Re: [CPEO-MEF] Digest for cpeo-military@igc.topica.com, issue 475

[themissinglink@eznetinc.com]

I would love to see the Lead Agency status taken away from the DoD.  I 
have always said that it is a conflict of interest.  They are the 
polluter and they are the financially responsible party so they should 
not be the ones taking the lead in analyzing the various alternatives.

CERCLA and RCRA are legally mandated cleanup standards.  Nothing else in 
the legal system would allow for even the appearance of a conflict of 
interest but here we have a very real conflict of interest.

And in my opinion it shows in the types of arguments I see from the DoD 
in the Response to Public Comments, the Feasibility Study, and the Risk 
Assessment for Landfill 7 on the edge of Lake Michigan in a former 
ravine within a quickly eroding 30 foot high bluff.

One example is that in the excavation option the DoD makes a big deal of 
the risk of exposure to air of the buried toxins while the risk of  
failure of the cap and bluff stabilization are never mentioned in the 
capping option. The DoD put a cap over this same landfill in 1982 but it 
failed due, in their opinion, to not being maintained properly.  14,000 
gallons of leachate were going into Lake Michigan per day because of 
this failure which is why they were able to fast track and interim cap 
currently.

My belief is that the failure of the previous cap was more due to the
unstable geologic nature of a ravine and bluff than the lack of DoD
stewardship but regardless it failed, so why does the Risk Assessment 
not cover the risk of failure of the capping option?  Conflict of 
interest. They do not want to excavate under any scenario, even if the 
waste turns out to be so hazardous as to trigger land disposal 
restrictions(a possibility by their own admission) and require 
incineration before being moved to a properly planned landfill.  So 
better to leave it in place near the source of 95% of this country's 
fresh water supply.

Steven Pollack
www.familyjeweler.com/fortweb.htm