Re: Such Nonsense!

[Ted Henry <thenry@umabnet.ab.umd.edu>]

Dear Don

While I strongly believe in a having a solid military force, I must not
concur with your stance. From my years in dealing with remediation at an
active base such as Aberdeen Proving Ground, I can assure you that the EPA
is not strong arming the Army into actions that compromise readiness. In
fact, CERCLA and RCRA issues are well separated, and the citizen has a
difficult time in staying informed rergarding ongoing efforts and
training. Furthermore, while I like many of the individuals I have worked
with at Region III, I still have many reservations regarding the strength
with which this federal agency oversees remediation and contamination
issues at APG. Although the EPA has become more helpful to the community
in recent years, the citizen is still clearly at a disadvantage in the
process.

While I have not had the opportunity to learn the specifics of the
case, I believe the move by EPA-Region I at the Military Reservation is an
important effort to make it clear that DOD needs to critical of its
contaminating activities, and make any and all feasible arrangements to
control environmental releases. This must be a consideration in the
design phase of testing, and I question if this takes place.

I do believe readiness is important, but leaving the power to the DOD
ranks to postpone a cease order is inappropriate for the following
reasons:

1. DOD clearly wants to do thier own overight rergarding environmental
contamination, and one can be sure that it is not because they feel the
EPA is to lax (do we need to review how 50 year old munitions are not
hazardous waste in DOD eyes)

2. If an incident gets to the point where one federal agency will tell
another that this is bad and it has to stop, then it can be assumed that
the activity of concern is hazardous, since this rarely or never happens.
Realisticly, it probably has been impacting communities for quite some
time if it reaches this point.

3. Again, the EPA does not rule the DOD with the strength it pursues
civilian issues.

4. If there is truly a case in the future where such an order hinders
readiness, than it should be shown before a panel of elected, scientific
and community representatives, and if it is really important, DOD should
be able to prepare their presentation quickly. How else will the community
know that some DOD official did not postpone a cease order just because
some general did not feel like doing the test or activity at another base
(for something less than serious readiness reasons)?

In the end, it is the EPA's task to protect community health and the
environment, and this responsibility should not be relinguished to DOD
- it is not their mandated task.

 Sincerely

Ted Henry <thenry@umabnet.ab.umd.edu>