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Fort Sheridan/Lake Michigan

The United States Army has closed Fort Sheridan according to the Base
Closure and Realignment Act.  This former base is located twenty miles
north of Chicago on the shore of Lake Michigan.  Since the 1940ís, the
Army has used seven ravines on the property as landfills.  These ravines
are natural drainage systems for rainwater and groundwater into Lake
Michigan.  Landfill #7, which will be explored in detail as the most
toxic, is situated on the edge of a bluff less than 200 feet from the
lake.  According to the U.S. Geologic Survey, bluff erosion in this area
ranges between 4 and 30 inches per year depending upon fluctuating lake
levels.  There is great risk that the bluff erosion will cause this
landfill to pollute Lake Michigan.

According to historical documents, landfill #7 was used to dump
radioactive dials and gauges associated with the Nike anti-aircraft
missile program for which this fort served as the regional maintenance
facility.  Historical accounts also show that PCB containing
transformers were deposited in this ravine.   The Remedial
Investigation-Risk Assessment/Feasibility Study (RI-RA/FS) testing of
the soil, groundwater, water, and sediment from this landfill reveals
the following chemicals to be above tolerance levels: lead, arsenic,
thallium, acetone, chloroform, cadmium, mercury, cyanide, benzene, 
beryllium, PNAís, sulfate, chloride, barium, chromium, zinc, selenium,
among numerous others.

The United States Army is the lead agency in analyzing cleanup
alternatives and making the final determination for remediation. 
Besides being the original polluter, the Army will also be financially
responsible to whatever cleanup method is determined necessary.  The
conflict of interest is glaring.  The Army has consequently determined
capping the landfill in place to be the preferred alternative.  This is
the least costly of the alternatives and the one that is the greatest
ecological danger to the community and Lake Michigan.  The analysis in
the RI-RA/FS is full of inconsistent and flawed logic which always seems
to benefit  the capping option.

The chemicals which show up in the testing are downplayed as being
common among Municipal Solid Waste Land Fills(MSWLF) while the
historical documents of waste of higher toxicity are belittled as
anecdotal.  The report does not consider that waste of higher toxicity
shown by these historical references may be at the beginning of an
extended decay and release which may not have shown up yet in the
testing.  The radioactive dials and gauges may eventually come in
contact  with acidic waste which would then release the radioactivity. 
Unknown containers of chemicals may not have decayed to the point of
release yet.  The known chemicals are highly toxic and bio-accumulation
will multiply the long term risks of even small quantities being
released.  The Army resists, at all stages of analysis, doing a more
effective investigation into the contents of the landfill.

Very little is mentioned of the landfill being located on the shore of
Lake Michigan in the RI-RA/FS or the Final Focused Feasibility
Study(FFFS).  The Great Lakes represent 95% of this countries fresh
water supply yet the analysis is based on the effects of the landfill on
the community in which it is located.  The site selection and design of
this MSWLF runs contrary to federal law.  The Clean Water Act,  40 CFR
241.204, 42 U.S.C 103 & 9618, The Pollution Prevention Act, the Great
Lakes Water Quality Agreement with Canada, and numerous other federal
laws prohibit the placement of a MSWLF,  much less the potentially more
toxic materials in landfill #7, on such a geologically unstable site as
an eroding bluff 50 feet above a major source of fresh surface water. 
The Army analysis does not address the U.S.G.S. observation that even
aggressive erosion barriers are ineffective because the erosion is
necessary in providing sand down lake which protects the underlying
finer textured lake bed from exposure to wave attack.  Coastal retreat
thus accelerates with aggressive vetments and the long term effect is
that the landfill will become an island.

Another logical flaw is in the cost/benefit analysis.  The cap will cost
$18 million.  Excavation will cost $38 million.  The Army reasons that
the known character of the chemicals does not necessitate excavation and
can be effectively contained by capping.  They further state that
excavation can lead to much higher costs.  If, during  excavation, the
waste is determined to be hazardous then the cost would go up to $135
million because of the additional cost of disposal fees in an
appropriate facility.  If the waste is so hazardous as to trigger land
disposal restrictions then the waste would have to be incinerated before
being placed in an appropriate facility and the cost would then become
$711 million.  The reasoning that excavation could lead to unjustified
higher costs based on the known character in the chemical analysis is
erroneous.  If during excavation the waste were determined to be higher
in toxicity than the chemical analysis now shows then the higher cleanup
costs would be completely justified and the imperative to remove this
type of waste from the shore of Lake Michigan would be certain.  The
Army decision to resist investigation into the actual character of the
waste and to make the final determination based on todayís imperfect
knowledge is then a catch 22 that benefits the less expensive capping

The risks to health and the potential for accident are fully explored in
the excavation analysis yet in the capping analysis, the potential for
system failure over itís infinite time frame is never analyzed.  The
fact that the cap must not shift for it to remain effective is never
held up to the fact that a ravine is the product of natural erosion and
will continue to deepen and cause the contents of the landfill to shift
and settle.  The groundwater will forever need to be pumped out and
treated at a rate greater than itís flow in order to keep it from
flowing into the lake.  The potential for mechanical failure over the
lifetime of the landfill or overload during periodic flood conditions is
never talked about.  Complete confidence in todayís scientific and
engineering ability is not juxtaposed with the complete failure on the
part of the Army to maintain and operate the non-functioning cap placed
over the landfill since 1982.

The final area where that analysis falls short is that in the excavation
alternative it is estimated that 10 feet of soil beneath the landfill
would also have to be removed due to suspected contamination.  The
report does not address the fact that the bottom of the landfill is only
30 feet above lake level and if groundwater is causing contamination to
seep downward in the soil then the capping will allow the chemicals to
eventually reach the lake.

It is worth the $20 million in excavation costs over and above the $18
million cap to make sure that the waste contained in landfill #7 is
truly benign as the Army wants to believe.  Even if the waste is typical
of MSWLF it is preferable in the long run to remove the waste rather
than to manage it in proximity of Lake Michigan.  In doing otherwise the
Army is being penny wise and pound foolish with this countryís fresh
water supply.  The Army is guarding itís own budget against non-weapon
expenditures but the time has come for the peace dividend to be paid. 
The health of the nation is worth more than another bomber.

Steven Bradley Pollack