[CPEO-MEF] Mitretek Study Use of Stockpile Facilities for Non-Stockpile Chemical

[CPEO Moderator <cpeo@cpeo.org>]

[This was posted to the list by Cal Baier-Anderson, 
<cbaie001@umaryland.edu>]

Hi Lenny-
 
Attached is a letter which we sent to the US Army Program Manager for 
Chemical Demilitarization which conveys our comments on a study by 
Mitretek on the feasibility of using stockpile facilities for the 
destruction of non-stockpile chemical materiel. These comments focus on 
the situation at Aberdeen Proving Ground (MD). We would appreciate it if 
you would post these on CPEO.
 
A copy of the document summary, prepared by University of Maryland for 
the community, is also available on request.
cal
_____________________________
Cal Baier-Anderson, PhD
University of Maryland, Program in Toxicology
100 N. Greene Street
Baltimore, Maryland, 21201
 
Office Phone: 410-706-1767
Office Fax: 410-706-6203
_____________________________

Mr. James L. Bacon
US Army Program Manager for Chemical Demilitarization
Building E4585, ATTN: SFAE-CD-P
Aberdeen Proving Ground, MD 21010-4005

November 27, 2000

Dear Mr. Bacon:

The Aberdeen Proving Ground Superfund Citizens Coalition (APGSCC) is an 
organization that was formed to work with the Aberdeen Proving Ground 
(APG) in the cleanup of its hazardous waste sites. There are two 
designated Superfund sites at APG, with more than 300 individual 
contaminated areas. For more than a decade, we have monitored the 
cleanup of these contaminated sites and worked closely with the APG 
Installation Restoration Program (IRP) to address contamination issues. 

We would like to begin by thanking you for the opportunity to review the 
"Assessment of Using Stockpile Disposal Facilities to Process Selected 
Non-Stockpile Chemical Materiel".  After careful consideration, we 
present the following comments. Please note that our comments are 
restricted to the situation at Aberdeen Proving Ground.

COMMENT 1: The letter issued to "Stakeholders" on June 1, 2000 and 
signed by James L. Bacon, requested comment on the use of stockpile 
facilities for the destruction of non-stockpile CWM.  At APG, the 
stockpile facility, which is under construction, is the Aberdeen 
Chemical Agent Disposal Facility (ABCDF). There was absolutely no 
mention of either the Chemical Transfer Facility (CTF) at APG, or the 
Chemical Agent Munitions Disposal Facility (CAMDS) at the Deseret 
Chemical Depot, Utah in this letter, yet both of these facilities were 
included in the study. How were the "stakeholders" supposed to comment 
on the study, when they were misinformed regarding the scope of the 
study? 

COMMENT 2: The Army requested Mitretek to evaluate the use of stockpile 
facilities to destroy non-stockpile CWM. This original mandate is 
fundamentally flawed because it ignores the question as to whether there 
are existing alternatives to using stockpile facilities for the 
destruction of non-stockpile CWM. The question of the technical 
feasibility of using stockpile facilities for this purpose could in fact 
be moot.

The scope of Mitretek's study exceeded this original request by 
including additional facilities that are not part of the stockpile 
program. Once Mitretek decided to extend its evaluation beyond stockpile 
facilities, it had a responsibility to consider all of the new 
facilities and technologies, as they could, in theory greatly reduce, or 
even eliminate, the need for the use of stockpile facilities in the 
first place. In fact, we would welcome a study of this nature.

As the report briefly notes, several facilities and technologies are, at 
APG, in the final stages of design/construction and testing, and should 
soon be available for use. For instance, there are two facilities under 
construction (the Prototype Detonation Test and Destruction Facility as 
well as the Munitions Assessment Processing System) and APG is also 
involved in the evaluation of the Explosive Destruction System (EDS) and 
Ballistic Tent and Foam. The fact that these facilities are not yet 
completed should not have been a deterrence to their inclusion, since 
the PDTDF and EDS will both be available before either the ABCDF or 
MAPS.

COMMENT 3. APGSCC would like to know to whom the "Dear Stakeholder" 
letter was sent. Neither the APG Restoration Advisory Board (RAB), nor 
APGSCC received this letter. The RAB works very closely with APG to 
determine the best approach to handling of CWM at APG. The RAB should 
have been briefed on this subject prior to the June deadline for public 
comment. As the principal community organization that actively monitors 
and evaluates remediation efforts at APG for more than a decade, APGSCC 
should also have been contacted. Additionally, a public meeting should 
have been held to provide a comprehensive explanation as to the nature 
of this study. Notices should have been posted in the local and regional 
newspapers.  In the absence of these efforts, there is absolutely no 
basis to comment on public acceptance.

APGSCC finds the conclusion that public acceptance of the use of the CTF 
is "high" to be unacceptable and mystifying, since no one was informed 
that it was being considered for such use.  The statements regarding 
public outlook must be retracted until the community receives a 
comprehensive briefing and will thus be in a position to offer educated 
opinions.

COMMENT 4: The question as to how best to destroy the non-stockpile CWM 
is extremely complex. It hinges not only on the number and nature of the 
items, but a complete assessment of all facilities and technologies, 
either currently available or under development, and their potential for 
use at each facility.  This simplistic report is a disservice to 
Congress, the Army and the community, in that it pre-selects remedies 
without a comprehensive assessment of all available options. The report 
appears, in the case of APG, to manufacture public acceptance, when 
there was no meaningful effort to inform the public as to the complex 
issues at hand. 

COMMENT 5: APGSCC stands firmly against the use of stockpile facility, 
ABCDF, to dispose of non-explosive mustard-filled rounds from the 
non-stockpile program. The community was repeatedly told that only 
stockpile inventory would be destroyed in this facility. To use it for 
the disposal of non-stockpile items is a breech of the public trust.

COMMENT 6: APGSCC supports the use of the CTF for the disposal of 
non-explosive CWM-filled rounds. However, this decision should be viewed 
within the context of a comprehensive assessment of the CWM destruction 
capabilities at APG.  This assessment must include all facilities and 
technologies under construction, development, testing or consideration.  
The PDTDF, MAPS, EDS, explosive containment "bang" boxes and Ballistic 
Tent and Foam must be evaluated in terms of technical feasibility as 
well as current and projected need.

COMMENT 7: MAPS is a very expensive facility that could increase CWM 
destruction capacity beyond the needs of APG, which may lead the DoD to 
consider its use for the destruction of out-of-state CWM in order to 
justify its cost. We strongly oppose the importation of non-stockpile 
CWM for destruction at APG. 

Since the DoD prohibits the use of DERA funds to search for and remove 
UXO/CWM it is unlikely that APG will uncover significant numbers of 
explosive chemical-filled rounds. APGSCC strongly believes that MAPS 
should not be built unless the Army commits to an aggressive excavation 
of UXO/CWM at APG. 

COMMENT 8: Mitretek must retract statements regarding public support 
until the community has been fully briefed and advised on the complete 
proposal. We recommend that this be accomplished by holding a 
well-publicized public meeting. Advertising for the meeting should 
include a public notice submitted to local and regional papers. 

We would welcome the opportunity to discuss these comments.  If you have 
any questions, please contact us through our technical advisor, Dr. Cal 
Baier-Anderson, University of Maryland, Baltimore, Program in 
Toxicology, (410) 535-9598, cbaie001@umaryland.edu.

Sincerely,



Christine M. Grochowski
Aberdeen Proving Ground Restoration
Advisory Board Community Co-Chair				
435 Acadia Drive
Joppa, MD 21085

Susan C. Rice
Treasurer, APGSCC
517A Trimble Road, 
Joppa, MD 21085

Cc: 	Mitretek Systems, Inc
Kenneth Stachiw, Director, APG Installation Restoration Program
Senator Paul S. Sarbanes
Senator Barbara Mikulski
Representative Wayne T. Gilchrist
Representative Robert L. Ehrlich
Jane T. Nishida, Secretary, Maryland Department of the Environment
Bradley Campbell, Administrator, US EPA Region 3
Steve Hirsh, US EPA Remedial Project Manager
James Harkins, Harford County Executive

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