From: | Lenny Siegel <lsiegel@cpeo.org> |
Date: | Sat, 31 Jul 1999 22:58:31 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | Sunflower FOSET |
SUNFLOWER FOSET LEAVES OUT ESSENTIAL INFORMATION The Finding of Suitability for Early Transfer (FOSET) for the Sunflower Army Ammunition Plant, in Johnson County, Kansas makes a mockery of the public participation provisions of the early transfer law. Released by the Army last week, the Sunflower FOSET leaves out information that any member of the public would require to constructively comment on the proposed transfer. As anticipated, the FOSET says, "the ongoing environmental investigation and remediation of hazardous substances on the property after the transfer will be accomplished by ... Oz Entertainment Company (OEC)," which plans to develop a theme park over much of the Plant's 9,000-plus acres. However, nothing in the FOSET attests to the capability or financial capacity of Oz Entertainment to complete the cleanup - a necessity for any early transfer where the transferee assumes responsibility for remediation. For many months state and federal agencies have said that they, Oz, and private insurance companies are working on agreements establishing Oz's responsibility. But the public has not had the opportunity to see any such documents. Many times the FOSET refers to a "proposed Consent Order between KDHE [Kansas Department of Health and Environment] and Oz Entertainment Company (OEC), which has not been completed or agreed to by the respective parties It is anticipated that the Consent Order between KDHE and Oz Entertainment Company (OEC) will be obtained and provided as a separate enclosure to or along with this FOSET prior to the Final FOSET being signed and submitted to the Governor for approval." That is, the FOSET contains no description of the cleanup standards or strategies Oz will be required to follow if it takes control of the property. This consent order is not an ancillary document. It's the heart of the issue - the official cleanup plan. Without the opportunity to review the cleanup plan, members local community have no way to determine whether the early transfer will expose them or theme park visitors and workers to unacceptably high levels of toxic contamination. The health and environmental risks at Sunflower aren't just an abstract possibility. Even before redevelopment and public access were proposed, Sunflower's high level of contamination qualified the facility for the "Superfund" National Priorities List, but regulators deferred the listing. Instead, cleanup is proceeding under the Resource Conservation and Recovery Act (RCRA). According to the FOSET: "There are Fifty-Two (52) Solid Waste Management Units (SWMUs) currently identified in the 1993 RCRA Facility Investigation (RFI) at SFAAP. Two (2) additional SWMUs have been identified since the 1993 RFI. Two (2) SWMUs have been remediated. This leaves a total of Fifty-two (52) active SWMUs currently at SFAAP. The current status of the Fifty-two (52) SWMUs to date show, 11 SWMUs requiring additional sampling to fill data gaps prior to remedy selection; 6 SWMUs which can proceed to closure documentation for No Further Action (NFA); 33 SWMUs that require remedial design and remedial action; and 2 SWMUs that require Long Term Monitoring (LTM). The Fifty-two SWMUs different site types include: 5 Landfills 4 Lagoons 6 Ponds 6 Disposal Areas 5 Ditches 10 Production Areas 16 Miscellaneous" A FOSET enclosure describing each of the SWMUs not only makes it clear that the FOSET documents don't have the answers, but that the Army and its regulators are in the early stages of the remediation process for a good portion of the property. Most of the descriptions were developed before the Army's closure decision, on the assumption that the property would remain in industrial use. Without a clear idea what is required to clean up the plant, it is difficult, if not impossible, for those affected most to evaluate the proposal to turn the plant and the cleanup program over to Oz. Here are excerpts from the descriptions of five SWMUs, from that enclosure. They illustrate both the seriousness of the contamination and the need for additional study. B POND AND SLUDGE DISPOSAL AREA The Draft RFI report indicates that manganese in the groundwater is associated with noncarcinogenic risk due to potential residential exposure. There is the potential for carcinogenic risk due to nitroglycerin in groundwater. The groundwater at the site is not currently used as a drinking water source and is unlikely to be used as such in the future; therefor, no remedial action for groundwater is recommended. The risk assessment indicated that beryllium in the sludge poses cumulative carcinogenic risk to commercial/industrial workers. The risk assessment indicated that potential risk exists through exposure to Kill Creek surface water by recreational receptors. Dieldrin is the primary contributor due to ingestion of fish. It is recommended that the ponds be closed. OLD/NEW SANITARY LANDFILLS The Draft RFI report states that the primary concerns at SWMUs 18/19 are the constituents detected in groundwater (sulfide; is-1,3-dichloropropane, ammonia nitrogen) and dioxins/furans in the shallow soil. The risk assessment indicates that the contaminated groundwater at the site poses potential carcinogenic and noncarcinogenic risks to residential receptors through ingestion of groundwater and inhalation of organic constituents from groundwater. Institutional controls to provide an access restriction to the site and a groundwater monitoring program to determine the need for future action is recommended. CONTAMINATED MATERIALS BURNING GROUND Burning Ground consists of approximately four acres located in the west central portion of SFAAP. The site has been in use since 1943 to decontaminate scrap metal and to burn other combustible material that has been contaminated with explosives or propellants. Prior to 1970, burning of contaminated materials occurred in two open trenches which were approximately 15 feet deep. However, in about 1970, two unlined 30 x 300-foot pads were installed where the trenches were located. The pads are separated by an earth berm and are still in use. Contaminated material accumulates at the site until the pad is full, which generally takes approximately one to two months. Burning is initiated using diesel fuel, waste oils, and scrap wood (including telephone poles). After a burn, metal items are collected for salvage. SFAAP randomly samples the remainder of the residue for EP toxicity metals, and upon negative results disposes the ash in the sanitary landfill. After one pad is burned, the other pad begins receiving materials for the next burn. During a site visit in 1990, burn areas were observed away from the main burn pads. Also located on the site is an open top tank, approximately eight feet in diameter, which was used to burn waste solvent. Adjacent to the tank is an elevated platform which appeared to have been used as an unloading dock for liquids to be emptied into the tank. At the time of a 1992 site visit the tank appeared to contain water . Ground-water and surface water runoff from the burn area flow northwest to Captain Creek or the adjacent Oxbow Lake. Waste Generated - Combustibles, solvents, explosive and propellant residues, and metals were handled at this location. ...The draft RFI report recommends further sampling to better define extent of contamination.. PASTE AREA HALF TANKS AND SETTLING PONDS According to the Survey, the lagoons were abandoned and in disrepair. As a result, unidentified quantities of NC [nitrocellulose] and NG [nitroglycerin] were known to be in and around the lagoons. Drilling was not recommended in the area because lagoon sediment samples were demonstrated to constitute a reactivity/ignitability hazard in analysis at the SFAAP laboratory. Reportedly, overflowing of the metal flumes and half tanks most likely occurred. There was no secondary containment. Due to overgrowth, the location of the remaining Half Tanks and of the Ponds is not clear. Waste Generated - The material collected in the Half Tanks consisted of partially colloided and colloided propellant solids containing lead salts. Releases to the Settling Pond included lead salts, NC, NG and uncolloided propellant. The pond sediments were also thought to contain plasticizer (2-NPDA), wax and possibly some carbon black. The propellant N5 is a colloided form of the paste. Recommendations from Draft RFI Report - None to date. CALCIUM CARBIDE DISPOSAL AREA An evaporation pond was reported to be located in the southwest portion of the landfill. White and black stains were observed along the edges of the pond during site visits in 1989 and 1990. There is some concern that the surface water runoff from this site drains to Pyott's Pond via the South Acid Area Drainage Ditch discussed in the previous section . Waste Generated - The calcium cyanamide landfilled at this site may contain calcium carbonate, calcium cyanamide, ammonium, nitrate, sulfate, guanidine nitrate (GN), and metals. Byproducts which can be expected are carbide, cyanide, ammonia, and nitrates. Recommendations from Draft RFI Report - The draft RFI report recommends further investigation to assess the potential for off-site migration of contaminants. -- Lenny Siegel Director, Center for Public Environmental Oversight c/o PSC, 222B View St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/968-1126 lsiegel@cpeo.org http://www.cpeo.org | |
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