Re: Former Tobyhanna Range

[Lenny Siegel <lsiegel@cpeo.org>]

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Some questions came up in response to my original (July 30, 2004) report
on the Tobyhanna Artillery Range (quoted below).

First and foremost, it should be clear that there is no suggestion that
the developer of the residential development at Lake Watawga has done
anything wrong.

Second, requests to local officials to defer development were informal.
This reinforces the lesson that there needs to be a better way to
coordinate health and safety concerns into development decisions.

Third, though fire-fighting organizations responsible for suppressing
forest fires have declared a non-suppression zone around the FUDS, the
local file department still responds to fires within the residential subdivision.

Lenny

Lenny Siegel wrote:
> 
> On Tuesday, July 20, 2004 I toured the former Tobyhanna Artillery Range,
> a Formerly Used Defense Site (FUDS) in northeastern Pennsylvania. Below
> is a brief summary of what I learned from my visit and background
> documents. For more information on the Tobyhanna FUDS, see http://www.dep.state.pa.us/dep/deputate/airwaste/wm/remserv/Tobyhanna/Tobyhanna.htm.
> 
> The Tobyhanna Artillery Range was an active military installation from
> 1912 until 1949, when most of the property was transferred to the
> Commonwealth of Pennsylvania. It served as an artillery range and impact
> area during World War I (1914 - 1918) and again at the beginning of
> World War II (1937 - 1941). Ordnance fired at the site included 37-mm,
> 75-mm, and 155-mm conventional munitions.
> 
> Today, most of the FUDS is comprised of the 7000-acre Tobyhanna State
> Park and 14,000 acres of State Gamelands. Tucked into a corner of the
> FUDS is the still active 1300-acre Tobyhanna Army Depot, which is on the
> "Superfund" National Priorities List. Though it has ordnance
> contamination as well, its principal environmental challenge is
> groundwater polluted with trichloroethylene.
> 
> Though most of the land was deforested during its use as an Army Range,
> most of the park and gamelands are now covered with a thirty-foot canopy
> of deciduous forest.
> 
> In 1997-98, the Baltimore District of the Army Corps or Engineers and
> its contractor conducted a time-critical unexploded ordnance removal
> action at the Tobyhanna State Park. 274 items, primarily 37-mm
> projectiles, were removed from camping and picnic areas, a boat ramp,
> and trails.
> 
> Though they covered a small portion of the range, they concluded that
> budget limits would prevent them from conducting further activities
> until about 2016. Concerned about this risk to visitors, the
> Pennsylvania Department of Environmental Protection (DEP) stepped up to
> the plate, promising more than $3 million from its Hazardous Sites
> Cleanup Fund to carry out an EE/CA (Engineering Evaluation/Cost
> Analysis). In early 2003 DEP negotiated a unique partnership with the
> Army Corps, not only to conduct the EE/CA, but to ensure that it would
> be sufficient to support future Army-funded cleanup.
> 
> Since then, the EE/CA has evolved into a Remedial
> Investigation/Feasibility Study (RI/FS), with the Corps agreeing to fund
> additional requirements, such as an explosive risk analysis. I was
> unable to determine, however, what methodology will guide that risk
> analysis. The partnership and its contractor, Weston Solutions, are
> using grid, transect, and meandering path sampling to cover about 2% of
> the entire FUDS. They will also sample for common explosive
> constituents. The purpose of the RI/FS is to develop, with the help of
> public comment, "a comprehensive removal and cleanup project in the near future."
> 
> When Corps representatives visited Tobyhanna in April, 2003, they found
> exposed ordnance in the gamelands area. They asked the Games Commission
> to restrict access, and they organized another time-critical removal
> action. The Corps cleared roads and trails, removing numerous 75-mm
> shells and one 155 mm round from those rights-of-way.
> 
> The Game Commission temporarily shut down the area, but deer and turkey
> hunting is considered a right in this region, and no accidents have been
> reported in the past. So it opened the property up after all. The Corps
> prepared a video to warn hunters and other visitors not to tamper with
> suspicious objects. However, there does not appear to be a comprehensive
> site security plan.
> 
> The local community appears supportive. There is a Restoration Advisory
> Board (RAB) at the Depot, and more than 40 people attended a public
> availability session for the Range project, but in the absence of
> sustained local interest, the  Corps plans to form a Technical Review
> Committee, not a RAB, to oversee Range response.
> 
> I met with a Depot RAB member, a long-time resident who has been
> following the munitions response activities. He said that long-time
> residents know about the UXO, and they know to avoid it. He explained,
> however, that parts of the area are becoming a bedroom community for New
> York City, and the newcomers don't understand the risks.
> 
> Also during the April 2003 visit, the partners discovered two live
> (75-mm and 155-mm artillery shells) rounds, several empty 155-mm rounds,
> and evidence of high explosive detonations at the northern edge of the
> Tobyhanna State Park, adjacent to an ongoing residential development at
> Lake Watawga. This project, planned to expand up to the Park (and FUDS)
> boundary, consists of wooded luxury homes, many of which are being built
> lakeside. Munitions debris has been found on the property now undergoing
> development, and most of the project is within the fragmentation safety
> zone for munitions found within the park. The Corps requested that local
> planners halt development, but they did not agree, and apparently
> neither the state nor the Army has the authority to even delay this
> private project.
> 
> The risk isn't simply from the direct impact of on-range explosions.
> After fires "cooked off" ordnance within the State Park, local
> firefighters declared the park, gamelands, and a buffer zone, including
> the subdivision, non-fire-suppression zones. That means that these
> expensive new homes will not be protected if there's a fire in the park.
> 
> Consequently, the Corps has proposed another time-critical removal
> action, to create a buffer zone of several hundred acres in the northern
> portion of the park, both to reduce direct risk and to allow
> firefighters into the area. DEP and the community member strongly
> support this proposal, but thus far the money has not been available.
> The Corps would like to line up the funding soon, to avoid what may be
> up to as much as $250,000 in remobilization costs.
> 
> Clearing several hundred acres to magnetometer depth would be expensive,
> perhaps costing over $10 million, but it should be possible for a lot
> less money to conduct a geophysical investigation, clear ordnance items
> found on the surface, and create a digital map to support the RI/FS and
> future cleanup. The Corps shouldn't wait too long to return, however.
> The freeze-thaw cycle brings ordnance to the surface every year. There's
> another reason to act quickly: Intrusive clearance and the open
> detonation of shells may require evacuation from a safety zone
> determined by the size of the ordnance. The more homes that are built
> near the park boundary, the more evacuation - with expected displeasure
> from residents - will be required.
> 
> ***
> 
> Lessons Learned
> 
> I've argued for some time that the size (explosive potency) of UXO
> shouldn't determine cleanup strategies, because the goal should be to
> prevent encounters no matter how big the potential blast. However, I
> learned from this visit that size matters along the boundary, because it
> determines what areas beyond the boundary lie within the explosive
> hazard zone.
> 
> I and others have been warning that once-remote impact areas are now
> being developed with housing, and that the national munitions response
> strategy needs to take that into account, particularly if developers
> assert their right to develop in dangerous areas. The Army Corps,
> regulatory agencies, and private financial/insurance companies, as well
> as the public at large, need to develop what I call a "To Build or Not
> to Build" strategy for munitions response areas. And the Defense
> Department's prioritization protocol for munitions response should be
> flexible enough to consider risks that are increased by proposed or
> actual development.
> 
> Finally, the underlying problem is that the FUDS program is grossly
> underfunded. That's why the Baltimore District cannot respond quickly to
> the clear need at Lake Watawga. That's why Pennsylvania is funding most
> of the RI/FS for the Tobyhanna Range. While the partnership between the
> state and the Corps is admirable, I am concerned that other states will
> be expected to do the same. If they determine that their residents are
> at serious risk, but the FUDS program won't get to a site for decades,
> will they be expected to fund a response? Will more developers go out
> and fund cleanup on their own - as in Colorado and California - and hope
> to be reimbursed? The response is the responsibility of the responsible
> party, so it's the duty of the Defense Department to request the funds
> to meet its obligations. Every year Congress appropriates more for the
> FUDS program than Defense requests, but the Department keeps its
> requests flat.
> 
> The FUDS munitions response program was jump-started by the death of two
> boys in San Diego in 1983. Will it take more casualties to find the
> funds to address documented risks such as those found at Tobyhanna?
> 
> Lenny
> 
> --
> 
> 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
> 


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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