Sunflower Army Munitions Plant - FOSET

[Marsden and June Chen <doobage@localnet.com>]

Under CERCLA 120(h), approval of the FOSET must be done jointly by the
Governor of the State and the Regional Administrator of the USEPA. This
should be done after review of the technical documents which should
describe the hazardous areas of concern a the facility, and the future
plans of the Army even after transfer of the property. In approving the
FOSET, the Gov. and Administr. will be confirming that hazardous
conditions exist at the site, no remedial actions have been taken but
transfer may take place without undue potential for impacts on human
health and the environment.
Thirty days for public comment on the FOSET is clearly insuffucient and
an extension should be sought from both regulatory agencies. Apart from
all the important documents that will certainly be generated for the
FOSET, probably the most important item to be considered is the remedy
of the site and the Army's feet should be held to the fire for doing
this. Moreover, the Army should be held responsible for any existing
hazardous conditions not yet discovered but which could come to light at
a later date. Both the State and EPA should agree on the type of
tripartite document that will describe the Army's future
responsibilities - a kiss and a goodbye will not do it. It might be
difficult in getting the Army to agree to a legal document and the most
that it may agrre to is a promisory letter.