[CPEO-MEF] Adminstrative Record at Camp Bonneville

[Lenny Siegel <lsiegel@cpeo.org>]

Submitted by Karen Kingston <Karen4theCamp@cs.com>


Ian Ray has brought an interesting question to the Camp Bonneville RAB
in his request to understand BRAC Administrative Record rules. 

Our contracted-BEC stated the Information Repository was also an
Administrative Record (AR) for Camp Bonneville at a recent RAB meeting. 
However, BRAC responded by noting the AR is located at Ft. Lewis, WA.
and is a complete master AR for Camp Bonneville.    Therein lies Ian's
question....whom to believe and why isn't it openly available to the
public. 

The following information is from my ongoing experience:  The AR for any
closed base is the master document file that also contains letters,
memos, etc., from regulators or anyone else advising.  In the case of
Camp Bonneville if an issue such as Early Transfer arose, the Governor's
office would then call for the AR as could Congress and/or other top
level officials or litigation.  The AR must be up to date and
ready-complete to be forwarded with short notice. 

The Information Repository as defined must be a compilation of projects,
contracted planning, surveys, RAB minutes, etc.  In the case of Camp
Bonneville the IR is held at a local library branch and contains volumes
upon volumes of public documents dating to our closure in 1994.  An IR
gives a local community access to current work information and reference
material on past work for the site. 

I have found that many people around the country involved at the
community level are unaware of an AR for their base.  Many assume the
Information Repository work-file is the bible for their site.  It is not
and I cannot stress the importance of a yearly checkup on information
within your site's AR.  I would not suggest overburdening your site's
BRAC coordinator by asking for a copy of the full file and instead
suggest asking for a copy of the Administrative Record Index.  This will
save copy fees.  Then you may request copies of particular indexed items
individually.  You will know if you have been given the correct index,
not just a copy of the IR index, because it will index letters and any
advisories sent by politicians, regulators, contractors, or citizens
requesting their advisory be contained within the AR.  I can only assume
your coordinator will comply with an AR request by merely asking; if not
send a FOIA. 

In 2002, I and another RAB member found that Camp Bonneville was without
an Administrative Record, a federal violation.  Some document copies
were at the IR, files were reported kept in various employee desks,
other document files contained within misc. correspondence in offices
within the Army.  The EPA stepped in and the Army was given an order
upon which it jumped into action by hiring the Corp of Engineers to
formally compile an AR.  I am pleased to report that a formal AR for
Camp Bonneville now exists and BRAC confirms that it is up to date and
complete. 

RAB members should consider what would happen to their transferring site
or parcel if a current person in charge could assemble a chronology and
history containing only documents they personally feel present the
closed base's profile.  As a citizen I feel it is also important for ARs
to contain the community's voice regarding specific contamination,
cleanup projects, as well as other issues such as wildlife, tribal
concerns, and the like.  In order for this to happen, you must add
within the text of your letter/advisory that your letter is to be
contained within the site's AR.  If you do not make this request, I have
found it is military and regulator protocol to file your letter within
its own correspondence files.  When you do your yearly Index check look
for this letter/advisory within the AR Index provided to you. 

You may also want to forward your copy of the index to your site's
regulator (Dept. of Ecology, EPA, Dept. of Energy). I have been told
that a regulator cannot regularly check the AR without cause and I feel
that it is important for all ARs to maintain consistency by containing
current regulator letters, memo's, and advisories.  Providing this
yearly Index copy allows the regulating office to crosscheck for
omissions.  You may well find surprises in your Index, such as
confirming compromises or advisories/demands that was not within earshot
of your RAB.  The AR is the document compilation the future will read
and adjudge. 

Should a local Information Repository contain community cleanup
advisories?  Ian has a good question.  My only concern: If we only have
a choice, I prefer my advisory be contained in the master AR and not
sitting on dusty IR library shelves.  Kudos to Ian if he can get these
in both places.  Ian has been a valiant marauder for community concerns
here. 

Karen Kingston  Vancouver, WA  
Karen serves on the Camp Bonneville RAB as Community Co-Chair  
<Karen4theCamp@CS.com>

-- 


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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