Ms. Stacy Braye
U.S. Environmental Protection Agency
Region 9
75 Hawthorne St.
San Francisco, CA 94105

February 11, 2002

Dear Ms. Braye,

Following are comments on behalf of the Chemical Weapons Working Group (CWWG) and the Non-Stockpile Chemical Weapons Citizens Coalition (Coalition) on the JACADS Closure Modification. We are submitting these comments pursuant to 42 U.S.C.§6924, 6925 and 40 CFR§264.110-120, 264.351, and 270.32 (b)(2).

GENERAL COMMENTS

1) Data gaps in the document, as a result of the September 11 incident, make comprehensive review of the Closure documents very difficult. As soon as possible, that information should be released to the public.

2) It still does not appear that PMCD is coordinating with the Air Force on clean-up of Johnston Island. That is unfortunate as coordination would save resources; be much more efficient for the agencies, contractors, regulators and citizens who are asked to provide comments on both clean-up proposals; and result in a higher level of "clean" for the island as a whole.

SPECIFIC COMMENTS

It appears as though many of the comments we submitted in September 2000 have resulted in changes to the Closure plan. We appreciate EPA's willingness to follow through with our earlier recommendations. However several issues remain:

1) We oppose the use of incineration for destruction of any materials during JACADS Closure. The Army has had plenty of time, and plenty of opportunities to choose non-incineration technologies for closure activities. Ironically, Attachment J page 23 notes that items not "amenable" to incineration during the Closure process will be chemically decontaminated. In our opinion, the inherent flaws in the incineration technology -- namely that chemical agents and other toxics cannot be neither controlled nor contained -- makes the technology unsuitable for any waste stream.

That same section notes that for wastes which cannot be incinerated, an alternate treatment plan will be submitted to EPA. This statement shows clearly how the Army knows full well that alternatives can -- and probably will -- be used during Closure. Their adherence to the incineration technology is unacceptable.

2) Regarding the Human Health Risk Assessment methodology, we question the rationale to use an exposure model that includes risks from dermal and oral contact and ingestion of toxics but does not include the risk of inhalation of toxics. Aside from the fact that incineration is the Army's preferred technology for as much JACADS wastes as possible, the dismantling of buildings and equipment will surely result in airborne toxics. Therefore, workers could be exposed to toxics via inhalation.

3) In Appendix B IV, the QA workplan, lewisite does not seem to be listed for sampling. Please clarify whether or not Lewisite was/is present on JI, and if so, the rationale for omitting this chemical agent from sampling.

4) Regarding the Human Health and Ecological workplan, clarify the statement that the risk assessment will not include the potential for exposures from direct inhalation, because "incinerators will have ceased operating." (Table V(a) - 2.1). See comment #2 above.

5) Because the ultimate fate of the Munitions Demilitarization Building (MDB) has not yet been determined, it is impossible to comment specifically on its impacts. The Army should not undertake any closure-related activities in this building without public notification or approval from EPA.

6) In Attachment J Section C2, the "maximum waste inventory" was not included because, in the Army's words, those activities were "in the past" -- implying that they are not relevant to closure. On the contrary, the maximum waste inventory is an indicator as to what items may still be left to destroy. This is entirely relevant to closure activities. Please clarify any perceived security issues that would prevent this information from being released to the public.

7) Regarding off-site non-agent contaminated waste shipments, please clarify the type, location and contractors of TSDFs receiving these wastes. The CWWG and Coalition oppose the incineration of any off-site wastes.

8) We concur that wastes containing mercury should not be burned.

9) There still does not appear to be any plan for disposal of PCBs and PCB contaminated wastes associated with chemical weapons activities. The Army should not be allowed to process PCB wastes without a specific plan, and the opportunity for public comment.

Thank you for accepting these comments. The Army and its contractors should be held to the highest possible clean-up standards for JACADS and Johnston Island, for the protection of future Island residents and the Pacific ecosystem.

Sincerely,

Elizabeth Crowe
Chemical Weapons Working Group
Non-Stockpile Chemical Weapons Citizens Coalition