[CPEO-MEF] Honey Lake Transfer

[Lenny Siegel <lsiegel@cpeo.org>]

[Today I am submitting to the Army the following comments on the draft
Finding of Suitability to Transfer nearly 60,000 acres at the Sierra
Army Depot. - LS]

I appreciate the opportunity to comment on the Draft Finding of
Suitability for Transfer for Honey Lake (Phase I) at the Sierra Army
Depot. In principle, I support the proposed transfer to a Natural
Resource Conservation Organization. However, I am concerned that no
party has adequately investigated the proposed transfer property to
support the finding that the property is suitable for transfer.

It is my understanding that Honey Lake is downstream from areas where
the Army and others have historically disposed of large quantities of
munitions and solid rocket fuel through open burning and open
detonation. Normally, such operations release heavy metals and explosive
constituents into the environment. Such pollutants are therefore likely
to be found in the waters of Honey Lake, its sediment, or in ground
water or surface channels feeding Honey Lake. At least, there is enough
reason to suspect such contamination that actual sampling should take
place before the property is cleared for transfer.

I am particularly concerned about perchlorate. The Sierra Army Depot
permitted at least one private contractor, United Technologies, to
demilitarize large quantities of solid rocket fuel on its property. I
have been informed that these activities took place upstream from Honey
Lake. Since United Technologies has found very high concentrations of
perchlorate at its Santa Clara County facilities, where it previously
conducted similar operations, there is reason to suspect serious
perchlorate contamination at Sierra.

I believe it would be prudent - indeed, it may be mandated by law and
regulation - to conduct sampling for perchlorate and other constituents
and byproducts of munitions before certifying Honey Lake clean enough
for an otherwise suitable transfer.

Lenny Siegel
-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

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