Lead and CERCLA

[Lenny Siegel <lsiegel@cpeo.org>]

Laura Olah's response to Bill Smith

Hi Bill,
According to the Army's October 1994 Environmental Update newsletter,
Twin Cities Army Ammunition Plant in Minnesota was required to clean up
10 acres of soil that was contaminated with lead and other heavy metals
from "years of open burning/open detonation of munitions". The TCAAP
cleanup was done to meet permit requirements under RCRA AND to satisfy a
"Federal Facilities Agreement (under Superfund) between the Army, EPA,
and Minnesota Pollution Control Agency". [The reference to Superfund
was cited in the article and was in parentheses in the original text.]
Soil Washing was the cleanup method; this required excavation and
cleansing of contaminated soils.

Also, at Badger AAP, here in Wisconsin, an area known as the "Race Track
Area" was similarly contaminated from OB/OD activities, however we're a
RCRA, not a CERCLA site. Have a call in to State regulators to
confirm under what authority cleanup was conducted. Soils were
excavated and taken to a licensed facility (a landfill)?

Sidenote: At GOCO facilities (Government-Owned, Contractor-Operated)
AAP's the Army has historically and routinely accepted liability for
their contractors' environmental bumbling. (Lenny posted a summary of a
GAO report that documented this.)

Hope this is helpful.

Laura