maintained in between emergency responses. Indeed, the Army achieved just these benefits when it located several EDSs at Pine Bluff (NRC, 2004).

Finding 3-7. Potential cost savings are likely to be realized by co-locating resources on one of the large burial sites, so that emergency response functions can be deployed efficiently.

Recommendation 3-7. The Army should evaluate and select one of the buried CWM sites as the location/repository for its emergency response operations in order to increase the cost-effectiveness of the overall program and maintain flexibility (NRC, 2004).

THE IMPORTANCE OF PUBLIC INVOLVEMENT

The importance of constructive and open engagement of the public by the U.S. Army in its policy decisions regarding non-stockpile materiel has been emphasized in several earlier reports from the National Research Council (NRC, 1994, 1999, 2001a, 2001b, 2002) and other organizations (EPA, 2001, 2002b, 2009a, 2010b; U.S. Army, 2007d). Indeed, many of the alternative treatment technologies for chemical agents owe their existence to public concerns and the influence of the public on Congress and the states.

Munitions response actions are governed by a number of laws at the federal, state, tribal, and local levels. As noted above, public involvement is embedded in RCRA and CERCLA (U.S. Army, 2005; EPA, 2005). In addition, the Emergency Planning and Community Right-to-Know Act (EPCRA) requires military installations reporting releases of listed hazardous substances to complete and make public the Toxic Release Inventory annually if the quantities exceed the reporting threshold.17

These regulatory frameworks detail the community engagement and stakeholder participation activities to be followed by the lead agency at MRSs. Further, DOD and Department of the Army regulations and policies provide a framework to guide military decision makers—installation commanders as the executive agent on active DOD installations, and the U.S. Army Corp of Engineers (USACE) as executive agent at FUDS—on requirements for conducting public outreach and involvement activities (U.S. Army, 2004a, 2004c, 2005, 2009c, 2009d). The Non-Stockpile Chemical Materiel Program (NSCMP) never has primary responsibility,18 but it does play a support role—for example, by providing literature for distribution and meeting with residents of impacted neighborhoods.

Feedback from stakeholders, reported in an earlier committee report (NRC, 2002), indicates that the U.S. Army has made considerable progress in providing information to the public and improving communications with stakeholders. Stakeholder feedback has identified a number of issues that typically are of high concern to members of the community. For example, there has been widespread opposition to importing out-of-state wastes that could result in a site becoming a dumping ground, with a correspondingly high preference for mobile destruction technologies. In addition, nonincineration technologies have received broad acceptance as an advance over open detonation, but some community members have expressed concern about the costs associated with the new technologies (NRC, 2002).

The approach taken at different sites may vary, based on the level of public interest. For example, Spring Valley, in Washington, D.C., has a very active restoration advisory board (RAB), while at Camp Sibert, Alabama, the public has not shown any interest in having such a board. Both sites hold public meetings, offer literature to the public, and provide information to the media. The key issue facing the Army as it starts to remediate large buried CWM sites is whether to keep its public involvement program modest in size, in proportion to the limited public interest expressed, or to expand its efforts in case public concern materializes as the buried CWM remediation program grows.

Finding 3-8. The U.S. Army project managers at current CWM sites have recognized the importance of public engagement and are supported appropriately by NSCMP.

Recommendation 3-8. As the U.S. Army undertakes remediation at the larger CWM sites, project managers should anticipate that there will be more public concern and continue to seek proactive public engagement. They should take steps to ensure that communications from the different participating organizations are coordinated.

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17David Lyon, Environmental Specialist, Environmental Division, Assistant Chief of Staff for Installation Management/Supply Directorate, personal communication to Derek Guest, committee member, on November 23, 2011.

18Laurence G. Gottschalk, PMNSCM, personal communication, to Richard Ayen, committee chair, November 29, 2011.



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