CAPE COD AGREEMENT

[Lenny Siegel <lsiegel@igc.org>]

CAPE COD AGREEMENT

The Massachusetts Military Reservation (MMR), which contains the Otis 
Air National Guard Base and Camp Edwards, has been the site of much 
recent controversy. Air Force headquarters took over management of MMR 
groundwater contamination response after it became clear that the Air 
Guard, regulatory agencies, and other government officials had let 
several plumes, affecting or threatening the area's sole source of 
drinking water, "get away." This January, the Cape Cod Times ran a 
thorough series documenting the mistakes that had been made.

More recently, we have posted a number of reports on U.S. EPA's order 
to halt live fire training exercises and to require munitions cleanup 
at Camp Edwards, an unprecedented case of human health protection being 
used to restrict routine military functions. The reason: toxic 
explosive constituents and byproducts threatening drinking water.

On the positive side, however, the Air Force and U.S. EPA have 
developed an innovative amendment to the Interagency Agreement (Federal 
Facilities Agreement) governing the cleanup of the MMR Superfund Site. 
Titled "Plume Response Decision Criteria and Schedule," this April 24, 
1997 document attempts to put groundwater cleanup back on the right 
course in two ways:

1) It presents a "Plume Response Alternatives Evaluation Matrix." For 
each of several plumes, it provides a form, modeled after Consumer 
Reports' product evaluation matrices, in which each of the major 
groundwater response alternatives is evaluated according to the nine 
criteria of the national contingency plan. Each criterion is divided 
into subsections. The matrices, which are to be completed in continuing 
consultation with the affected public, are designed to present in a 
comprehensible way what will probably be a complex set of 
decision-making trade-offs.

2) It established real-world milestones, not just deadlines for the 
submission of documents. Depending upon the remedy and stage of 
activity, those milestones may include "Initiate sampling," "Complete 
first 10 wells," or "System start-up."

It is obviously too soon to know how well these innovations will work, 
and project success depends on both the quality of technical work and 
on the substance of community participation. Hopefully, it's a case 
where the silver lining on the plumes of contamination has been 
learning better ways to conduct cleanup.

Lenny Siegel