[CPEO-MEF] UXO at Tobyhanna

[Lenny Siegel <lsiegel@cpeo.org>]

Below I have pasted comments I just sent to U.S. EPA questioning the
proposed partial deletion of a former artillery impact range, at
Pennsylvania's Tobyhanna Army Depot, from the "Superfund" National
Priorities List. It appears that ordnance has been lefts in place and
that physical controls, supported by land use restrictions, form the
"remedy" at that site.

TO: Lorie Baker <baker.lorie@epa.gov>, Superfund Site Manager, U.S. EPA
Region 3
FROM: Lenny Siegel <lsiegel@cpeo.org>, Executive Director, Center for
Public Environmental Oversight
SUBJECT: Deletion of UXO Contaminated Land from the Tobyhanna Army Depot
National Priorities List Site
DATE: July 2, 2001


I am concerned about EPA's proposal to delete a portion of the Tobyhanna
Army Depot, Pennsylvania, property from the National Priorities List, as
proposed in the Federal Register, June 12, 2001, page. 31582. According
to the notice, a 400-acre former artillery range, known now as Operable
Unit 4, is proposed for deletion, even though no site remediation has
been done in this area.

That is, the CERCLA (Comprehensive Environmental Response, Compensation,
and Liability Act) response, according to the Federal Register notice,
consists of physical access controls, land use restrictions, and public
education. That might be the proper remedy, at least for now, but
unexploded ordnance (UXO) apparently remains in place throughout the
operable unit. UXO is a hazardous substance posing a long-term threat to
public safety, and conceivably its presence could eventually generate
toxic wastes posing a threat to local groundwater.

Deleting areas known to contain such hazardous substances is not only a
dangerous way to manage the Tobyhanna property, but it would set a
dangerous precedent for the management of former munitions impact areas elsewhere.



-- 


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: 650/961-8918
lsiegel@cpeo.org
http://www.cpeo.org

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