2009 CPEO Military List Archive

From: Lenny Siegel <lennysiegel@gmail.com>
Date: Wed, 24 Jun 2009 19:45:35 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] BIOTA, COMMUNITY: Comment, re U.S. Natick [MA] Soldier Systems Center's Proposed Plan for Toxic Sediment Removal from Lake Cochituate
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.
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.

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.

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.

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."
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.

--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

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