[CPEO-MEF] Emercency IRA under CERCLA

[CPEO Moderator <cpeo@cpeo.org>]

Please see the attached letter [BELOW] requesting EPA use regulatory
powers to require APG to conduct an emergency interim remedial action
for the perchlorate contamination under CERCLA.  This will ensure public
health and safe drinking water for the city of Aberdeen.

Thank you,

Glenda Bowling,
Pres. APGSCC (Aberdeen Proving Ground Superfund Citizens Coalition)

_________________________________
September 4, 2002

Mr. Steve Hirsh
US EPA Remedial Project Manager
3HS13
USEPA Region III
1650 Arch Street
Philadelphia, PA 19103-2029

Dear Mr. Hirsh:

As you know, perchlorate was recently detected in four of the City of
Aberdeen Production (CAP) wells ranging from 1.1 to 5 ppb. Although the
concentrations of perchlorate in the finished water do not currently
exceed the State of Maryland health advisory limit of 1 ppb (1), we at
APGSCC believe that there is clear consensus that sufficient scientific
data exists to justify immediate action to protect human health.

We specifically recommend the implementation of an emergency interim
remedial action. This action must include the installation of temporary,
portable ion exchange systems on each CAP well containing perchlorate
contamination. This should be followed by the installation of a
permanent ion exchange system to treat all CAP wells.

The perchlorate is thought to derive from historic and current training
activities in the vicinity of Camp Stanton, Aberdeen Proving Ground,
although no single incident or source location can be pinpointed for the
newly detected contamination.  Given the complexity of the aquifer in
the Aberdeen Area and the extent of the contamination it is difficult to
predict if and when well concentrations will increase. Thus, we are
faced with a completed exposure pathway and are relying solely on
dilution to protect the health of local citizens. APGSCC believes this
is unacceptable.

Despite consensus at the local level that the perchlorate issue must be
addressed, it is the current policy of the Department of Defense to
oppose action to remediate perchlorate contamination in the absence of
enforceable standards (2). Since perchlorate constitutes a known health
risk, APGSCC petitions EPA Region III to use the regulatory powers
established by CERCLA and SDWA to require APG to undertake an immediate
interim remedial action. Such action would serve to ensure the
protection of public health.

The residents of Harford County need the leadership of the EPA in
addressing this issue. Given the history of APG and the lessons we
learned from the unnecessary public exposures to the trichloroethylene
in the Perryman well field, we need to be more proactive in our response
to this latest threat.

Thank you for your time and attention on this important matter. We look
forward to discussing this issue further at your earliest convenience. I
may be contacted at 410- 272-5925.



Sincerely,



Glenda Bowling
President, APGSCC
198 Sunnyside Drive
Aberdeen, Maryland 21001



(1) Letter from Robert M. Summers, Director, Water Management
Administration, Maryland Department of the Environment to Peter A.
Dacey, City Manager, City of Aberdeen, Maryland, dated August 20, 2002.

(2) Memorandum for Deputy Assistant Secretary of the Army (Environment,
Safety, and Occupational Health) Deputy Assistant Secretary of the Navy
(Environment) Deputy Assistant Secretary of the Air Force (Environment,
Safety, and Occupational Health) Staff Director, Environment and Safety,
Defense Logistics Agency Support Services (DSS-E). Subject: Interim
Guidance on Sampling for Ammonium Perchlorate Contamination, Signed by
John Paul Woodley, Jr., Assistant Deputy Under Secretary of Defense
(Environment).

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