From: | CPEO Moderator <cpeo@cpeo.org> |
Date: | 6 Sep 2002 13:37:56 -0000 |
Reply: | cpeo-military |
Subject: | [CPEO-MEF] Emercency IRA under CERCLA |
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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