[CPEO-MEF] Aberdeen Range Management

[Lenny Siegel <lsiegel@cpeo.org>]

[The following article, from the August, 2001 edition of Coming Clean,
the newsletter of the Aberdeen Proving Ground Superfund Citizens
Coalition (APGSCC), raises important issues about "Sustainable Range
Management" on land with extensive historic contamination as well as
nearby civilian communities. - LS]


INACTIVE RANGES ON SUPERFUND SITES BECOME ACTIVE AS MAJOR INCREASE IN
TESTING AND TRAINING PLANNED FOR APG
Joint-Force Warfighters to Use Multiple Ranges 

by
Cal Baier-Anderson, University of Maryland 
For APGSCC

Aberdeen Proving Ground (APG) is a tenant facility, which means that
many different military components, as well as private corporations,
rent space (buildings, ranges, etc.).  The money collected for this use
is an important source of revenue, and is used for maintenance and
construction. The Aberdeen Test Facility (ATC) is a major tenant at APG.
 One of their most important functions is to coordinate and schedule
access to APG’s test and training ranges. 

ATC has recently submitted a proposal to generate additional revenue for
APG by renting out ranges to joint warfighter groups (Navy, Airforce,
Marines, Army) for the purpose of training. Warfighters are the soldiers
who are trained to fight.  In order to gain approval for this proposal,
ATC was required to submit a document called an Environmental
Assessment, which examines the potential environmental and human health
impact of a proposed activity.  If the Environmental Assessment
concludes that there is a potential significant impact, then the
Assessment must be followed by an Environmental Impact Statement, which
provides an in depth evaluation of potential impacts. In contrast, if
the Environmental Assessment concludes with a Finding of No Significant
Impact, then the process of evaluation is basically considered complete.
 ATC’s Environmental Assessment concluded with a Finding of No
Significant Impact. The APG Restoration Advisory Board (RAB) and APGSCC
had the opportunity to review and comment on this Environmental
Assessment, and have identified several major concerns.

ATC’s PROPOSAL 
The purpose of the proposed action is to provide warfighter soldiers
with more realistic training events. Training includes airborne jumps,
troop movement by helicopters, unmanned aerial vehicles, beach landings,
water craft maneuvers, firing from water to land, land/water ambush,
foreign vehicle recognition, small and large arms firing, orienteering
and global positions station use, peace keeping exercises, use of
simulants, staged scenarios, urban training, breaching and assault, and
camping. Many of these areas include Superfund sites and inactive
ranges, which will become active to accommodate the new testing and
training. These activities could impact the ongoing Superfund cleanup activities.

The following restrictions were noted:
*  Intrusive work will be kept to a minimum
*  UXO (unexploded ordnance) clearance (land and water) will be
performed prior to training
*  A 500-meter safety arc will be respected for Bald Eagle nesting (15
Dec - 15 June)
*  Pond restrictions for wood duck habitation will be observed
*  Small arms fire will be restricted to small arms ranges or other
approved areas. Mobile bullet traps will be used.
Testing of large caliber rounds will be authorized by ATC Range safety
office on established ranges. It is specified in the Assessment that
ongoing and known future Installation Restoration Program (IRP)
(Superfund) sites will be avoided.

ATC’s ENVIRONMENTAL ASSESSMENT
The Environmental Assessment evaluated APG air quality, noise control,
groundwater, surface water, ecology and wildlife, hazardous waste
management, and the ongoing Superfund cleanup activities by the
Installation Restoration Program. The following summarizes ATC’s assessment:
 
Air Quality: APG and Harford County are located within Maryland’s air
quality control Region III.  Air quality for each region is based on the
National Ambient Air Quality Standards.  Region III is in attainment for
particulate matter, nitrogen dioxide, sulfur dioxide, lead and carbon
monoxide, but is in non-attainment for ozone. (Note that there are
actually only two monitoring sites on or near APG, and these sites are
only monitored for ozone, so we do not actually know if the APG area is
in attainment for the other air quality criteria pollutants.)

Noise Control: In 1989, APG implemented a program to determine the need
for noise restrictions, and three zones were defined. Zone I is
acceptable for residential housing, schools and churches, zone III is
unacceptable for those activities, and zone II has unacceptable noise
levels, but noise controls can be implemented.  According to this
report, all APG test ranges and airfields are in zones II and III.

Groundwater: Both the Harford County and City of Aberdeen Production
(CAP) wells are located in the northern Aberdeen Area. Historical range
activities at APG have contaminated Perryman and CAP wells, which
provide drinking water to Harford County residents.  In addition, there
are two on-post groundwater supply wells located in the Edgewood Area
(H-Field test range and Westwood) that are used to produce water for
vehicle washing, well drilling and equipment decontamination There are
also private wells adjacent to the Installation boundary. The wells must
be protected from further contamination.

Surface Water: There are three major bodies of water surrounding the
Aberdeen Areas: the Chesapeake Bay, Bush River and Swan Creek.  Romney
Creek is the major watershed within the Aberdeen Area. To the east are
Mosquito, Woodrest and Delph Creeks. To the west are Cod and Abbey
Creeks. In the Edgewood Area, there is the Gunpowder River to the west,
and the Bush River to the east. Other, smaller river systems include
Wright Creek, Swaderick Creek, and Watson Creek, which drain into the
Gunpowder, and Coopers Creek and Boones Creek, which drain into the Bush
River. (Note that most of these waterways have already been contaminated
or degraded by historic range activities.)

Ecology and Wildlife: APG contains woodlands, fields, wetlands, and
shoreline bordering the Chesapeake Bay. A wide variety of wildlife can
be found here. There are six waterfowl refuge areas; and protections for
bald eagles and several endangered plant species are in place.

Hazardous Waste Management: This report indicates that the generation of
hazardous wastes is not expected, other than vehicular maintenance
materials. 

Installation Restoration Program: The report notes that historical
activities have resulted in contamination that has placed APG on the
National Priorities List as a Superfund Site. The APG Installation
Restoration Program (IRP) is in charge of investigating the contaminated
sites within the 13 study areas.

The Assessment concludes that the proposed training will have: 
*  No Impact on topography and soils, cultural resources, hazardous
waste management, and
*  Minor impacts on air quality, noise, groundwater, surface water,
ecological protection, and IRP activities.
Additionally, 
*  ATC must certify training areas/sites have been cleaned of training
debris (spent smoke grenades/canisters),
*  ATC must provide written training guidance and instructions on IRP
hazards, UXO hazards, endangered species avoidance areas, vehicle
policies, training site boundaries, and noise limitations, and
*  Amphibious landing sites will be pre-approved and marked.  Some
landings will be designated “single file” to minimize beach use. 

APGSCC AND APG RAB IDENTIFY CONCERNS 
APGSCC technical advisors have reviewed the ATC Environmental Assessment
and met with representatives from ATC and APG to discuss the proposed
plans.  Our comments and concerns are based upon a decade of work with
the APG Installation Restoration Program. APG has identified major
contamination from historical testing and training activities, and we
must insure that we do not repeat past mistakes.  The concerns that we
have identified are described below:

Training Areas: The Environmental Assessment does not adequately
describe the specific activities that could take place nor does it
convey sufficient detail regarding area restrictions. In particular,
community members are concerned that activities could occur in the
boundary areas (e.g., Carroll Island, Graces Quarters, Westwood,
Lauderick Creek, Western Boundary), resulting in new contamination or
the mobilization of known and unknown historical contamination, which
puts the adjacent community at risk. Additionally, there is the concern
that trainees will not necessarily restrict their activities to those
areas approved by APG.  For example, the Maryland National Guard
recently strayed from approved training areas in Westwood, resulting in
damage to an area that was recently remediated.  These concerns are best
addressed by a public meeting that includes representatives from APG
DSHE, ATC, EPA and MDE.

Location of Historical Contamination: Since the Remedial Investigations
for both the Other Edgewood Areas, the Western Boundary Area and the
Other Aberdeen Areas are ongoing, and have not been completed, we do not
have a clear sense of the location of all of the areas of contamination
that may require remediation. APGSCC is also particularly concerned
about the extensive depleted uranium and UXO contamination that will
need investigation. 

In general the APG coastline represents vast areas that could contain
many more sites.  There are many munitions disposal sites in the Other
Edgewood Areas that have yet to be located. For instance, there will
soon be a geophysical survey to identify the location of historic
munitions disposal sites within H-, I- and C-Fields. This raises several issues:
*  For more than a decade, APGSCC has observed APG and contractors
uncover additional extensive contamination after APG had performed its
initial site investigations.  Will the trainees be briefed that they may
encounter historic disposal sites or impact areas containing chemical,
radiological contamination and possibly biological contamination? If
not, then this warning should be added to the training guidance, which
is provided to all trainees.
*  In the event that historic disposal sites or impact sites are
encountered, what is the process for the notification of the IRP and
EPA, so that they can undertake an investigation and possible remedial
action? 
*  Will spent munitions and UXO be removed from firing ranges prior to
and at the termination of training and testing operations? If so, is
this realistic considering the presence of UXO on ranges from decades of
testing? 

Live Fire Impacts. The firing of large munitions will result in the
release of toxic chemical explosives into the environment.  This will
result in increased contamination of soil, sediment, surface water and
groundwater.  The degree of contamination will depend on the number of
munitions that are fired, and the degree of cleanup following the
termination of firing exercises. But the conclusion that training will
result in no increased impact does not make sense, and we disagree with
this conclusion.  
*  We disagree with the Army that munitions and their fills (explosives
such as RDX and HMX, as well as “inert” fillers such as benzene, carbon
tetrachloride and chloroform) do not constitute hazardous waste. We
believe that filled munitions are analogous to drums of hazardous waste.
 Both constitute metal containers filled with toxic materials, including
probable carcinogens.  Explosive contamination (RDX) detected by APG in
several of Harford County’s Perryman Wellfield public drinking water
wells, and in one of the City of Aberdeen’s production wells are the
likely result of munitions testing and training. The question is, should
the Army wait until there is a severe threat to human health before it
acts? We urge the Army to be proactive and undertake UXO remediation at
APG on a larger scale. 
*  We strongly believe that remediation should be an integral part of
live fire testing and training. APG has conducted only limited UXO
remediation, despite the massive historical UXO legacy that needs to be
addressed.  APGSCC maintains that because the APG IRP has spent hundreds
of millions of dollars on remediation activities at APG and will
continue to do so in the future, it makes sense to implement a stringent
UXO remediation program now. 
Congressmen Earl Blumenauer (D-OR) and Bob Riley (R-AL) recently
introduced legislation that lays out policy guidelines for the
government's cleanup of unexploded ordnance (UXO), and includes a
separate budget. Passage of this legislation could make UXO cleanup a priority.

Protection of Boundary Areas. APGSCC believes that all boundary areas,
which contain both conventional and chemical-filled UXO, should be
unavailable for training and testing activities. The accidental release
of chemical agent (from historic UXO) or other hazardous fillers during
training activities could impact the trainees and adjacent communities.
These areas are best designated “buffer zones”.

Environmental Monitoring of Effects of Training Activities. The soils
and other media at the test sites will not be analyzed for the presence
of contaminants resulting from testing and training activities.  APGSCC
and the RAB strongly believe that the cleanup response must be
comprehensive to prevent the creation of new Superfund sites.  

The Department of Defense, Directive Number 4715.11, Subject:
Environmental and Explosives Safety Management on Department of Defense
Active and Inactive Ranges Within the United States, which was signed on
August 17, 1999, directs DoD components to develop sustainable range
management plans. APG has not yet developed this plan.

Specifically, Section 5.4.14 of the Directive indicates that the head of
each DoD Component must “Respond… to a release or substantial threat of
a release of munitions constituents from an active or inactive range to
off range areas, when such releases pose an imminent threat to human
health or the environment”. We maintain that before the Component can
respond to such a threat, the threat must be characterized, which
requires a monitoring program.

We urge APG to develop plans to implement this Directive and provide the
community with the opportunity to comment on the plans. In particular,
we believe that comprehensive monitoring for contaminants that could be
leaving the sites is warranted. This is critical because the drainage
basins on APG all lead to the Chesapeake Bay, a national resource that
must be protected.  Moreover, recreational boaters, and commercial and
recreational fishermen who frequent the waters adjacent to APG must be
protected from exposure to hazardous contaminants generated during
testing and training activities. Finally, the adjacent communities must
also be protected from contamination moving off the testing and training
sites, particularly through air and groundwater contamination.

APGSCC understands that to develop and implement a strong sustainable
range management plan that is protective of the on-post community, the
adjacent community and the environment will require a significant amount
of funding. However, we do not believe that this should be used as an
excuse not to do so.  To obtain adequate funding requires a financial
commitment from the Department of Defense, Pentagon officials, the
Department of the Army, APG and tenant organizations. APG is ultimately
responsible for how all tenant activities impact the installation,
natural resources, the local environment and community stakeholders. 
Given the extensive contamination at APG, APG can’t afford NOT to
implement a strong sustainable range management plan to investigate and
cleanup UXO. If this does not happen, then this will lead to the
creation of more Superfund sites and put both the adjacent communities
and the Chesapeake Bay at further risk.  

In conclusion, the activities proposed by ATC bring into focus all of
the potential problems associated with active military training and
testing programs. APGSCC urges APG to implement a strong range
management and environmental monitoring program that would be protective
of the local public and the environment. This must include a UXO
remediation plan to ensure that APG can continue its mission into the
next decade. While the community recognizes the need for this testing
and training to promote military readiness, we maintain that such
programs must include protections for the adjacent community. 
Protection must include an adequate buffer zone and comprehensive
environmental monitoring.  With these safeguards in place, APG is more
likely to obtain support for testing and training programs. [

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