2009 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Wed, 4 Feb 2009 08:55:23 -0800 (PST)
Reply: cpeo-military
Subject: [CPEO-MEF] MUNITIONS, REGULATION: Camp Bonneville (WA) Superfund petition
Submitted by Dvija Michael Bertish <dmb88@iinet.com>:


Elin Miller, Regional Administrator	
Michelle Pirzadeh, Acting Regional Administrator   February 3, 2009
United States Environmental Protection Agency, Region X
1200 Sixth Avenue, Suite 900
Seattle, WA 98101								Fax: 206-553-1809

Under the authority of CERCLA Section 105 (d), as amended, the petitioner,

(Name) : Dvija Michael Bertish, Rosemere Neighborhood Association, Columbia Riverkeeper
(Address) : Box 61471, Vancouver WA, 98666
(Telephone Number) : 360-281-4747

We hereby request that Region X of the United States Environmental Protection Agency conduct a preliminary assessment of the known and suspected release of a hazardous substances, pollutants, or contaminants at the following location:

Camp Bonneville, Former US Military Installation, Clark County, WA (just outside Vancouver, WA)

Petitioners are affected by the [release (or) threatened release] because: Camp Bonneville, a surplus military property, is the subject of a dirty transfer from the US Dept. of Defense (DoD), to Clark County Government, via a non-profit "nature conservancy" known as the Bonneville Conservation, Restoration and Renewal Team (BCRRT). The property is currently under a cleanup program with supervision by Washington State Dept. of Ecology. EPA Region X staff are very familiar with the issues (both known and unknown) at the site. EPA was formerly involved with the clean-up project, but in an extremely rare occurrence, EPA opted out of the project in July 2003 citing a lack of adequate site assessment and a lack of collaboration on the US Army's part. Given various circumstances that have occurred since 2003, members of the public firmly believe that this project requires EPA to re-engage and list this site on the National Priorities List to achieve a higher level of oversight and to ensure public health and safety. As a former member of the Camp Bonneville Restoration Advisory Board, the petitioner is very concerned about ongoing groundwater contamination that has not been successfully mitigated. Landfill 4 was evacuated - military ordnance and great amounts of soil were removed and clean fill replaced. Ecology stated clearly that post evacuation increases in groundwater contaminant levels would indicate additional (unidentified) sources. Ammonium perchlorate concentrations have increased to above 500 ppb, and there are additional concerns with TCE, and RDX. RDX has a 100 year lifespan in the environment. The groundwater contamination plume abuts and flows toward Lacamas Creek, a salmon bearing stream that feeds into Lacamas Lake, and then into the Columbia River. Lacamas Creek flows through the heart of Camp Bonneville, including the Central Valley Floor where new pollutant discoveries have been made since the project ensued. The surrounding residents all use well water as their potable water supply, however the water on site is unsafe for human consumption. The site exists within the EPA designated Troutdale Sole Source Aquifer System, and petitioners are concerned that federal dollars being expended on this project are not being used to sufficiently protect against further damage to the vulnerable aquifer system and offsite migration of contamination. Since there is a direct federal funding nexus to the project, the petitioners request EPA to invoke its jurisdiction citing Sole Source Aquifer designation in order to evaluate these concerns, as there appears to have been insufficient containment and monitoring (placement of monitoring wells).

Faulty site characterization has long been a problem on this project, and since clean-up activity began, there have been at least 9+ new Area's of Concern (AOC) identified. The new AOCs include new firing points, burial pits and practice ranges. Despite public comments regarding the probability of 155 mm Howitzer's being armed and fired on site, officials denied this concern, only to discover and detonate a Howitzer in the Central Target Impact Area in May of 2007. The find was near existing residential neighborhoods that were apparently built directly over the firing fans for this kind of projectile. Petitioners understand that the Army Corps of Engineers and/or the Dept. of Defense advised neighboring residences on the periphery of the site not to dig a pond or drive stakes into the ground on their own properties, however, there has been no additional planning to evaluate this public safety concern. In a January 12, 2009 letter from Baker Engineering & Energy (subcontractor) to BCRRT, Ecology's comments on the Draft Cleanup Action Plan include: "It is apparent from MEC data collected at the CVF [Central Valley Floor] that MEC types and distributions as well as their corresponding Explosive Hazard Rankings developed for Maneuver and Training areas need to be re-evaluated. The findings completely discredit the prevailing concept in the RI/FS that maneuver areas have negligible explosion hazard risks." Ecology also states: "Based on current available field data it is obvious that the selected cleanup actions for Maneuver areas, especially within the Regional Park, fall short of protectiveness in terms of long-term effectiveness. A more protective action should take into account surface contamination, and in some areas, subsurface contamination as well." In response to Ecology's concerns, BCRRT staff seems to indicate that risk from new anomalies is "unlikely," and that more empirical data is required to determine if the threat is real. The public insists that the project is well beyond the need to prove whether the threat is real or valid. Various parties of record were denied the opportunity to offer scoping comments on the supplemental RI/FS. To date, the public has not seen a supplemental RI/FS to offer public comment, even though cleanup activity is presumably still underway. Petitioners voiced concern through the RI/FS process that the site was inadequately characterized, and that such data gaps would elevate risk assessment for the intended re-use of the site as a public park and overnight campground, but these concerns were ignored or rebuffed by officials running the project.

In a January 31, 2009 Columbian Article [Army Contests Camp Bonneville Costs; Contractor defends dubious expenses, including large bar tabs], the BCRRT contractor, Mike Gage, states that BCRRT "[has] found several things on-site that we believe are Army-retained conditions that they did not disclose to us." It has now been publicly acknowledged by the contractor that the federal funds budgeted to this project are insufficient to achieve cleanup standards necessary for the intended re-use, and the contractor will be seeking additional federal funding to cover the data gaps that were pointed out by EPA and the public prior to the inception of this project. The Columbian article continues with descriptions of misappropriated federal funds from the project expense records, a lack of oversight between Clark County and the contractor, and the contractor claiming that the project is a private contract that allows him to spend federal cleanup dollars as he so chooses without oversight. In published responses to the Columbian Article, the public perceives these developments as project mismanagement, collusion, and greed.

It is important for EPA to list this site on the National Priorities List simply because the public needs better federal oversight to ensure that the clean-up standards are achieved for optimum risk assessment to protect the public health and safety on this project. Superfund listing would provide additional oversight and would require de-listing prior to release of the site for re-use implementation. The petitioners firmly believe this layer of protection is necessary due to unmitigated circumstances at the site. Clark County officials have openly stated that conditions on this site allow for an "acceptable risk" for the intended re-use as a public park, a position that many people from the public vehemently oppose. Institutional controls call for MEC to remain on site in perpetuity, to be cordoned off by a three strand barbed wire fence adjacent to planned public recreation facilities. Many members of the public have argued that Camp Bonneville is unsuitable for a public park and that they would never bring their children to the site. This public perception is detrimental to the public's interest in this project, especially in light of financial shortfalls currently forecast. The EPA would be better suited to manage additional federal resources and what's left of the current operating budget since financial oversight and accountability are lacking. It appears that Ecology is in need of assistance to bring clean-up standards to bear under CERCLA and MTCA regulations given the new discoveries.

Given that Camp Bonneville is a precedent setting project that sets an example for other military clean-ups of its kind, it is imperative that EPA help to establish improved protocols in order to protect other communities around the nation from experiencing the depth of confusion and largesse experienced on the ground in Clark County. The protocols noted in a Dept. of Defense/EPA document entitled "Management Principals for Implementing Response Actions at Closed, Transferring, or Transferred Ranges," clearly outline intended practices, including collaboration between EPA and DoD, that have been absent from Camp Bonneville's active clean-up. The petitioners hope that EPA can re-energize these much needed protocols and apply them with due diligence to Camp Bonneville's restoration efforts.

Type or characteristics of the substance(s) involved: Ammonium Perchlorate, Trichloroethane, Dichloroethene, Cyclotrimethylenetrinitramine (RDX), HMX, Lead, Chromium, Mercury and others. An extensive list of Militarized Ordnance including mortars, missiles, grenades, chemical warfare agents, and unknown contaminants located in new burial pits. Potential for radioactive materials. Nature and history of any activities that have occurred regarding the release/threatened release: The sources of contamination are military landfills, target impact areas, firing ranges, burial pits and open burn pits, and documented groundwater contamination.

Federal, State and local authorities you have contacted about the release/threatened release and the response, if any: Washington State Dept. of Ecology, Barry Rogowski, Tim Nord, Ben Forson, Greg Johnson, Dawn Hooper; Martha Lentz, Sole Source Program, EPA Region X; Jonnie Hyde, Clark County Health Dept; Nancy Harney and Harry Craig, EPA Region X; Steve Stuart and Marc Boldt, Clark County Commissioners. Bill Barron, Clark County Administrator. Bill O'Donnell, US Dept. of Defense, Pentagon. Katherine Hanks, Environmental Health Scientist, Agency for Toxic Substances and Disease Registry; Jeroen Kok, Clark County Parks and Recreation; Pete Capell and Jerry Barnett, Clark County Public Works; Mike Gage, BCRRT Contractor; Taylor Aalvik and Nathan Reynolds, Cowlitz Tribe; Ed Marshman, FBI Portland, OR; Vancouver Fire Department District 5; Washington Department of Natural Resources; Camas/Washougal/Woodland Veterans of Foreign Wars and Veterans Administration Land Acquisitions, Willamette Cemetery Portland, OR; Gary Lucas, Clark County Sheriff; Department of Toxic Substances Bureau, San Francisco; Earl Blumenauer, Oregon Congressman; Brian Baird, Washington Congressman; Patty Murray and Maria Cantwell, Washington Senators; Governor Christine Gregoire, Washington.

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