Background info with questions on RCRA cleanup of SFAAP

[hdqrs@worldnet.att.net]

[The following is a letter to the SFAAP EPA Cleanup manager, from Jim
Oyler]

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Background info: Sunflower Army Ammunitions Plant (SFAAP).

The contamination score for SFAAP was rated at 50 with 28.5 being the
minimum requred for SFAAP to be placed on the CERCLA NPL list. It is not
know why EPA did not require SFAAP to be placed on the NPL list to be
cleandup under CERCLA requirements.

The environmental investigation of identified contaminated sites at SFAAP
began under the Resource Conservation and Recovery Act (RCRA). That's why
the GSA EA Report on  Sunflower talks about Solid Waste Management Units
(SWMU, or "schmoos), which are a RCRA term. 

EPA has approved SFAAP as a RCRA site for cleanup with an early transfer to
the state without total cleanup.

Questions?

1. Why was SFAAP not placed on the CERCLA NPL list for CERCLA requirements
as to the early transfer and cleanup of the contamination?

2.  Has the EPA designated the state of Kansas a delegated state for RCRA
Correction Action?

3 (a). Has EPA turned over the RCRA cleanups requirements at SFAAP entirely
to state regulators?

3. (b) If not what direct oversight will EPA use in the Kansas state RCRA
cleanup of SFAAP?

4. Why did the State of Kansas want SFAAP deleted as a NPL Site (freeing
CERCLA reqirements for cleanup) Based Upon RCRA Deferral?

5. With over 150 million spent (1992 to date) at SFAAP by the Army/Hercules
what cleanup has occured at SFAAP.

6. What appropriate steps to inform the community that SFAAP is being
cleanup under RCRA rather than CERCLA have been taken?

7. Has the state and the Federal facility (SFAAP) which requested an NPL
(CERCLA) deferral documented all of their interactions with the community
and inform EPA of any possible opposition to NPL CERCLA deferral of the
SFAAP site?

Awaiting you answers.

Thanks.

Jimmie D. Oyler, Principal Chief
United Tribe of Shawnee Indians