[CPEO-MEF] BIOTA, COMMUNITY: Comment, re U.S. Natick [MA] Soldier Systems Center's Proposed Plan for Toxic Sediment Removal from Lake Cochituate

[Lenny Siegel <lennysiegel@gmail.com>]

From: Dick Miller <TheMillers@millermicro.com>

Hi, Lenny:

You already posted the standard announcement of US Natick Soldier
Systems Center's (U.S. Army Natick Laboratories') proposed plan to
remove some of its toxic sediments from Lake Cochituate. Below is my
personal attempt to address the issues it chose not to discuss.

As always, thanks for your excellent coverage of other military clean-ups.

I'll be looking for signs that we won't have to live with this pollution
forever in the major recreational lake in eastern Massachusetts. And,
perhaps, to find good examples of mitigation money for the belated
removal of a nasty invasive weed, which might have been removed in a
timely manner if it hadn't first appeared in the midst of SSC's toxic
sediment (and probably via that facility's adjacent boat launching ramp).

Best wishes from
--Dick Miller
  Member, U.S. Natick Soldier System Center's Restoration Advisory Board
  Member, Cochituate State Park Advisory Committee

I appreciate this opportunity to comment in writing on the U.S. Natick 
Soldier Systems Center's Proposed Plan for Toxic Sediment Removal from 
Lake Cochituate.
(http://www.epa.gov/region1/superfund/sites/naticklab/448238.pdf)
My personal comments are based on my background as a physicist and 
engineer, my 41 years of volunteer environmental activism including past 
Chair of the Natick Conservation Commission, Executive Director of the 
Lake Cochituate Watershed Association, member of the Cochituate State 
Park Advisory Committee since its founding, Chair of the Natick Cancer 
Study Task Force, continuous membership on this facility's Restoration 
Advisory Board (RAB) since its founding, participation in dozens of 
workshops including several national-level ones for DOD clean-ups, and more.

As I stated orally, I have three main comment topics, as follows.

1. PUBLIC PARTICIPATION PROCESS:
    In scheduling the public meeting without including the Restoration 
Advisory Board, the public participation process was evaded at 
considerable cost - no official Town or Mass. DCR participation, and few 
others who could attend on that night. From now on, include your RAB! I 
thank the EPA, Army and other RAB members who corrected that with a 
second public hearing (quite unusual). I'm also glad that the 6-day 
period (after the good hearing) that the Army offered for written 
response was extended to about half of the usual 30 days.

2.  EXTENT OF CLEAN-UP:
    The Army proposes to leave toxic sediment in our lake, and even in 
shallow water, if it isn't toxic to the level of 1 part per million. 
That is no more clean-up than is done at, for example, the Nyanza 
Chemical superfund site in Ashland, Mass. But the Nyanza clean-up area 
is dry ground, high over the water table, and far away from houses, 
wells, ponds or popular river stretches or other public recreation areas.
     Why no better at Lake Cochituate, in Cochituate State Park? This 
is in the water, in the major recreational lake in eastern 
Massachusetts! The general answer is that they don't measure better, so 
they don't clean better. Plus, we are told, the current risk estimates 
indicate that this level is adequate.
     Unfortunately, the current risk estimates don't make sense. Our 
average national cancer incidence rates - and the higher rates here - 
have risen over the decades since 1940. Lower age levels are impacted 
even more. If chemical risk estimates were correct, we would not have as 
much cancer as, in fact, we do. We don't sufficiently understand the 
problem - yet propose to use our lake as a receptacle for a considerable 
remainder of the Army's past pollution, based upon the fallacious 
assumptions that we inherit. That is illogical, and justifies sediment 
removal from a wider area. You put it in; take it out!
    Surely it is cost-effective to include the additional sediment 
removal during this clean-up operation, rather than in a future year. 
And meanwhile, doing so would reduce health risks we cannot yet 
quantify; that's the Precautionary Principle.
(http://millermicro.com/PrecPrin.html)

3. DAMAGE MITIGATION:
    The Army proposal does not consider any damage mitigation beyond 
the removal of its toxic sediment, and has failed to document years of 
RAB concern about disturbing its toxic sediment to uproot invasive 
weeds. (Eurasian water milfoil, a highly invasive weed that first 
appeared in Pegan Cove in 2002, has since spread downstream to the 
entire chain of ponds, and will be very expensive to control while 
protecting the Town of Natick's adjacent drinking water wells from 
exposure to more questionable chemicals.) In fact, at the May 2009 
meeting of the Cochituate State Park Advisory Committee, the Army stated 
that no such mitigation recourse exists. But it does - including the 
U.S. Natural Resource Damage & Restoration Assessment Program.
    A key paragraph on the US NRD web site states:
"Natural resource injuries may occur at sites as a result of releases of 
hazardous substances or oil. Trustees use NRDAs to assess injury to 
natural resources held in the public trust. This is an initial step 
toward restoring injured resources and services and toward compensating 
the public for their loss."
(http://www.epa.gov/superfund/programs/nrd/primer.htm)
    I formally request that the Army and RAB members actively cooperate 
in a full report and pursuit of these restoration options (not limited 
to NRD), concerning the Army sediment's partial cause for the spread of 
invasive weeds in Lake Cochituate.

Sincerely,
--Dick Miller, Partner, MMS <TheMillers@millermicro.com>
  Member, Natick Soldier System Center Restoration Advisory Board
  Member, Cochituate State Park Advisory Committee

--


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
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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