[CPEO-MEF] EPA Letter to Army re: Camp Bonneville

[CPEO Moderator <cpeo@cpeo.org>]

The following was posted by Karen Kingston <Karen4theCamp@cs.com>
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The Transfer of Camp Bonneville, Vancouver Washington, is imminent.
Clark County Commissioner Judie Stanton, County Administrator Bill
Barron, and Congressman Brian Baird are in Washington, DC working to
gain an Early Transfer of this BRAC site to Clark County.  Clark County
has been involved in the BCT for the past seven years and has done
nothing to either enable a better evaluation or characterization of Camp
Bonneville.  To the regret of the RAB Stakeholders and the
EPA, a premature transfer may be a severe detriment to the protection of
the environment, the public, and the wildlife.  The following EPA letter
is the best explanation regarding data gaps and mismanagement that I
have seen to date.

Karen Kingston
Camp Bonneville RAB Co-Chair
Vancouver, WA

____________________________________________________
Subject: EPA Withdrawal from Camp Bonneville Base Closure Team

Dear Col. Conte:

This letter is to notify the United States Army of the Environmental
Protection Agency’s (EPA’s) decision to discontinue involvement with the
Base Closure Team (BCT) at the Camp Bonneville Base Realignment and
Closure(BRAC) site.  This is a decision that EPA has not made lightly.
However, given the particular circumstances at Camp Bonneville, EPA has
made a management decision to reallocate its limited staff resources to
other urgent cleanup needs in Region 10.  As Camp Bonneville is among
the Department of Defense (DoD) installations included in a Memorandum
of Understanding (MOU) between DoD and EPA, we have consulted with our
Headquarters Program Office on this matter and they have concurred with
our decision.

We made this decision knowing the State of Washington’s Department of
Ecology (Ecology) has increased its staff for Camp Bonneville.  Ecology
also has issued an enforcement order for Camp Bonneville.  As a result
of their increased investment at this site, Ecology requested that EPA
not continue in a concurrent oversight role.  We have decided to
withdraw from the BCT; however, we want to go on record with our ongoing
concerns, in the interest of supporting Ecology’s, the Army’s, and the
public’s interest in addressing the human health and environmental
issues at Camp Bonneville.

After the initial round of base closure legislation, the Department of
Defense (DoD) developed  guidance which relied on bottom up
decision-making by the military service, EPA, the state, and other
stakeholders.  The BCT was meant to work collaboratively to make cleanup
decisions and facilitate reuse of the property.  The DoD model and BCTs
have been successful in accomplishing those goals at both NPL and
non-NPL BRAC sites all over the country including Region 10.  In Region
10, the BCT model worked well at Sand Point Naval Station, Seattle,
Washington; Fort Greeley, Delta Junction, Alaska; and at Adak Island
Naval Air Station, Alaska.

In the case of Camp Bonneville; however, there has not been the level of
collaboration that is typical in the BRAC process.  Over the past seven
years of EPA involvement through the BCT, we have made every effort to
assist the Army in characterizing the risks to human health and the
environment at the Camp Bonneville site.  EPA has sought to provide
information and comments to help improve the site characterization
activities relating both to munitions and other contamination.  We also
provided comments to address what we believe are other significant
shortcomings of the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) cleanup process that was being implemented.
On many issues, the Army has not been responsive to EPA’s comments.
Enclosure 1 provides examples of significant data gaps and procedural
shortfalls at Camp Bonneville which are one result of the lack of
cooperation and collaboration in the BCT process.

Even though the Army has completed a number of removal actions,  the
site lacks the necessary level of site characterization information on
which to base long-term remedial decisions.  We are also concerned that
decisions about property transfer need to be based on better information
than is currently available.  There is only limited understanding about
the nature and extent of contamination primarily from munitions and
unexploded ordnance (UXO), but also in limited areas related to chemical
releases.  We believe that this information could have been developed
had the Army incorporated our comments into their characterization
workplans and related analyses over the past seven years.

We have made our concerns and comments known to Ecology.  We will
continue to provide support to Ecology on an “as needed” basis.   Please
contact me at (206) 553-4181 or at eaton.thomas@epa.gov with any
questions or concerns.


Sincerely,

Thomas Eaton, Associate Director
Office of Environmental Cleanup

Enclosure

cc:  Tim Nord, Ecology   sent via e-mail only
Barry Rogowski, Ecology  “”
Jim Woolford, EPA   “”
Brian Vincent, Clark County  “”
Karen Kingston, RAB co-chair “”
Eric Waehling, Army   “”
Nancy Harney, EPA

Enclosure1:

  Camp Bonneville Data Gaps

Significant data gaps at Camp Bonneville BRAC site include:

1. lack of geophysical investigations for the detection of subsurface
UXO/munitions in areas of concern such as the proposed Regional Park,
the artillery/mortar/rocket Impact Area, and Demolition Area 1
(Approximately 1% of Camp Bonneville has previously been geophysically
surveyed for subsurface UXO/munitions, 99% has not been surveyed);
2. lack of Remedial Investigations (RI) on the nature and extent of
contamination from UXO/munitions, and soil and groundwater contamination
at known disposal areas such Demolition Areas 1, 2,and 3;
3. lack of an RI to determine the presence/absence of soil and
groundwater contamination in the Impact Area due to munitions residues
(No soil or groundwater sampling data currently exists for the Impact
Area);
4. lack of public review and comment on the proposed response action
(EE/CA or Feasibility Study) to take place on Demolition Area 1,
including review of the CERCLA standards the Army expects to attain and
how these standards were derived;
5. demonstration of attainment of published cleanup standards (ARARs and
TBCs) for Demolition Area 1/landfill 4;
6. lack of lead hazard assessment for Camp Killpack where child-occupied
facilities are forecasted by the County;
7. improvement of QA/QC procedure for all site sampling including
adherence to accepted, published standards (MTCA specified QA/QC is only
a starting point);
8. assessment of QA/QC deficiencies from past field efforts to determine
if  these sampling events should be redone;
9. additional sampling of small caliber firing ranges to account for low
sampling density;
10. surface clearance of UXO/munitions the entire Camp including
“wildlife” areas which will inevitably be vulnerable to trespass;
additionally surface clearance is a required step in conducting
subsurface UXO/munitions clearance.
11. location of additional downgradient wells near demolition area 2
that are within 100 feet from Ecology’s best estimate of the location of
past demolition practices; and
12. lack of an RI/FS for all Camp areas which includes hazardous waste
issues, ordnance clearance, and assessment and removal if necessary of
ordnance residue.

Examples of CERCLA compliance issues and coordination problems:

1. noncompliance with various parts of CERCLA and the NCP including
inappropriate use of time-critical removal authority;
2. refusal to publish in any federal CERCLA Decision Documents clear
statements of the applicable requirements for cleanup actions taken,
such that regulators and the public may track the Army’s compliance; and

3. unilaterally making field changes without consulting regulators, in
some cases rendering the field work useless.

Concurrence 6/2003 EPA Withdrawal from Camp Bonneville Base Closure Team

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