[CPEO-MEF] APGSCC Tech Update: Letter and Info

[CPEO Moderator <cpeo@cpeo.org>]

A copy of the following letter is being sent to Senator Paul Sarbanes
from Glenda Bowling, President of the APGSCC (Aberdeen Proving Ground
Superfund Citizens Coalition).  Please note that a copy of the
Unexploded Ordnance Technical Information Update at APG is pasted
immediately following the letter.

September 17, 2002

Senator Paul S. Sarbanes
100 S. Charles Street
Tower 1, Suite 1010
Baltimore, MD 21202-3099

Dear Senator Sarbanes:

APGSCC is writing this letter to inform you of a complex and critical
issue that needs resolution to protect public health now and in future
generations.  As representatives of community stakeholders at Aberdeen
Proving Ground, Aberdeen Proving Ground Superfund Citizens Coalition
(APGSCC) has worked hard to demonstrate our credibility as serious
participants in the Superfund cleanup process.  We have succeeded in
establishing a working relationship with APG and EPA Region III such
that we are considered a member of the Project Team (i.e., we are
involved with making decisions ranging from where environmental sampling
should occur to what remedial options should be considered). We are
proud that both APG and EPA Region III believe that we provide an
important contribution to the remedial process, and we are committed to
continuing this productive relationship.

In the attached Technical Update [*PASTED BELOW], we provide information
on the problem of unexploded ordnance (UXO) at APG. This issue is
considered to be extremely important to community stakeholders and is
faced with significant obstacles to resolution. The APG Installation
Restoration Program (APG IRP) is willing to begin to address UXO issues
in a comprehensive manner, however it lacks support and funding from the
Department of the Army and the Department of Defense. With your previous
assistance, APG obtained funding to clean-up UXO/CWM in the Lauderick
Creek Study Area, along the Edgewood Area base boundary. This removal
action is nearly complete, and has to date, been very successful.
However, the problem of UXO contamination is enormous throughout the
installation.  UXO along the base boundary, including the extensive APG
shoreline, pose a significant safety and health concern.

The remediation process at APG has proven to be remarkably effective in
integrating complex scientific information with public concerns. We are
concerned that by DoD opposing the collective work of the APG IRP, EPA
and community stakeholders, the DoD risks losing our trust and
potentially placing the public at risk now and in the future.

We would like to convene a meeting with you to discuss our concerns as
soon as possible. We propose inviting DoD and EPA officials to discuss a
resolution to the DoD?s position on the referenced issue.

We will be contacting your office within a week in order to schedule an
appointment.  In the meantime, if you have any questions, please contact
Glenda Bowling, APGSCC President at (410) 272-5925 or Cal
Baier-Anderson, University of Maryland, APGSCC Technical Assistance
Grant Consultant, at (410) 706-8196 or (410) 535-9598.  We hope you find
this information useful.

Thank you in advance for your assistance in this matter.

Sincerely,

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

410 272-5925
cc: Kenneth Stachiw, Director APG Installation Restoration Program
Steven Hirsh, EPA Region III Remedial Project Manager
___________________________________________

*Aberdeen Proving Ground Superfund Citizens Coalition
Technical Information Update
Unexploded Ordnance at APG

Prepared for APGSCC by
Cal Baier-Anderson, PhD, University of Maryland, Baltimore
September 17, 2002

Unexploded ordnance (UXO) are military munitions that have been fired,
dropped, launched, projected, or placed in such a manner as to
constitute a hazard to operations, installations, personnel, or
material; and remain unexploded either by malfunction, design, or any
other cause.  UXO often contain hazardous explosive or toxic chemicals;
at APG these can include lethal chemical agents.

The Department of Defense is in the process of developing a
comprehensive response to the problem of UXO, discarded military
munitions, and munitions constituents. Among the goals of the Military
Munitions Response Program (MMRP) are to develop an inventory of all
locations, other than operational ranges, that require a military
munitions response, and to prioritize these sites.

According to the MMRP, formerly used defense sites (FUDS) are a
priority, as these sites are no longer under DOD control.  But it also
includes those sites on active military bases that are no longer used
for range activities.  The DOD has yet to finalize its prioritization
protocol, however the following criteria are expected to be part of the
protocol:
? Known, versus suspected, presence of munitions or constituents and
nature of munitions.
- Presence/effectiveness of public access controls, and the potential
for direct human contact.
- Extent of documented incidents (e.g., explosions, discoveries,
injuries, etc)
- Potential for drinking water contamination or the release of munitions
constituents into the air
- Potential destruction of sensitive ecosystems and damage to natural
resources

UXO at APG
At APG, UXO can be found along the entire base boundary in both the
Edgewood and Aberdeen areas, leftover from both range and disposal
activities.  APGSCC has been urging APG to remove UXO and military
munitions, along with residual munitions contaminants from the boundary
areas in order to create a safe buffer zone between the off-post
community and APG active ranges. In our view, directing efforts along
the base boundary areas (including the extensive shoreline) would
provide the most protection for people and the environment, and
therefore deserves the highest priority.

It is currently very difficult for APG to obtain approval and funding to
conduct UXO removal operations, even in known disposal areas that are
subject to regulatory oversight. While there is certainly a need to
improve available technologies for finding, removing and safely
destroying UXO, it is necessary to begin removal now in order to provide
a secure buffer zone. Unfortunately, there does not appear to be
specific funding mechanisms included with the MMRP.

APGSCC Recommendations
- APG must define which areas are, or should be considered ?closed?, in
the sense that they cannot or should not be re-used as active ranges for
testing and training operations. We recommend that the entire APG land
boundary and most of the shoreline should fall into this category.
- APG should complete an inventory of active and closed range areas as
soon as possible, to facilitate prioritization of cleanup areas.
- APG should assign high priority to boundary areas that can be readily
accessed by the public.
- The DOD should fund UXO removal actions now while continuing to
develop better technologies for finding, removing and destroying UXO.

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