[CPEO-MEF] Camp Bonneville clarification and comment

[Lenny Siegel <lsiegel@cpeo.org>]

In response to an inquiry from CPEO, the office of the Assistant
Secretary of the Army for Installations and Environment has clarified
the Army's position on its cleanup plans for Camp Bonneville, a closing
training base in Clark County, Washington. 

The Army wrote: "The Army is continuing its cleanup activities
associated with non-munitions related CERCLA response actions. Cleanup
activities are continuing for: groundwater and soils in the impact area;
lead from small arms, groundwater and soils at all three open burn and
open detonation sites. 

"Regarding munitions and UXO response actions, the dialogue the Army is
engaged in now is not whether we are going to remediate UXO at Camp
Bonneville but to what extent remediation is necessary to fully support
the end use of the property. Additional UXO studies, such as Engineering
Evaluation/Cost Analysis, will be deferred until property reuse
decisions are finalized. The Army will work with Clark County to
accomplish all of the necessary tasks to turnover Camp Bonneville as
quickly as possible. 

"The Army met with Congressman Bruce Baird on March 30 to discuss these
issues. The Army appreciates his personal interest in moving this effort
along. Another meeting is scheduled for April 16 at Vancouver,
Washington with Congressman Baird and other stakeholders. The Army is
hopeful that we can reach an agreement in principle at that meeting on
the approach to UXO cleanup activities and property transfer at Camp
Bonneville. Once a comprehensive reuse plan is patched together
considering all interests, we will be able to put together a
comprehensive UXO remediation plan."

To further clarify the situation, I asked: "I thought Clark County had a
land use plan. Is the Army suggesting that it be changed based upon the
difficulty of remediating the UXO?"

The Army responded again: "Clark County and the Department of the Army
are negotiating a land use plan that is acceptable to all parties. The
Clark County proposed land use plan is serving as the start point for
these negotiations."


***

COMMENTARY (by Lenny Siegel)

I am sure that the residents of the Camp Bonneville area appreciate the
Army's willingness to re-start its unexploded ordnance [UXO] response
program at the installation. Furthermore, it's a good sign that the Army
is talking to both Clark County and its member of Congress. Still, I
find the Army's position deficient. Its reluctance to continue UXO
response activity illustrates the need for a strong regulatory framework
governing UXO and similar explosive wastes.

It appears that the Army wants Clark County to modify its reuse plan - a
park, primarily - to save money on cleanup. While that tends to go
against the nation's stated base closure policy, of cleaning to local
reuse plans, it's not necessarily unreasonable. With today's ordnance
remediation technology, it may be impossible to make portions of the
property safe enough to convert it all into a public park. One can
understand why the Army is unwilling, at least for now, to spend money
on activity that will do little to enable greater public access.

I'm not saying that I support the Army position. But this is a key
decision to be made at the remedy selection phase.

And the Army is pulling the plug before remedy selection. To make an
informed judgment as to whether it's practical to clear all of Camp
Bonneville of UXO, and to what depth, there needs to be full
characterization. It's my understanding that the base cleanup team,
composed of representatives of the Army, U.S. EPA, and the Washington
Department of Ecology, had agreed - before the recent Army announcement
of suspended activity - upon an innovative transect strategy for
investigating Camp Bonneville. As I understand the Army announcement,
that work cannot take place until it accepts a "final" land use plan.

Furthermore, the Army's promise to continue the characterization of
toxic substances in soil and groundwater at the facility is hollow
unless UXO response is conducted at the sampling sites. As a rule, at
ordnance sites one does not go around collecting soil samples or poking
holes into the ground without first checking for UXO.

Finally, the Army hasn't made it clear to what degree access controls,
general considered part of UXO response, will be implemented while it's
reviewing its remediation plans. While I would expect the current,
minimal level of protection to continue, it's fairly clear that more
resources must be expended to keep people out of impact areas as long as
the UXO remains on or near the surface.


Lenny
-- 


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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