[CPEO-MEF] The Army's ITR Process at Aberdeen

[Lenny Siegel <lsiegel@cpeo.org>]

Submitted by "Cal Baier-Anderson" <cbaie001@umaryland.edu>, technical
consultant to the Abderdenn Proving Group Superfund Citizens Coalition.

The Army Internal Technical Review: APGSCC's Experience

The stated purpose of the Internal Technical Review (ITR) process is to
assess and defend the use of environmental restoration funds at military
bases.  The ITR provides technical expert assistance while evaluating
the Installation Restoration Program (IRP). It also promotes the use of
risk-based and risk-management approaches to remediation
decision-making, which would, in theory, assure that remedial
alternatives are "properly assessed and balanced". Additionally, the ITR
should identify opportunities to implement new and innovative
technologies.  APGSCC was invited to attend Aberdeen Proving Ground's
(APG's) ITR meetings. Having witnessed the review process, APGSCC has
identified several conceptual problems with the ITR.

1)	APG personnel indicated that a major obstacle encountered in the
restoration process is that the Department of the Army (DA) regularly
questions the need for remedies selected by the IRP yet declines to
actively participate in the cleanup process until the final draft ROD is
presented to them. This creates problems in the process for the local
command, IRP personnel, federal and state regulators, and citizens who
have participated in the process from the outset. The delays caused by
the DA's last minute involvement extend the remediation process and time
to site closure. Although the obstacles posed by the DA inevitably and
unnecessarily increase the cost of remediation, the ITR team had
absolutely no response to this very real problem. They literally changed
the subject and moved on.

2)	The ITR emphasized legal loopholes.  They argued that if there is no
legal driver, then there is no need to clean up a site.  While APG
personnel asked about "moral drivers" (e.g., the Army contaminated the
environment, so they are morally responsible for its cleanup), the ITR
team continued to emphasize that in the absence of legal drivers, no
remediation is necessary. We believe that this view underscores the
pressure that is put on IRPs to minimize remediation costs.

3)	ITR strongly stated that the community is not part of the Project
Management Team (PMT).  The PMT consists of the Army Project Managers,
the US EPA, and State Regulators, and it is the decision-making body. 
The ITR panel did indicate that open lines of communication between the
PMT and Technical Staff (listed in their material as "CHPPM, EPA and
State, ROM and USACE, Contractors and Consultants") and the PMT and
"Other Stakeholders" (listed in their material as "Native American
tribes, Property Owners, Local Government Agencies and Interested Public
(RABs)" are important.  This view of the PMT directly contradicts verbal
assurances given by the DA to APGSCC that the community is part of the
PMT.

-- 


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


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
You can find archived listserve messages on the CPEO website at 

http://www.cpeo.org/lists/index.html.

If this email has been forwarded to you and you'd like to subscribe, please send a message to: 

cpeo-military-subscribe@igc.topica.com
___________________________________________________________
T O P I C A  The Email You Want. http://www.topica.com/t/16
Newsletters, Tips and Discussions on Your Favorite Topics