is a direct federal funding nexus to the 
project, the petitioners request EPA to invoke its jurisdiction citing 
Sole Source Aquifer designation in order to evaluate these concerns, as 
there appears to have been insufficient containment and monitoring 
(placement of monitoring wells).

Faulty site characterization has long been a problem on this project, 
and since clean-up activity began, there have been at least 9+ new 
Area's of Concern (AOC) identified. The new AOCs include new firing 
points, burial pits and practice ranges. Despite public comments 
regarding the probability of 155 mm Howitzer's being armed and fired on 
site, officials denied this concern, only to discover and detonate a 
Howitzer in the Central Target Impact Area in May of 2007. The find was 
near existing residential neighborhoods that were apparently built 
directly over the firing fans for this kind of projectile. Petitioners 
understand that the Army Corps of Engineers and/or the Dept. of Defense 
advised neighboring residences on the periphery of the site not to dig a 
pond or drive stakes into the ground on their own properties, however, 
there has been no additional planning to evaluate this public safety 
concern. In a January 12, 2009 letter from Baker Engineering & Energy 
(subcontractor) to BCRRT, Ecology's comments on the Draft Cleanup Action 
Plan include: "It is apparent from MEC data collected at the CVF 
[Central Valley Floor] that MEC types and distributions as well as their 
corresponding Explosive Hazard Rankings developed for Maneuver and 
Training areas need to be re-evaluated. The findings completely 
discredit the prevailing concept in the RI/FS that maneuver areas have 
negligible explosion hazard risks." Ecology also states: "Based on 
current available field data it is obvious that the selected cleanup 
actions for Maneuver areas, especially within the Regional Park, fall 
short of protectiveness in terms of long-term effectiveness. A more 
protective action should take into account surface contamination, and in 
some areas, subsurface contamination as well." In response to Ecology's 
concerns, BCRRT staff seems to indicate that risk from new anomalies is 
"unlikely," and that more empirical data is required to determine if the 
threat is real. The public insists that the project is well beyond the 
need to prove whether the threat is real or valid. Various parties of 
record were denied the opportunity to offer scoping comments on the 
supplemental RI/FS. To date, the public has not seen a supplemental 
RI/FS to offer public comment, even though cleanup activity is 
presumably still underway. Petitioners voiced concern through the RI/FS 
process that the site was inadequately characterized, and that such data 
gaps would elevate risk assessment for the intended re-use of the site 
as a public park and overnight campground, but these concerns were 
ignored or rebuffed by officials running the project.

In a January 31, 2009 Columbian Article [Army Contests Camp Bonneville 
Costs; Contractor defends dubious expenses, including large bar tabs], 
the BCRRT contractor, Mike Gage, states that BCRRT "[has] found several 
things on-site that we believe are Army-retained conditions that they 
did not disclose to us." It has now been publicly acknowledged by the 
contractor that the federal funds budgeted to this project are 
insufficient to achieve cleanup standards necessary for the intended 
re-use, and the contractor will be seeking additional federal funding to 
cover the data gaps that were pointed out by EPA and the public prior to 
the inception of this project. The Columbian article continues with 
descriptions of misappropriated federal funds from the project expense 
records, a lack of oversight between Clark County and the contractor, 
and the contractor claiming that the project is a private contract that 
allows him to spend federal cleanup dollars as he so chooses without 
oversight. In published responses to the Columbian Article, the public 
perceives these developments as project mismanagement, collusion, and 
greed.

It is important for EPA to list this site on the National Priorities 
List simply because the public needs better federal oversight to ensure 
that the clean-up standards are achieved for optimum risk assessment to 
protect the public health and safety on this project. Superfund listing 
would provide additional oversight and would require de-listing prior to 
release of the site for re-use implementation. The petitioners firmly 
believe this layer of protection is necessary due to unmitigated 
circumstances at the site. Clark County officials have openly stated 
that conditions on this site allow for an "acceptable risk" for the 
intended re-use as a public park, a position that many people from the 
public vehemently oppose. Institutional controls call for MEC to remain 
on site in perpetuity, to be cordoned off by a three strand barbed wire 
fence adjacent to planned public recreation facilities. Many members of 
the public have argued that Camp Bonneville is unsuitable for a public 
park and that they would never bring their children to the site. This 
public perception is detrimental to the public's interest in this 
project, especially in light of financial shortfalls currently forecast. 
The EPA would be better suited to manage additional federal resources 
and what's left of the current operating budget since financial 
oversight and accountability are lacking. It appears that Ecology is in 
need of assistance to bring clean-up standards to bear under CERCLA and 
MTCA regulations given the new discoveries.

Given that Camp Bonneville is a precedent setting project that sets an 
example for other military clean-ups of its kind, it is imperative that 
EPA help to establish improved protocols in order to protect other 
communities around the nation from experiencing the depth of confusion 
and largesse experienced on the ground in Clark County. The protocols 
noted in a Dept. of Defense/EPA document entitled "Management Principals 
for Implementing Response Actions at Closed, Transferring, or 
Transferred Ranges," clearly outline intended practices, including 
collaboration between EPA and DoD, that have been absent from Camp 
Bonneville's active clean-up. The petitioners hope that EPA can 
re-energize these much needed protocols and apply them with due 
diligence to Camp Bonneville's restoration efforts.

Type or characteristics of the substance(s) involved: Ammonium 
Perchlorate, Trichloroethane, Dichloroethene, 
Cyclotrimethylenetrinitramine (RDX), HMX, Lead, Chromium, Mercury and 
others. An extensive list of Militarized Ordnance including mortars, 
missiles, grenades, chemical warfare agents, and unknown contaminants 
located in new burial pits. Potential for radioactive materials.
Nature and history of any activities that have occurred regarding the 
release/threatened release: The sources of contamination are military 
landfills, target impact areas, firing ranges, burial pits and open burn 
pits, and documented groundwater contamination.

Federal, State and local authorities you have contacted about the 
release/threatened release and the response, if any: Washington State 
Dept. of Ecology, Barry Rogowski, Tim Nord, Ben Forson, Greg Johnson, 
Dawn Hooper; Martha Lentz, Sole Source Program, EPA Region X; Jonnie 
Hyde, Clark County Health Dept; Nancy Harney and Harry Craig, EPA Region 
X; Steve Stuart and Marc Boldt, Clark County Commissioners. Bill Barron, 
Clark County Administrator. Bill O'Donnell, US Dept. of Defense, 
Pentagon. Katherine Hanks, Environmental Health Scientist, Agency for 
Toxic Substances and Disease Registry; Jeroen Kok, Clark County Parks 
and Recreation; Pete Capell and Jerry Barnett, Clark County Public 
Works; Mike Gage, BCRRT Contractor; Taylor Aalvik and Nathan Reynolds, 
Cowlitz Tribe; Ed Marshman, FBI Portland, OR; Vancouver Fire Department 
District 5; Washington Department of Natural Resources; 
Camas/Washougal/Woodland Veterans of Foreign Wars and Veterans 
Administration Land Acquisitions, Willamette Cemetery Portland, OR; Gary 
Lucas, Clark County Sheriff; Department of Toxic Substances Bureau, San 
Francisco; Earl Blumenauer, Oregon Congressman; Brian Baird, Washington 
Congressman; Patty Murray and Maria Cantwell, Washington Senators; 
Governor Christine Gregoire, Washington.



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