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G1. Progressive Green
Evidence of toxic herbicide use including Agent Orange at Fort Ord, CA
We request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Fort Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for the above referenced conditions among those who were exposed.
Making a comment is simple to do. Go here: https://www.regulations.gov/document/VA-2024-VBA-0006-0001 Click on Comment. The deadline in April 12, 2024.
April 5, 2024
Table of Contents
A. Background on herbicides, including Agent Orange and suspected impact on Fort Ord
B. Background on VA Rule § 3.309, proposed changes, and the diseases subject to presumptive service connection for herbicides
C. Summary of evidence for Agent Orange usage at Fort Ord
D. Detailed evidence of Agent Orange usage at Fort Ord:
I. U.S. Army Agronomist report on Poison Oak Control Work at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage.
III. A citation in The Military Engineer from 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year, including waste classification of 2,4,5-T specifically.
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons proving to provide immediate but not long-lasting control of the poison oak.
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt.
E. Summary of advocacy and findings from Cancer and illnesses from Fort Ord, CA military base
F. Lawmaker asks on behalf of those impacted by Fort Ord contamination
G. Source citations
Contributors to this Evidentiary Document
Julie Akey
Founder of Cancer and illnesses from Fort Ord, CA military base. Impacted U.S. Army Veteran and Retired U.S. Diplomat.
Mrs. Akey is a veteran who lived at Fort Ord and who graduated from the Defense Language Institute (Arabic). She is a retired U.S. Foreign Service Officer and was the State Department’s Vice Consul in Spain, Columbia, Ecuador, Guyana, and Nigeria. In 2017, Ms. Akey was diagnosed with Multiple Myeloma. Soon after, she created the Facebook group “Cancer and illnesses from Fort Ord, CA military base” to bring awareness and information to others who have suffered illnesses they believe are associated with contamination at Fort Ord.
Pat Elder, MA,
Research Analyst and Director of Military Poisons pelder@militarypoisons.org https://www.militarypoisons.org/
Mr. Elder is an expert speaker and author who founded the organization, Military Poisons, that focuses primarily on the U.S. military's use of per-and polyfluoroalkyl substances, known as PFAS. Pat has authored 300 articles on the subject and has addressed audiences around the world on the dangers inherent in the military's use of these toxins.
Denise Trabbic-Pointer, MS
Retired Chemical Engineer certified in Hazardous Material Management
Toxics and Remediation Specialist with Sierra Club dtrabbicpointer@gmail.com
Mrs. Trabbic-Pointer is a retired (2019) chemical engineer certified in Hazardous Material Management. As a career environment and occupational health professional, during her 42-year career with DuPont Performance Coatings (later spun-off as Axalta Coating Systems), Ms. Trabbic-Pointer brought awareness to and education of the adverse effects and health impacts of exposure to chemicals in the workplace. Ms. Trabbic-Pointer now volunteers her efforts as a Toxics and Remediation Specialist with the Sierra Club as a technical resource for communities affected by toxic chemicals in air, water and soil.
L. Kyle Horton, MD, MBA
Internal Medicine Physician and Public Policy Advocate
Founder and CEO of On Your Side Action
kyle@onyoursideaction.org https://www.onyoursideaction.org
Dr. Kyle Horton is a former VA physician and trained internist who is now boarded with the National Board of Physicians and Surgeons (NBPAS). She recently founded On Your Side Action, which is an advocacy organization focused on health equity, improving veterans care, and fostering healthier and safer environments. She has years of experience in both clinical practice and assisting veterans with toxic exposures in medical consultation related to their exposures. She has used these experiences to successfully advocate alongside veterans and environmental groups for legislation related to toxic exposures, care of female veterans, opiate safety, and suicide prevention to name a few.
A. Background on herbicides, including Agent Orange and suspected impact on Fort Ord Veterans
In background, Agent Orange is a 50-50 mix of the herbicides 2,4-D and 2,4,5-T; the latter of which was banned in 1979.1 2,4,5-T contains 2,3,7,8-Tetrachlorodibenzodioxin or TCDD, otherwise known as dioxin, which is one of the deadliest substances known.1 Exposure to dioxin can include simple inhalation and exposures can occur from fires, trash, and fuel burning. The half-life of dioxins in the soil is from 60 to 80 years with decades-long persistence as it seeps into the soil and sediments, and migrates into the vegetation and aquatic life, poisoning the food chain.2
According to the VA Public Health, the dioxin TCDD was “an unwanted byproduct of herbicide production.”3 TCDD is the most toxic of the dioxins, and is classified for carcinogenicity by the Environmental Protection Agency.4 The updated Agency for Toxic Substances and Disease Registry information on chlorinated dibenzo-p-dioxins (CDDs) acknowledges that exposure to 2,3,7,8-TCDD increases the risks of several types of cancer in people.5 And in point of fact the World Health Organization (WHO) International Agency for Research on Cancer does qualify 2,3,7,8-TCDD as a human carcinogen.6 Since that 1997 classification by the IARC of TCDD as a group 1 carcinogen based on limited evidence in humans, a subsequent evaluation of epidemiologic evidence in 2004 that was published in Environmental Health Perspectives found in a review of studies including mechanistic, epidemiologic, and industrial cohorts, that the evidence generally supported that 1997 IARC classification.7
The following evidentiary document references specifically the U.S. Army installation at Fort Ord which was declared an EPA Superfund site in 1990.8 Fort Ord was added to the National Priorities List citing over 45 contaminants of concern found in the soil and groundwater, including aquifers that historically served as the drinking water source.9 Expert researchers have found very substantial and compelling evidence that the most toxic components of Agent Orange, including the now banned 2,4,5-T, were used in massive quantities in order to control poison oak over thousands of acres of Fort Ord where troops extensively trained.
In recent years, organizers have identified many seriously ill or deceased former service members, dependents, and staff who served, lived, and worked around Fort Ord. Mrs. Julie Peters Akey was herself impacted by the contamination at Fort Ord having lived on the base in 1996 and 1997. She subsequently developed Multiple Myeloma (MM) which is a rare blood cancer affecting plasma cells that is more typically found in much older males with a racial disparity in incidence and earlier age of onset for blacks.10
Given the concerns for her unusual diagnosis and as she learned more about the nature of the contamination at Fort Ord, she started a private Facebook group called “Cancer and illnesses from Fort Ord, CA military base.”11 The group now has over 1,600 members including those who served, lived, and worked around Fort Ord who are concerned about health effects that may be related to the contamination.11 As part of her organizing efforts, she has created a database that includes the cancers and diseases of over 1,250 soldiers and dependents.12 This database includes a substantial number of veterans and dependents suffering from hematologic malignancies, other cancers, and illnesses that VA currently recognizes as presumptive from exposure to Agent Orange.13
Since forming the group, expert researchers have continued to find credible and definitive sources substantiating the heavy use of herbicides at Fort Ord, including the use of Agent Orange. The following document details evidence compiled by April 1, 2024. This evidence is provided to lawmakers in the hopes of action pursuant to an updated VA rule change which would expand the recognition of locations where Agent Orange was used to 18 different DOD installations in 12 states.14 The proposed list extends locations for presumptives for Agent Orange exposure in the U.S., Canada, and India by adding them to the existing locations Vietnam, Cambodia, Johnson, Atoll, Guam, American Samoa, Korea, Laos, and Thailand. The proposed VA rule change is available for public comment through the Federal Register which already reflects comments from those concerned about Agent Orange usage at Fort Ord.15
This designation of presumption for Agent Orange exposure means that VA automatically assumes a veteran who served in that area during the designated timeframe was exposed to the toxin which ensures the veteran access to related healthcare and lowers the burden of proof for veterans to be granted disability benefits. Fort Ord was left off of this list even though expert researchers, including a chemical engineer, have found substantial evidence that Fort Ord used massive amounts of herbicides to control poison oak over thousands of acres. Evidence suggests this use persisted for decades from the 1950s through the 1970s, and documents even note the intent to store 2,4,5-T designated on Ord’s Resource Conservation and Recovery Act (RCRA) Base Closure plan in 1991.16,17Although we have this compelling evidence of AO use at Ord, to date, and to our knowledge, all veteran claims in the Fort Ord Facebook group which were filed for concern of Agent Orange or other related herbicide exposure have been denied. Although Mrs. Akey’s claim for service connection was subsequently approved citing primarily other contaminants in the soil and water, including benzene, TCE, PCE, Dichloroethane, Dicloromethane (DCM), and PFAS. The vast majority of other claims for veterans without a clear occupational toxic exposure risk activity have been denied.
Based on this evidence, we respectfully request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for certain conditions among those who were exposed—the deadline for federal register comments is April 12th, 2024.
B. Background on VA Rule § 3.309, proposed changes, and the diseases subject to presumptive service connection for herbicides
For the 1st time, a VA proposal on February 12, 2024, plans to expand Agent Orange health coverage and presumption for disability or death benefits to veterans with certain conditions who served at 18 DOD installations in 12 states.14 The previously recognized locations as presumptive for Agent Orange exposure included locations in Vietnam, Cambodia, Johnson Atoll, Guam, American Samoa, Korea, Laos, and Thailand.
The proposed rule change to § 3.309 would expand the locations and timeframes for which VA would presume exposure to Agent Orange and other herbicides including locations in the United States, Canada, and India. The DOD has previously recognized toxic herbicide use at a limited number of DOD installations outside of Vietnam.18 This list from 2019 where “tactical herbicides and their chemical components were tested, used, or stored outside of Vietnam” does not include Fort Ord despite the evidence we will present in this document.18
The proposed rule change is part of an effort by the Biden-Harris administration in their “Unity Agenda.” While the PACT Act has addressed and created the largest expansion of veteran care and benefits in generations, it is important to realize that presumptives were not extended by that legislation in a way that benefits many veterans of Fort Ord.19 Also, it is important to realize that the PACT Act screening does not include questions about soil or water contamination at stateside installations outside of Lejeune.20 Because veterans were not made aware of the legacy of contamination at Ord, including for Agent Orange, they would not self-report their exposure in the PACT Act screening nor would they be eligible for the Agent Orange disease registry as it stands.
Given all of these factors, to date, most veterans impacted by Fort Ord’s contamination are still unable to get claims approval unless their occupation leads to their approval through a recognized occupational toxic exposure risk activity (TERA).21 The intent of the PACT Act and these changes, however, was clearly to help veterans who had faced stateside contamination like that for which we have evidence at the heavily contaminated Fort Ord. According to VA Under Secretary for Health Shereef Elnahal, M.D., “We can also care for Veterans who never deployed but were exposed to toxins or hazards while training or on active duty here at home – by working with chemicals, pesticides, lead, asbestos, certain paints, nuclear weapons, x-rays, and more. We want to bring all of these Veterans to VA for the care they’ve earned and deserve.”21
To honor the promise of this nation and the intent of the PACT Act passage by congress, we need your help to recognize the extensive contamination at Fort Ord. Briefly explained, the rule change and presumption of exposure means that VA automatically assumes that veterans who served in certain locations were exposed to certain toxins. A designation of presumption for a condition lowers the burden of proof required for a veteran to receive disability benefits, helping veterans get the benefits they deserve as quickly as possible. This expansion of presumptives under the rule change § 3.309 by adding Fort Ord would mean that VA recognizes toxic herbicides, including Agent Orange, were used at Fort Ord and would mean that veterans with certain conditions that are highly associated with exposure to these herbicides would be covered for VA benefits. Through April 12th, the VA is accepting public comments on the proposed expansion of presumptive areas of exposure from herbicides, and many Fort Ord veterans have chosen to comment.15
For reference, the diseases recognized by VA as associated with exposure to certain herbicide agents are delineated as follows: AL amyloidosis, Chloracne or other acneform disease consistent with chloracne, Type 2 diabetes (also known as Type II diabetes mellitus or adult-onset diabetes), Hodgkin's disease, Ischemic heart disease (including, but not limited to, acute, subacute, and old myocardial infarction; atherosclerotic cardiovascular disease including coronary artery disease (including coronary spasm) and coronary bypass surgery; and stable, unstable and Prinzmetal's angina), all chronic B-cell leukemias (including, but not limited to, hairy-cell leukemia and chronic lymphocytic leukemia), Multiple myeloma, non-Hodgkin's lymphoma, Parkinson's disease, early-onset peripheral neuropathy, porphyria cutanea tarda, prostate cancer, respiratory cancers (cancer of the lung, bronchus, larynx, or trachea), soft-tissue sarcoma (other than osteosarcoma, chondrosarcoma, Kaposi's sarcoma, or mesothelioma).13 The term “soft-tissue sarcoma” includes the following: “Adult fibrosarcoma, Dermatofibrosarcoma protuberans, Malignant fibrous histiocytoma, Liposarcoma, Leiomyosarcoma, Epithelioid leiomyosarcoma (malignant leiomyoblastoma), Rhabdomyosarcoma, Ectomesenchymoma, Angiosarcoma (hemangiosarcoma and lymphangiosarcoma), Proliferating (systemic) angioendotheliomatosis, Malignant glomus tumor, Malignant hemangiopericytoma, Synovial sarcoma (malignant synovioma), Malignant giant cell tumor of tendon sheath, Malignant schwannoma, including malignant schwannoma with rhabdomyoblastic differentiation (malignant Triton tumor), glandular and epithelioid malignant schwannomas, Malignant mesenchymoma, Malignant granular cell tumor, Alveolar soft part sarcoma, Epithelioid sarcoma, Clear cell sarcoma of tendons and aponeuroses, Extraskeletal Ewing's sarcoma, Congenital and infantile fibrosarcoma, and Malignant ganglioneuroma.”13
When reviewing those conditions and comparing to the database of the Facebook group “Cancer and illnesses from Fort Ord, CA military base, you will find similarities in the patterns of conditions being found.12 ASAP action by lawmakers would ensure DOD recognition of the compelling evidence of Agent Orange usage at Ord and that impacted Fort Ord veterans would be eligible for presumptive coverage for their benefits.
We request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized under § 3.309. Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for the above referenced conditions among those who were exposed.
C. Summary of evidence for Agent Orange usage at Fort Ord
To date, researcher Pat Elder and retired chemical engineer Denise Trabbic-Pointer have found seven different primary sources of evidence for heavy herbicide usage, including the active components of Agent Orange. This evidence was first reported by Mr. Elder on March 31, 2024.
Photo - Toxicodendron diversilobum - Pacific Poison Oak.
I. U.S. Army Agronomist report on Poison Oak Control Work at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.16
Floyd L. Otter who was a Management Agronomist for the U.S. Army working at Fort Ord reports on records on the usage of herbicides to control poison oak at Fort Ord. He documents the impact on training from the number of troops who reported to sick call with poison oak dermatitis. He compares the reduction of cases from the control period, which was in 1950 before the herbicide use, and explains, “By August 1, 1951 only 691 acres of an estimated 9,000 needing treatment had been sprayed. Of course, the more heavily used areas were treated first.” He continues by clarifying the extent of the need and the herbicidal usage approach which proved effective. Specifically cited are the use of 2,4-D and 2,4,5-T; the latter of which is the banned known and carcinogenic component of Agent Orange. From Mr. Otter, “Daily records were kept so that we can go back to any area and know when and how it was treated. The records show that the requirement of herbicide usually ran between 4 and 8 pounds of acid per acre, or one to two gallons of liquid herbicide. The report reads, “The spray rig when a full crew was available, would put out 1500 to 2000 gallons per 8-hour day. A representative acre therefore would take 200 gallons of spray material (of which 1} gallons would be 2,4-D - 2,4,5-T mixture, and 8 gallons diesel oil) and one man-day of labor.”16
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage. 22
Citation NR: 1235530 with a decision date of 10/15/2012 which was an appeal from the Department of Veterans Affairs Regional Office in Portland, OR includes a letter from the Army dated in December 1980 noting that the Pest Control Shop at Fort Ord had monthly records dating back to January 1973 of all herbicides used, and that 2,4,5-T and 2,4-D usage was included in the records.22 The veteran was unfortunately denied his claim for Type II DM and chronic lymphocytic leukemia (CLL) secondary to herbicide exposure.23
III. A citation in The Military Engineer from 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”24
Discussions in the journal from Sam E. Alden, Major, Corps of Engineers and Post Engineer, reference that the information from Mr. Neil about brush control at Fort Ord will serve as “a very valuable reference in our weed control program.” The description of the poison oak control efforts at Fort Ord reads, “In training areas, such as Fort Ord, where poison oak has been extremely troublesome to military personnel., a well-organized chemical war has been waged against this woody plant pest. A drastic reduction in trainee dermatitis casualties has been the reward. Here both 2,4-D—2,4,5-T brush killer, and “Ammate” weed and brush killer have been used in the chemical campaign.”24
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year including waste classification of 2,4,5-T specifically.25
From the Defense Technical Information Center, the Hazardous Waste Minimization Assessment for Fort Ord presents in Table 26 total waste generation and “Quantities of Materials Used by Miscellaneous Sources,” which references 80,000 pounds of herbicides used per year. In these documents, Agent Orange is characterized as a phenoxy pesticide and in Table 50 of that document is the Waste Classification Pesticides, including those containing 2,4,5-T, with a reference to the use of 2,000 lbs. The trade names under that waste classification include Brush-Rhap, Dacamine, Ded-Weedon, Esteron, Farmco Fence Rider, Forron, Inverton 245, Line Rider, Super D Weedone, Tormona, Transamine, U 46, Veon 245, Weedar, and Weedone.25
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.17
The Final Closure Plan for Fort Ord for the Defense Reutilization Marketing Office indicates the storage of hazardous waste that falls under the EPA waste number F027, which includes, “discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.)”26 This listing of all the hazardous wastes that were or could be generated at Fort Ord, and particularly during the facility closure activities, cites the hazardous waste F027 as a waste that could be generated and stored on the DRMO storage unit at less than 1,000 pounds. This means the Army intended to store, prior to discarding, up to 1000 pounds of Agent Orange waste at the permitted storage unit. To further substantiate this concern, Table 7 of the “Draft” Final Closure Plan for the DRMO Container Storage Unit includes analytical results that indicate 4,4-DDE and 4,4-DDT were present in soil and sediments underlying that storage unit—further confirmation of Agent Orange storage prior to disposal.17
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons, as proving to provide immediate but not long-lasting control of the poison oak. 27
There is a citation for an assessment of the effectiveness of several herbicides in controlling poison oak at Fort Ord from 1965 to 1969. The article appears in a “Right-of-Way Ecological Effects Bibliography” from the Electric Power Research Institute and recaps the author’s general experiences in controlling poison oak with herbicides. The document references the usage of 2,4,5-T; 2,4-D; silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons as giving immediate but not long-lasting control of the poison oak at Fort Ord.27
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. 28
From the Sacramento Corps of Engineers, the Record of Decision Operable Unit 1 at Fritzsche Army Airfield in Fort Ord, there is a report of “Chemicals Detected in the Soil Prior to and After Excavation and Preliminary Remediation Goals.” Table 3 in that document cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. This finding is above the remediation goal of 1.2 ppt.28
C. Detailed evidence of Agent Orange usage at Fort Ord
I. U.S. Army Agronomist report on Poison Oak Control Work Control at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.16
The report documents a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material. The report reads as follows, “Poison oak poisoning, for some mysterious reason is often considered a slightly humorous disease. At Fort Ord, however, the Medical Officer gives it the more dignified name of poison oak dermatitis, and his reports on the extent of this poisoning among trainees do not make humorous reading to the training officers nor to the taxpayers.
Previous to starting the 1951 control program as many as 339 men in one month reported on sick call with poison oak dermatitis and as many as 34 cases in one month had to be hospitalized for an average of 7 clays per case. This does not include the cases not serious enough to require a doctor. It can readily be seen that this shrub not only causes lost time and hospital costs but the interruption of the regular training sequences is even more costly. A man who loses one week from poison oak poisoning may have to be dropped from his unit and be held over several weeks to complete his training with another unit.
This loss, contrary to· common opinion, is almost constant throughout the year with no consistent seasonal variation. Nearly 27,000 acres at Fort Ord are used for training. The most intensively used areas are thickly infested with .poison oak. They are used almost daily for marching, bivouacing, and infantry problems of all kinds, night and day.
One solution suggested for this poison oak problem is that Selective Service induct all poison oak susceptible men into the Navy instead of the Army. Until some such simple solution is found, however, it seems necessary to attack the poison oak.
I will briefly review three phases of the program:
Effect of one season's work on the number of poisoning cases.
Methods and costs.
Results insofar as they are obtainable at this early date.
Credit should go to the Sixth Army at San Francisco for recognizing the problem and providing funds for last year and for the coming season, and also for furnishing a machine called a Bushwacker, new to the west, for clearing the brushy areas. I am indebted to the Medical Officer at Fort Ord for the data on poisoning cases, and to the Post for authorization to hire an experienced weed control man to supervise the work.
The U.S. Department of Agriculture's Blister Rust people deserve special mention. Mr. H. R. Offord, M. V. Benedict and Art London besides giving us complete plans and advice based on their Ribes control experience, loaned us equipment and trained our men in the use of it. Dr. Oliver Leonard of the University of California at Davis has advised us on chemicals and put out dozens of test plots on the reservation. The State Extension Service, State Department of Agriculture, and the field men of several chemical companies have also been very helpful.
The control work seems to have given surprisingly quick results. To get the best possible comparative·figures the period August l to December 31, 1950 was taken as representative of the period before intensive control work had been done, and the corresponding five months of 1951 were taken as representative of the results after an appreciable area had been treated. Actually, by August 1, 1951 only 691 acres of an estimated 9000 needing treatment had been sprayed. Of course, the more heavily used areas were treated first. '
Comparison of the two five-month periods shows that poison oak sick call cases, even with an increase in post strength, decreased 53%, the rate of incidence of poison oak cases per 1000 men decreased 57%, and the daily non~effective rate per 1000 men decreased 68%. Additional information is shown in Table 1.
The methods and equipment used for control work were selected after considerable study of methods used elsewhere. At Camp Adair, Oregon, for example, the Army, assisted by the U.S. Department of Agriculture's Blister Rust Control people carried out an eradication program up 17,000 acres in 1942•3 using bulldozers, hand-grubbing and borax. Costs ran up to $400 per acre with an average of $18.00. Fort Ord has done extensive hand grubbing, diesel oil spraying and 2,4-D spraying in past years. Airplane spraying was considered but most of the poison oak is found under live oak trees which were needed as cover for the training work. It was felt, also, that airplane spraying might be hazardous to the lettuce and artichoke fields near the base.
The methods and equipment developed over a period of several years for Ribea control were therefore adopted. A spray rig consisting of a Bean ''Royal 20" pump, Wisconsin VF-4 gasoline motor and a 500-gallon tank was purchased and mounted on a 22-Ton 4-Wheel drive army truck. This rig works normally about 15 acres to a setting, using 1000 feet of 11 mainline hose and eight 3/8 inch lateral hoses, each 400 feet long. All couplings are of the type that can be quickly coupled and uncoupled under pressure. The rig requires 10 men for full operation. Each nozzle man works a lane 33 feet wide laid out with white string.
Chemicals used included 2,4-D and 2,5-T Esters (Ed. Note – this is a typo! There is no such 2,5-T ester. It is 2,4,5-T) alone and in various combinations, 2,4-D amine, and ammonium sulphamate. Diesel oil and a spreader sticker were used. Acid concentrations were between 3000 and 5000 p.p.m.
Daily records were kept so that we can go back to any area and know when and how it was treated. The records show that the requirement of herbicide usually ran between 4 and 8 pounds of acid per acre, or one to two gallons of liquid herbicide. The spray rig when a full crew was available, would put out 1500 to 2000 gallons per 8 hour day.
A representative acre therefore would take 200 gallons of spray material (of which 1} gallons would be 2,4-D - 2,4,5-T mixture, and 8 gallons diesel oil) and one man-day of labor. These materials cost about $14.00 and the labor $11.00, or $25.00 per acre to which must be added .all costs of equipment operation, depreciation, miscellaneous supplies, and office overhead.
During the season, April 2 to October 12, 875 acres were treated. As to the amount of kill obtained very little can be determined at this early date. The areas treated in 1949 and 1950 with straight 2,4-D and water re-sprouted heavily, The season of treatment seems to be very important. The winter work using the "dormant" spray method with 2,4-D and diesel oil was a failure. Our standard treatment applied before May 15th gave top kill but there was heavy sprouting in the open areas where leafing-out was late. The areas treated from May 15 to October 12 all appear dead at this time, but we expect some regrowth.
In conclusion, we are fairly well satisfied with the methods used last year, and with the results as far as they can be ascertained at this time. The 57% reduction in poison oak cases shows quicker results than were expected. We are interested in any improvement that can be made in equipment or materials or any way in which costs can be lowered or quicker kill obtained.”16
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage. 22, 23
Citation NR: 1235530 with a decision date of 10/15/2012 which was an appeal from the Department of Veterans Affairs Regional Office in Portland, OR includes a letter from the Army dated in December 1980 noting that the Pest Control Shop at Fort Ord had monthly records dating back to January 1973 of all herbicides used, and that 2,4,5-T and 2,4-D usage was included in the records.22
The veteran was unfortunately denied his claim for Type II DM and chronic lymphocytic leukemia (CLL) secondary to herbicide exposure.23
III. A citation in The Military Engineer from Jan.-Feb. 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”24
Discussions in the journal from Sam E. Alden, Major, Corps of Engineers and Post Engineer, reference a report from a Mr. Neil about brush control at Fort Ord, and explains that brush control program will serve as “a very valuable reference in our weed control program.”
The description of the poison oak control efforts at Fort Ord reads, “In training areas, such as Fort Ord, where poison oak has been extremely troublesome to military personnel., a well-organized chemical war has been waged against this woody plant pest.
A drastic reduction in trainee dermatitis casualties has been the reward. Here both 2,4-D—2,4,5-T brush killer, and “Ammate” weed and brush killer have been used in the chemical campaign.”24
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year including waste classification of 2,4,5-T specifically.25
From the Defense Technical Information Center, the Hazardous Waste Minimization Assessment for Fort Ord presents in Table 26 total waste generation and “Quantities of Materials Used by Miscellaneous Sources,” which references 80,000 pounds of herbicides used per year.25
Hazardous Waste Minimization Assessment - Fort Ord, CA July 5, 1991In these documents, Agent Orange is characterized as a phenoxy pesticide which would include Table 50 of that document which is Waste Classification Pesticides including those containing 2,4,5-T references the use of 2,000 lbs. The trade names under that waste classification include Brush-Rhap, Dacamine, Ded-Weedon, Esteron, Farmco Fence Rider, Forron, Inverton 245, Line Rider, Super D Weedone, Tormona, Transamine, U 46, Veon 245, Weedar, and Weedone.25
TABLE 50
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.17
The following is from a Hazardous Waste Permit Part A application pursuant to Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan, which lists all the hazardous wastes that were or could be generated at Fort Ord, and particularly during facility closure activities. As indicated in the following screenshots from the application, F027 waste, was one of the waste codes that could be generated and stored on the DRMO storage unit site at less than 1,000 pounds.17
The wastes covered by Hazardous Waste Number F027 include “Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.)”26
This means the Army intended to store, prior to discarding, up to 1000 pounds of F027 Agent Orange waste at the permitted storage unit (DRMO) for the period defined in their hazardous waste permit (typically one year). Evidence does not tell us how much Agent Orange waste they temporarily stored at the DRMO storage unit and ultimately disposed of, but we do know that the active ingredients in Agent Orange were stored on the hazardous waste storage unit.
Table 7 of the "Draft" Final Closure Plan for the DRMO Container Storage Unit includes analytical results that indicate 4,4-DDE and 4,4-DDT were present in soil and sediments underlying the DRMO storage unit. This further confirms that AO was stored on the DRMO prior to disposal.30
TABLE 7
Dioxin is bioaccumulative and has a half-life in soil from 60 to 80 years, and at the same time, it persists for a long time in the environment, seeps into the soil and sediments, and migrates into vegetation and aquatic life, leading to bioaccumulation in the soil and food chain.29
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons proving to provide immediate but not long-lasting control of the poison oak. 27
A citation for an assessment of the effectiveness of several herbicides in controlling poison oak at Fort Ord from 1965 to 1969. The article appears in a “Right-of-Way Ecological Effects Bibliography” from the Electric Power Research Institute and recaps the author’s general experiences in controlling poison oak with herbicides listed including 2,4,5-T; 2,4-D; silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons as giving immediate but not long-lasting control.27
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt.28
From the Sacramento Corps of Engineers, the Record of Decision Operable Unit 1 at Fritzsche Army Airfield in Fort Ord, there is a report of “Chemicals Detected in the Soil Prior to and After Excavation and Preliminary Remediation Goals.” Table 3 in that document cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. This finding is above the remediation goal of 1.2 ppt.28
E. Summary of advocacy and findings from Cancer and illnesses from Fort Ord, CA military base
Ms. Akey lived on base in 1996 and 1997, and was subsequently diagnosed, at an atypically young age, with Multiple Myeloma (MM). Ms. Akey’s claim was approved as 100% service connected by citing contaminants in the soil and likely affecting the groundwater--primarily hinging on evidence of TCE, PCE, Dichloroethane, benzene, PFAS, and Dicloromethane (DCM). Prior to gathering the compelling evidence for the herbicide use, VA denied Ms. Akey’s claim for service connection for her MM based on Agent Orange exposure.
Given her ongoing concerns with her own condition and others impacted, she has continued to grow the network of a Facebook group “Cancer and illnesses from Fort Ord, CA military base.”11 That group has continued to grow and now includes over 1,600 members. As part of her organizing efforts, she has created a database that includes the cancers and diseases of over 1,250 soldiers and dependents.12 This database includes a substantial number of veterans and dependents suffering from hematologic malignancies, other cancers, and illnesses that VA currently recognizes as presumptive from exposure to Agent Orange.13 Although we have this compelling evidence of AO use at Ord, to date, all veteran claims in the group filed for concern of AO have been denied and the vast majority of other claims for veterans without a clear occupational toxic exposure risk activity have been denied.
Beginning in 2021, group leaders organized the impacted community around a series of asks focused on better understanding of the impact of the contamination on their health and facilitating action to get appropriate healthcare and benefits to those suffering. They created a petition at that time asking for a number of actions in a whole of government approach to addressing the impacts of the contamination that included: providing healthcare and benefits for those impacted by Fort Ord contamination akin to those granted to those who were impacted at Camp Lejeune, the creation of a health registry, reassessment of health effects by ATSDR, creation of a medical monitoring program, and periodic reassessment to add conditions to the presumptive list pursuant to new evidence by ATSDR or gained through the health registry.31
The community of folks concerned with Fort Ord previously drafted a petition calling for “Fairness for the Patriots and Patriots Poisoned at Fort Ord, US Army Base—that petition has gathered over 27,000 signatures of individuals who stand with Fort Ord.31
Media outreach has continued to reach more folks and in 2022, the AP published a nationally featured story about the contamination at Fort Ord entitled, “What Lies Beneath: Vets worry polluted base made them ill.”32 Later, they would follow-up with a more thorough investigative report on the concerns with the contamination at Fort Ord. The investigative reporting was featured nationally as a “Best of the Week” and is archived as, “Toxic Chemicals Lie Beneath Fort Ord.”33
In that reporting, you will find reference to a flawed previous ATSDR study conducted in 1996, which concluded that there was “no apparent public health hazard” posed by the contamination at Fort Ord.34In review of the quality of the study and after consultation with experts, Ms. Akey corresponded with ATSDR on her concerns. Also, leaders had a series of meetings and follow-up with Representatives Jimmy Panetta and Katie Porter who subsequently corresponded with ATSDR to request an updated study. ATSDR would agree to conduct an updated study and health assessment although details were initially unclear. In February 2023, the Agency published more information on what assessments would be completed as part of the updated study.35
In review of that documentation, Ms. Akey consulted with Ms. Trabbic-Pointer who is a chemical engineer with a BS and MS in Hazardous Materials Management and a career EHS professional. Ms. Trabbic-Pointer has 42 years of experience with DuPont and a spin-off company, Axalta Coating Systems. Using her expertise, they crafted a detailed series of requests to ATSDR with the express goal of providing those impacted by the Fort Ord contamination with a more accurate and comprehensive health assessment of their risks from exposure. Concerns raised included but were not limited to: failure to consider and review volatilization of indoor air from chlorinated chemicals, not assessing cumulative exposures to chlorinated chemicals, failure to consider synergistic effects including of PFAS with previous known carcinogenic chemicals like TCE, and consequentially ignoring evidence of an expanding TCE plume due to a faulty extraction well and pump and treat system. Major inadequacies in the initial Fort Ord Public Health Assessment that they identified include failure to: consider key routes of exposure, include certain highly toxic contaminants of concern, assess certain base locations and times of ongoing contamination, and study very consequential potential health effects including immune toxicity and from endocrine disruption in particular.
Despite the many inadequacies addressed in their detailed request, ATSDR essentially denied every request. Even considering this denial, our expert leaders continue to advocate, including recently meeting with the new Director of NCEH/ATSDR. Unfortunately, per his expressed concerns, the updated budget to ATSDR was cut and so there is little reason to believe that ATSDR will commit to any further action at Ord in the future, although there was a new allotment made of $5M for PFAS-related outreach and work.
In recent months though, the evidence we have assimilated on the herbicide use, including of Agent Orange, has led leadership to a clear conclusion that the contamination at Fort Ord needs and merit immediate redress.
We are asking for your immediate ACTION to add Fort Ord under the updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides is recognized for presumption of service connection for certain conditions. Given the very direct and compelling evidence for dioxin use, as well as the decades of science behind the toxic effects of these herbicides, we believe a study is no longer needed--rather that the addition of Fort Ord to the proposed expanded list for presumption is the EVIDENCE-BASED action that is merited.
F. Lawmaker Asks on Behalf of those impacted by Fort Ord Contamination
As previously described, a VA proposal on February 12, 2024, plans to expand Agent Orange health coverage and presumption for disability or death benefits to veterans with certain conditions who served at 18 DOD installations in 12 states.3 Unfortunately, Fort Ord was left off the list. Since previous corresponding with federal lawmakers, expert researchers, including a chemical engineer, have found substantial, compelling evidence that Fort Ord used massive amounts of herbicides to control poison oak over thousands of acres. We believe this use persisted for decades from the 1950s through the 1970s, and have noted the intent to store 2,4,5-T designated on Ord’s Resource Conservation and Recovery Act (RCRA) Closure plan in 1991.
Based on this evidence, we respectfully request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Ord’s inclusion with this updated rule § 3.309 would grant presumption for the adjudication of disability or death benefit claims for certain conditions among those who were exposed.
Furthermore, we ask your consideration for the many seriously ill or deceased former service members, dependents, and staff who served, lived, and worked around Fort Ord, which was among the worst of the worst locations for contamination by virtue of its designation on the EPA’s Superfund National Priorities List. Fort Ord featured a burn pit on top of the inadequately assessed groundwater contamination, which seeped into the drinking water aquifers. The groundwater contamination included extremely toxic and carcinogenic contaminants, namely: TCE, benzene, PCE, Dichloroethane, Dichloromethane, and PFAS (to name a few). In view of the previously inadequate study of the health effects at Fort Ord and the ATSDR’s clear expression that they are unwilling to provide the kind of comprehensive health information those impacted deserve, we continue to ask for definitive and health protective action by lawmakers to stand up for Fort Ord.
We must stop the cycle of delay, deny, and hope they die when it comes to those who have served, lived on, or worked at these DOD Superfund sites.
To stop this abusive cycle, we are respectfully requesting parity with the same healthcare and benefits guaranteed to those exposed at Camp Lejeune. This includes a specific request for veterans benefits coverage as well as hospital and medical services coverage equivalent to those guaranteed in the Honoring America’s Veterans and Caring for Camp Lejeune Families Act of 2012. And because this is now a pattern across different service branches and including many other DOD sites, we are demanding proactive policies that protect those exposed at all the other Lejeunes that may be identified. We respectfully request the following further federal actions:
❖ Creating a Health Registry similar to the Airborne Hazards and Open Burn Pit Registry that allows for growing the body of knowledge of potential conditions related to contamination at Fort Ord and other DOD Superfund sites.
❖ Requiring periodic reviews of the registry with public comment periods coinciding with ATSDR reporting to Congress on emerging epidemiological evidence that would substantiate adding conditions to the presumptive list for VA benefits coverage.
❖ Establishing a Medical Monitoring Program for those impacted that will be guided by information learned through the Registry.
❖ Add DOD Superfund site information to the VA Exposure Education Application with links to clinical guidance on key contaminants of concern found at Lejeune and which are now repeatedly being identified, including specifically those that are known or probable human carcinogens.
The above requests for action have been endorsed by over 27,000 individuals who stand with those impacted by the contamination at Fort Ord.
G. Source Citations
1. NIH. History of the Controversy of the Use of Herbicides. Available at: https://www.ncbi.nlm.nih.gov/books/NBK236351/#:~:text=The%20military%20use%20of%202,of%20the%20entire%20herbicide%20operation.
2. NIH. A Review of Soil Contaminated with Dioxins and Biodegradation Technologies: Current Status and Future Prospects. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9227754/
3. U.S. Department of Veterans Affairs Public Health. Facts About Herbicides. Available at: https://www.epa.gov/sites/default/files/2016-09/documents/2-3-7-8-tetrachlorodibenzo-p-dioxin.pdf
4. Environmental Protection Agency (EPA). Info on 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (2,3,7,8,-TCDD). Available at: https://www.epa.gov/sites/default/files/2016-09/documents/2-3-7-8-tetrachlorodibenzo-p-dioxin.pdf
5. Agency for Toxic Substances and Disease Registry Division of Toxicology and Environmental Medicine. ToxFAQs Chlorinated Dibenzo-p-Dioxins (CDDs). Available at: https://www.atsdr.cdc.gov/toxfaqs/tfacts104.pdf
6. World Health Organization (WHO) International Agency for Research on Caner (IARC). Monographs on the Evaluation of Carcinogenic Risks to Humans Volume 69 Polychlorinated Dibenzo-para-Dioxins and Polychlorinated Dibenzofurans. Available at: https://publications.iarc.fr/Book-And-Report-Series/Iarc-Monographs-On-The-Identification-Of-Carcinogenic-Hazards-To-Humans/Polychlorinated-Dibenzo--Em-Para-Em--Dioxins-And-Polychlorinated-Dibenzofurans-1997
7. Steenland et al. Environmental Health Perspect. 2004. Dioxin revisited: developments since the 1997 IARC classification of dioxin as a human carcinogen. Available at: https://pubmed.ncbi.nlm.nih.gov/15345337/
8. U.S. Environmental Protection Agency (EPA) Superfund Site report for Fort Ord. Available at: https://cumulis.epa.gov/supercpad/CurSites/csitinfo.cfm?id=0902783&msspp=med
9. U.S. Environmental Protection Agency (EPA) Superfund Contaminant List for Fort Ord. Available at: https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.contams&id=0902783&fbclid=IwAR0EsetwJ2BIfWD7PLJoQ6CIuas-LojWYTvRmsXznVohhrqZ28waTInTVCY
10. Waxman et al. Blood. 2010. Racial disparities in incidence and outcoume in multiple myeloma: a population-based study. Available at: https://ashpublications.org/blood/article/116/25/5501/28669/Racial-disparities-in-incidence-and-outcome-in
11. Cancer and Illnesses from Fort Ord, CA military base. Private Facebook Group, 1,600 Members.
12. Database of Impacted Veterans, Civilians, and Dependents who served, worked, or lived at Fort Ord. https://static1.squarespace.com/static/6005a180c8cd610112a8a795/t/65d4bd987a294d133fe7d226/1708440984923/Akey+ATSDR+Spreadsheet+no+initials.xlsx
13. National Archives Code of Federal Regulations . § 3.309 Disease subject to presumptive service connection. Diseases associated with exposure to certain herbicide agents. Available at: https://www.ecfr.gov/current/title-38/chapter-I/part-3/subpart-A/subject-group-ECFR39056aee4e9ff13/section-3.309?fbclid=IwAR1dkw-wCE8K0ZAtRXK4AgPhSqRCR0-MU4Pm7Qu77XJphOvzTXo-87PRqPQ_aem_AdzqnESBYP2wAEn7rCQo7J5pb3hg78g4wfnxnwviyUIr572TSjoCJ6TdRL5asJL0BSABvziv-Tt4q8I8HOnw68ja
14. U.S. Department of Veterans Affairs. VA proposes rule to extend presumed areas of exposure to Agent Orange and other herbicides, making it easier for exposed Veterans to receive their earned benefits. Available at: https://news.va.gov/press-room/va-presumes-exposure-agent-orange-herbicides/
15. U.S. Department of Veterans Affairs. Updating VA Adjudication for Disability or Death Benefit Claims Related to Exposure to Certain Herbicide Agents. Available at: https://www.federalregister.gov/documents/2024/02/12/2024-02590/updating-va-adjudication-regulations-for-disability-or-death-benefit-claims-related-to-exposure-to
16. Poison Oak Control Work at Fort Ord, California from Floyd L. Otter, Management Agronomist for US Army, Fort Ord, California. Available at: https://ucanr.edu/repository/fileaccess.cfm?article=164771&p=LKIILR
17. U.S. Environmental Protection Agency. Fort Ord Hazardous Waste Permit Application Part A. November 1996 with revision March 1997. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-BW-0188/Appendices/Appendix_B.pdf
18. U.S. Department of Veterans Affairs Public Health. Herbicide Tests and Storage in the U.S. Available at: https://www.publichealth.va.gov/exposures/agentorange/locations/tests-storage/usa.asp
19. U.S. Department of Veterans Affairs. The PACT Act and your VA benefits. Available at: https://www.va.gov/resources/the-pact-act-and-your-va-benefits/
20. U.S. Department of Veterans Affairs. PACT Act Toxic Exposure Screening and your VA benefits. Available at: https://www.va.gov/lovell-federal-health-care-va/programs/pact-act-toxic-exposure-screening-and-your-va-benefits/#:~:text=A%20toxic%20exposure%20screening%20supports,toxins%20during%20your%20military%20service.
21. U.S. Department of Veterans Affairs. VA Expands health care eligibility to all Veterans exposed to toxins and other hazards during military service. 2024. Available at: https://www.va.gov/southern-nevada-health-care/news-releases/va-expands-health-care-eligibility-to-all-veterans-exposed-to-toxins-and-other-hazards-during-military/
22. U.S. Department of Veterans Affairs. Citation Nr: 1235530. Decision date: 10/15/2012. Available at: https://www.va.gov/vetapp12/files5/1235530.txt?fbclid=IwAR2NOr9xldhtkvY3Vn-VFyXoZuwBsQAWkSRBkkRyhY2eyzPEy9klDot270o
23. U.S. Department of Veterans Affairs. Citation Nr: 0802291. Decision 1/22/08. Available at. https://www.va.gov/vetapp08/files1/0802291.txt
24. Alden et al. The Military Engineer. Vol 48 No. 321 (Jan-Feb 1956). P 33-35. Discussions on Chemical Control of Weeds. Available at: https://www.jstor.org/stable/44603883
25. Defense Technical Information Center. Hazardous Waste Minimization Assessment: Fort Ord, CA. May 1991. Available at: https://apps.dtic.mil/sti/citations/ADA238101
26. U.S. Environmental Protection Agency. Hazardous Waste Numbers as cited in Federal Register § 261.31 Hazardous wastes from non-specific sources. Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261#261.31
27. Price, L.G. U.S. Dept. of Defense. Industrial Vegetation Management. 2(1) 15-17. 1970. Alb; A5b. Available at: https://www.osti.gov/biblio/6269398
28. U.S. Department of the Army Sacramento Corps of Engineers. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA from July 25, 1995. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-OU1-362//ou1-362.pdf
29. Nhung et al. A Review of Soil Contaminated with Dioxins and Biodegradation Technologies: Current Status and Future Prospects. Toxics 2022, 10(6), 278; https://doi.org/10.3390/toxics10060278
30. U.S. Environmental Protection Agency. RCRA Base Closure Plan for DRMO Storage Unit Tables. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-BW-0188//Tables.pdf
31. Akey and leaders Cancer and illnesses from Fort Ord, CA military base. Change.org petition. Fairness for the Families and Patriots Poisoned at Fort Ord, US Army Base. Started June 1, 2021. Available at: https://www.change.org/p/fairness-for-the-families-and-patriots-poisoned-at-fort-ord-us-army-base
32. Mendoza et al. Associated Press. What Lies Beneath: Vets worry polluted base made them ill. February 23, 2022. Available at: https://apnews.com/article/us-army-fort-ord-chemical-exposure-cancer-c1078dd520322f2a4130e2f7077b7892
33. Dearen et al. Associated Press. AP Investigation: Toxic Chemicals Lie Beneath Fort Ord. March 4, 2022 Available at: https://www.ap.org/news-highlights/best-of-the-week/2022/toxic-waste-lies-beneath-fort-ord/
34. Agency for Toxic Substances and Disease Registry (ATSDR). Public Health Assessment for Fort Ord, Marina, Monterey County, California July 15, 1996. Available at: https://www.documentcloud.org/documents/21177635-fort-ord-1996-public-health-assessment
35. Agency for Toxic Substances and Disease Registry (ATSDR). ATSDR to Re-Evaluate 1985-1994 Drinking Water Exposures at Fort Ord. February 2023. Available at: https://fortordcleanup.com/wp-content/uploads/2023/07/ATSDR-Ft-ord-intro-factsheet-02102023_cleared_formatted.pdf
The role of CCS in Germany’s climate toolbox: Bellona Deutschland’s statement in the Association Hearing
We welcome the publication of both documents and the associated recognition of the relevance of CCS as a component of climate action in industry. The integration of CCS is of central importance for reducing process emissions. Together with the ETS1 and the end of certificate allocation, CCS sets a standard for profound emission reductions in emission-intensive industries. CCS is just one component of many in the climate protection portfolio — measures to avoid emissions must continue to have priority.
From our perspective, four points are particularly relevant:
- To not neglect nature conservation and endanger the acceptance of CCS, the CMS must present more concrete figures on land use, contain clear rules for nature-compatible land management, and show ways to compensate for impairments. The CMS must contain clear rules for meaningful CCS applications and reflect the systemic conditions of these application scenarios, including the availability of alternatives.
- It is crucial to ensure government support for the alternatives. Otherwise, there is a risk of justified loss of trust and acceptance for CCS as an important component of comprehensive climate protection. The core of the challenges in the area of financing is the economic risk mitigation and coordination of actors along the entire CO2 value chain in the initial phase of CCS development. Concrete governance solutions for complex economic problems must be developed within the framework of the CMS.
- The “chicken and egg dilemma” necessitates starting implementation activities before other steps are conclusively clarified. The state must be financially prepared to act as a market facilitator if no private-sector solution is found for the complex organizational problems. In the storage sector, securing economic risks will also be necessary over a longer period. The CMS and KSpTG must provide clear organizational structures for effective and transparent coordination of infrastructure development. The project management envisaged in the KSpTG should be specified with regard to its scope of tasks and working methods. The goal must be to coordinate and plan the development of connected infrastructures (e.g., offshore wind parks and CO2 storage, or pipelines, (sub) cables, and conduits) together.
Read the explanation of these points in our statement (in German).
The post The role of CCS in Germany’s climate toolbox: Bellona Deutschland’s statement in the Association Hearing appeared first on Bellona.org.
What do the new federal PFAS drinking water standards mean?
More than 5,000 sites across the U.S. are polluted with the toxic “forever chemicals” known as PFAS, creating an urgent national health and environmental crisis.
For years, states have led the way in addressing this contamination, with at least 11 setting enforceable drinking water standards. These standards, also known as maximum contaminant levels, limit the amount of PFAS legally allowed in tap water.
On April 10, the Biden administration finalized bold new limits for six notorious PFAS: PFOA, PFOS, GenX, PFBS, PFNA and PFHxS.
But what does this mean?
EWG has answers to questions about what the Environmental Protection Agency’s federal drinking water standards mean for the state guidelines already in place – and for the millions of Americans threatened by the PFAS contamination crisis.
Impact of the new standardsWhat are PFAS and why are they harmful?
PFAS are known as “forever chemicals” because they build up in our bodies and never break down in the environment. They are used in thousands of consumer and industrial applications to make products nonstick, stain-repellent and waterproof.
Hundreds of studies link PFAS exposure to health harms including testicular, kidney, liver and pancreatic cancer; reproductive problems; weakened childhood immunity; low birth weight; endocrine disruption; increased cholesterol; and weight gain in children and dieting adults.
Why is the Biden administration finalizing a drinking water standard for PFAS?
In 2020, then-presidential candidates Joe Biden and Kamala Harris promised in their Plan to Secure Environmental Justice to set a drinking water standard for PFAS.
What is a maximum contaminant level?
A maximum contaminant level, or MCL, is the highest amount of a chemical legally allowed in drinking water. The standard is based on public health, as well as the cost and feasibility of cleaning up the water. The upcoming EPA rule will set MCLs for six PFAS: PFOA, PFOS, GenX, PFBS, PFNA and PFHxS.
What are the new standards?
The EPA set MCLs of 4 parts per trillion, or ppt, for PFOA and PFOS and 10 ppt for Gen X, PFNA and PFHxS. The agency has set a hazard index of 1 for GenX, PFBS, PFNA and PFBS. A hazard index is a way to address cumulative risks from mixtures of chemicals.
How much is 4 ppt?
Imagine a map of Texas. One ppt – a single part per trillion – is equivalent to 7 square feet out of the 7 trillion square feet that make up the state.
How have these six PFAS been regulated in drinking water up until now?
Eleven states have set drinking water standards for PFAS, but 39 others have not. So 260 million people will now have protection from PFAS contamination in their tap water because the EPA finalized its rule.
What does a federal limit mean for states that have already established their own?
Once federal PFAS drinking water standards are set, utilities across the country must comply with them. But states can still impose stricter standards, setting even tighter limits.
The agency set an interim health advisory in 2022. Why is the MCL higher than the level set in that advisory?
Lifetime health advisories for drinking water are based on health considerations only. When drinking water contaminants are linked to health harms such as cancer, the EPA when developing health advisories must assume the safe level is zero, or the level at which there is no known or expected risk.
But when it sets the standard, the EPA must also consider other factors, including cost and technological feasibility, which leads to a higher number. The interim health advisories are also below the level at which the EPA can detect PFOA and PFOS, so the agency cannot enforce MCLs set at those levels.
When was the last time the EPA set a standard for a new contaminant?
This is the first time the EPA has set new standards under the process created by the 1996 amendments to the Safe Drinking Water Act.
The EPA has finalized new standards since 1996, but those were not for new contaminants or they were initiated before 1996. For example, in 2001 EPA set a new, tighter limit for arsenic, as required by the 1996 amendments to the Safe Drinking Water Act. The EPA also set an MCL for radionuclides, a new contaminant, in 2000, but the EPA first proposed that MCL in 1991, before the 1996 amendments.
Steps to tackle PFAS exposureHow many people are drinking water contaminated with PFAS?
EWG estimates that 200 million people may be drinking water contaminated with PFAS. The EPA’s own analysis estimates that about 60 million people get their water from a system containing PFOA or PFOS – two of the most well-studied PFAS – at maximum levels above the new proposed limits.
How do I know if PFAS contaminate my drinking water?
EWG has mapped sites with known PFAS detections. You can check to see whether your city or water utility has detected PFAS. You can also search for your ZIP code on our Tap Water Database to find out whether PFAS and other pollutants have been found in your tap water.
But some drinking water systems have not recently or ever tested their water for PFAS or have not yet published their results. All public water systems serving more than 3,000 people must test for 29 PFAS some time between 2023 and 2025.
What if I rely on a private well for drinking water?
Well water is not covered by the EPA’s drinking water rule. However, to address PFAS, the EPA is making funding available to well owners. This funding can be used to test and treat well water. The EPA will release more guidance soon on how to access this funding.
How can I protect myself at home?
To help you lower your family’s exposure at home, EWG has a step-by-step guide for consumers interested in buying a home tap water filter.
Reverse osmosis and carbon-based home water filters can help reduce PFAS in tap water.
What other steps can I take to reduce my exposure?
Lowering the amount of PFAS in drinking water is among the most effective ways to reduce PFAS in your blood. Other steps include changing your diet, cooking more at home and avoiding products made with PFAS.
Impact of the EPA ruleHow many drinking water systems will be affected?
The EPA estimates that roughly 66,000 water systems will be subject to the new limits. But the agency also calculates that PFAS at levels exceeding the new MCL contaminate about 4,000 systems.
When will my drinking water meet the new standards?
Water utilities have up to five years to comply with the new standards.
Will my water bill go up?
Congress included $10 billion in the 2021 bipartisan infrastructure law to help water utilities with infrastructure upgrades needed to address PFAS. Water utilities have recovered billions more through lawsuits against polluters, and that’s expected to rise in the coming years.
What technologies can treat PFAS in drinking water?
There are several utility-scale treatments that can treat PFAS, including granular activated carbon, anion exchange and reverse osmosis.
What about PFAS that are not covered by the EPA’s rule?
The federal standard is limited to six PFAS. But technologies required by the new regulation will effectively treat other PFAS, too, and lower total levels in drinking water.
What about the polluters who contaminate drinking water?
Water utilities shouldn’t bear the sole burden of getting PFAS out of drinking water. Polluters should also have to limit how much PFAS waste they discharge into sources of drinking water. The EPA should stop PFAS at the source and quickly impose industry-wide limits for PFAS for all the sectors most likely to be using the chemicals.
What does this mean for military communities?
The Defense Department has known about the risks of PFAS exposure since at least the 1970s but still used PFAS-laden firefighting foam for decades without warning nearby communities. As a result, many Defense communities have had contaminated water for decades. Thousands of people in these areas who drink water contaminated by the military will be eligible for bottled water, home filtration systems or connections to public water supplies.
Health harms linked to PFASHow does PFAS affect reproductive health?
Exposure to PFAS is linked to developmental and reproductive toxicity, including low birth weight, thyroid disruption, harm to the male reproductive system, pregnancy-induced high blood pressure, and some evidence of infertility and shorter duration of breastfeeding.
What are the public health benefits from this rule?
According to the EPA, the standard will prevent tens of thousands of serious PFAS-attributable illnesses or deaths. The agency estimates that these new PFAS limits will result in 1,232 fewer birth-weight-related infant deaths; 1,928 fewer kidney cancer deaths; 1,844 fewer bladder cancer deaths; and 3,584 fewer deaths caused by cardiovascular disease.
How does PFAS exposure raise the risk of cardiovascular disease?
Exposure to PFAS through drinking water contributes to increased PFAS in blood serum. This can lead to increases in total cholesterol, changes in high-density lipoproteins and elevated levels of systolic blood pressure. Changes in these factors are associated with a higher risk of cardiovascular events, such as heart attacks and strokes.
How do PFAS increase the number of infant deaths?
Exposure to PFAS has been linked to developmental problems, such as low infant birth weight, birth length, and head circumference at birth. Low birth weight is an important factor in survival rates and medical care costs among infants.
Are children more susceptible to the harms caused by PFAS?
Because children are still developing, they may be more sensitive to the harmful effects of chemicals like PFAS. Children drink more water, eat more food and breathe more air per pound of body weight than adults, which can increase their exposure to PFAS.
Young children crawl on floors and put things in their mouths which leads to a higher exposure to PFAS from carpets, household dust, toys and cleaning products. Breast milk with PFAS and formula made with water containing PFAS can expose infants to PFAS, and it’s also possible for the the developing fetus to be exposed.
Areas of Focus Food & Water Water Toxic Chemicals PFAS Chemicals Disqus Comments Guest Authors EWG Staff April 5, 2024The True Cost of PFAS and Global Foundries Government Grants and Contracts
By Marguerite Adelman
April 7, 2024
Aerial view of the Global Foundries facility in Essex Junction, Vermont. The facility is on the Winooski River which flows into Lake Champlain.
Excuse me if I don’t celebrate the $125 million in federal and $4.5 million in state funding that Global Foundries (GF) announced at a press conference in March or the Department of Defense (DoD) multi-year contract for $3.1 billion in September of 2023. Just so you know, GF is located in Essex Junction, Vermont. The company makes semi-conductors and since 2015, occupies the 11.5 acres of the former IBM chip-manufacturing facility. Global Foundries is also the largest private employer in Vermont.
Besides our tax dollars for these grants and contracts, Vermonters will be paying exorbitantly now and into the future for the per- and polyfluoroalkyl substances (PFAS) and other hazardous materials linked directly to the environmental contamination resulting from the semiconductor chips made by GF. PFAS are used extensively in the semiconductor industry from the photolithographic processes to chemical processing to packaging to the assembly system lubricants. The chip industry considers PFAS essential to its manufacturing processes and end products.
Semiconductor chips are at the center of GF manufacturing processes. The chips are used in solar and wind energy, electric vehicles, power grids, aerospace and defense systems, and so much more. The green energy revolution and the defense industry are reliant on PFAS, a man-made class of 15,000 toxic chemicals that bioaccumulate in living beings and are linked to birth defects and myriad chronic diseases. PFAS last for hundreds and thousands of years, hence the name, “forever chemicals.”
The Cost of PFAS Discharges and Air Emissions
If you look up GF in the Environmental Protection Agency’s new PFAS Analytic Tools, you’ll find some shocking results under “greenhouse gas emissions.” Global Foundries’ PFAS air emissions in Vermont are documented at over 262 metric tons for the past 12 years, averaging 22 metric tons or 48,501 lbs. per year.
Under “discharge monitoring,” the EPA permit requires GF to monitor the release of Vermont’s 5 regulated forms of PFAS into the Winooski River. The discharges have increased from 218 lbs. in 2021 to 486 lbs. in 2023.
Why are these numbers significant? According to a Minnesota Pollution Control Board report, PFAS can be bought for $50 to $1,000 per pound. It’s a pretty cheap chemical. However, it costs between $2.7 million to $18 million per pound to remove PFAS from municipal wastewater, depending on the facility size and type of PFAS.
The cost to prevent 48,501 lbs. of GF’s PFAS air emissions per year is harder to calculate. A Science Direct article estimates the cost at $0.9 million to $67 million per kg. of PFAAS (a subclass of PFAS). Twenty-two metric tons per year equals 22,000 kgs. When you do the math, the cost to prevent PFAS emissions into the air is in the millions and billions.
PFAS Personal Health Costs
The health costs of PFAS must also be considered. PFAS chemicals are endocrine disruptors, resulting in birth defects and chronic diseases, including breast cancer, endocrine disorders, metabolic disorders, kidney cancer, testicular cancer, liver disease, reproductive disorders and infertility, thyroid disorders, high cholesterol, and ulcerative colitis. A compilation of toxicity studies shows that virtually every type of PFAS examined is correlated with these adverse health outcomes. Cancer rates and infertility among both men and women are increasing, and the Centers for Disease Control has just recommended that people discuss getting PFAS blood tests with their doctors.
Health Care, Water, and Military Site Clean Up Costs
An NYU Grossman School of Medicine study estimated the annual health-related costs of PFAS between $5.5 to $63 billion annually. Removing PFAS from U.S. drinking water supplies to meet the EPA recommended Maximum Contaminant Levels (MCL) could add more than $3.2 to $7 billion annually to the bill, according to a report from the American Water Works Association. These PFAS-related water expenses are substantial costs for any community, but especially for low-income and small rural communities. Cleaning up PFAS at U.S. military bases could cost at least $31 billion. All of these costs could be broken down to represent what Vermont would be paying for health care, drinking water, and military bases, but I think you get my point.
After these celebrated grants and contracts have been fulfilled, Vermont citizens will be paying personally with their health and their money for a very long time. The semi-conductor chips used in the green energy revolution to slow climate change are sacrificing our health and our environment.
The “Not So Green” Revolution
There can be no green revolution with PFAS. However, there are already safer alternatives for most forms of PFAS. The International Chemical Secretariat, an independent non-profit that advocates substitution of safer alternatives to toxic chemicals, has online tools that industries can use to identify PFAS in their processes and products in order to find safer replacements.
PFAS chemicals are cheap to buy, but enormously expensive to clean up. According to Food and Water Watch, the U.S. chemical industry spent over $110 million during just the last two election cycles, deploying lobbyists to kill dozens of pieces of PFAS legislation—they were successful. It’s a shame that industry lobbying money wasn’t spent to develop safer alternatives.
Every day of delay in legislation leads to more PFAS contamination that irreversibly accumulates in the environment, harming our health and the health of future generations.
Treat the PFAS pollution crisis as the emergency that it is. Turn off the PFAS tap now and forever.
References:
https://awsedap.epa.gov/public/extensions/PFAS_Tools/PFAS_Tools.html
https://www.pca.state.mn.us/sites/default/files/c-pfc1-26.pdf
https://www.sciencedirect.com/science/article/abs/pii/S0048969724007861?via%3Dihub
https://www.medpagetoday.com/publichealthpolicy/environmentalhealth/108346
https://www.sciencedaily.com/releases/2022/07/220726132528.htm
Marguerite Adelman is the Coordinator of the Vermont PFAS/Military Poisons Coalition, a project of the Women’s International League for Peace and Freedom (WILPF) Burlington Branch and WILPF US Earth Democracy Committee
Bellona’s new working paper analyzes Russia’s big LNG ambitions the Arctic
The use and production of LNG in the Arctic is a particularly fraught issue due to the region’s vulnerable climate. All operations with natural gas inevitably emit methane – a short-lived greenhouse gas 80 times more intense than CO2. Because of this, expanding LNG’s use as a shipping fuel and increasing its extraction in Arctic reserves is a matter of great concern to environmentalists.
Prior to launching their invasion of Ukraine, Russian authorities actively lobbied for the use of natural gas as a “green” solution in the international arena in a bid to prolong the use of fossil fuels for as long as possible. Indeed, gas exports are the lifeblood of the current political regime. Subsequent sanctions targeting Russian natural gas exports and related industries have curbed Russia’s ambitions, but certainly has not stopped them.
The newly published working paper by Bellona gives an overview of the Russian LNG sector with a focus on the current status and future projections of LNG production and use as ship fuel in the Russian Arctic. The influence of economic sanctions on Russian LNG development plans are also analyzed in the paper.
Bellona supports an appeal urging the EU and G7 countries to ban LNG imports from Russia, as well as its transshipment through European ports for exports to other countries. Along with strengthened economic sanctions on oil, the appeal will help shrink Russia’s budget revenues, and therefore, its ability to continue its military invasion of Ukraine.
Download a PDF of the report here.
The post Bellona’s new working paper analyzes Russia’s big LNG ambitions the Arctic appeared first on Bellona.org.
EWG sponsors bill to ban use in California of toxic weedkiller linked to Parkinson’s disease
SACRAMENTO, Calif. – The Environmental Working Group is sponsoring legislation that would ban the use of the highly toxic herbicide paraquat in California.
Past and recent peer-reviewed scientific studies have found a strong connection between paraquat exposure and an elevated risk of Parkinson’s disease.
If passed and signed into law by Gov. Gavin Newsom, Assembly Bill 1963, authored by Assemblymember Laura Friedman (D-Burbank), would end the use of paraquat on fields and orchards in the state by January 2026.
“The evidence is clear: Paraquat poses a serious risk to human health and the environment,” Friedman said. “With dozens of countries already banning its use, it’s time for California to follow suit to protect Californians, especially those in rural communities, from exposure to this toxic weedkiller. We cannot afford to ignore the mounting evidence linking paraquat exposure to Parkinson’s disease, non-Hodgkin lymphoma and childhood leukemia.”
Exposure to paraquat has consistently been linked to an increased risk of developing Parkinson’s disease, a progressive brain disorder that sparks involuntary motions, such as tremors, stiffness and a loss of balance. These symptoms worsen over time and permanently impair a person’s ability to move and speak.
“California must take decisive action to safeguard public health by enacting this legislation to permanently prohibit paraquat spraying on farms across the state,” said Bill Allayaud, EWG director of government affairs in California. “Paraquat poses a significant threat to the health of farmworkers, their families and surrounding communities.”
An EWG analysis published on March 27 shows paraquat is disproportionately sprayed in areas of the state inhabited by Latino farmworkers and their families, exacerbating environmental health risks for these communities.
Using state pesticide use data, EWG researchers found that 5.3 million pounds of paraquat were sprayed in California from 2017 to 2021, with Kern County standing out as a hot spot. Over 80 percent of residents in the Kern County communities of Shafter and Wasco are in proximity to spraying of almost 180,000 pounds of paraquat.
Over a decade ago, an analysis based on data from the National Institutes of Health found that workers who handle paraquat are more than twice as likely to develop Parkinson’s disease as those who apply other pesticides. A sweeping meta-analysis combining the findings from 13 studies bolstered this conclusion, revealing a 64 percent increase in the risk of Parkinson’s disease linked to exposure to paraquat.
For years, the primary manufacturer of paraquat, the Swiss-based and now Chinese-owned chemical giant Syngenta, knew about the health hazards associated with the chemical, including its correlation with Parkinson’s disease. But instead of disclosing this crucial information to the public and the Environmental Protection Agency, Syngenta spent decades concealing that information.
In 2022, The New Lede, a nonprofit news organization, published its exposé “The Paraquat Papers,” documenting the decades Syngenta spent plotting to hide its own scientific evidence and undermine independent research showing a link between exposure to paraquat and Parkinson’s.
More than 60 countries have banned paraquat, but the EPA continues to permit its use on crop fields, disregarding mounting evidence of harm – even though the agency does not allow the pesticide to be used on golf courses.
And the EPA has even warned “one sip can kill” with ingesting paraquat, which has been the cause of suicides and accidental fatal poisonings all over the world, underscoring just how toxic the chemical is.
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Full disclosure: The New Lede, which launched in May 2022, is a journalism initiative of EWG and is a distinct service that operates independently of the organization’s advocacy and communications units. EWG has no influence on editorial decision-making at The New Lede.
The Environmental Working Group is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action.
Court prohibits Eurowings greenwashing adverts
- German airline, Eurowings, has been prohibited from advertising flights as “CO2 neutral” through carbon offsetting, by Cologne Regional Court
- Eurowings had misled customers with its greenwashing claims, the court ruled
- Forest offsetting projects are unsuitable for CO2 compensation from aviation
Berlin, 2nd April 2024 – On March 28th, “Deutsche Umwelthilfe” (DUH) achieved a success against misleading sustainability advertising by the airline Eurowings. The Cologne Regional Court in Germany fully upheld the complaint brought by the environmental and consumer protection organisation. The court prohibited the airline from advertising flights whose emissions are offset with a few euros as “CO2-neutral” in the form in which they were advertised at the time the lawsuit was filed.
The court found that the forest protection projects used for the alleged offsetting of emissions are not suitable for achieving actual compensation: Forest projects cannot be operated for the same length of time as the CO2 emitted by the flight remains in the atmosphere.
Magdalena Heuwieser, spokesperson of the Stay Grounded network: “Offsets are a licence to pollute. They legitimise business as usual, don’t work, and can lead to new injustices. The industry cannot buy itself out of the necessity to reduce flights. Greenwashing is a major obstacle to the changes that need to happen to counter climate collapse. The sad truth is that the only green plane is the one that stays on the ground.”
Jürgen Resch, Federal Managing Director of DUH: “With its court ruling, the Cologne Regional Court has fully confirmed our legal opinion. An airline that pretends to offer its customers ‘CO2-neutral’ flights for a few euros more is acting in a highly misleading manner if it uses forest protection projects that are only secured for a few years. With this trickery, Eurowings is trying to divert attention from the climate-damaging nature of its business model. The compensation projects that supposedly protect the forest are not suitable for neutralising the greenhouse gas emissions caused by the flights.” (see original quote in German here: https://www.presseportal.de/pm/22521/5745740)
Eurowings uses an offsetting calculator to offer its passengers the opportunity to make their flights supposedly “CO2-neutral” by making a small financial contribution to forest protection and cooking stove projects. However, according to DUH’s conviction, which was fully shared by the court with regard to the forest protection projects, the projects listed are completely unsuitable for offsetting flight emissions and cannot ensure the promised compensation.
Press Contact: Magdalena Heuwieser, press@stay-grounded.org, +436703534311
Background
Apart from Eurowings, also other airlines have been found guilty of greenwashing. On March 19th 2024, another court had ruled that the Dutch airline KLM misled customers with its green claims. Already om 2020, KLM had been ordered to change advertisements that misleadingly implied up to a 50% usage of so called “Sustainable Aviation Fuel” (SAF), when in reality biofuel only accounted for 0.18% of the airline’s fuel use in 2019. In 2023, after conducting an investigation into offsetting claims in the airline industry, the Netherlands Authority for Consumers and Markets (ACM) accused Ryanair of using misleading sustainability claims. In 2020, Ryanair already had an advert banned in the UK for claiming it was the UK’s lowest-emissions airline. In 2022, Austrian Airlines was reprimanded by the Austrian Advertising Council for a misleading advertisement about “CO2-neutral” flying. An advert by Qatar Airways at the UEFA Euros 2020 football tournament suggested without any evidence that it could help passengers “Fly Greener”, prompting calls for the UK’s Advertising Standards Authority (ASA) to crack down on greenwashing. Austrian Airlines (AUA) are no longer allowed to say their flights are CO2-neutral – since this is a lie as reported by after successful court case by The Association for Consumer Information (VKI). The VKI had sued AUA for advertising flights as CO2-neutral. The Korneuburg Regional Court followed the legal opinion of the VKI and judged the advertising to be a misleading business practice. That same advert was ruled as misleading by the Austrian Advertising Agency after complaints by Stay Grounded member Eric Stam.
Stay Grounded is a network for 215 member initiatives around the world, including community groups surrounding airports, NGOs, and trade unions. The network campaigns for a fair reduction of aviation and for a just mobility system that works for all, now and in the future. https://stay-grounded.org
Der Beitrag Court prohibits Eurowings greenwashing adverts erschien zuerst auf Stay Grounded.
Anemic EPA announcement warning farmworkers of health risks of pesticide DCPA doesn’t go far enough
WASHINGTON – Today the Environmental Protection Agency publicly warned farmworkers of the “serious, permanent, and irreversible health risks” posed by the pesticide DCPA – in what is likely a final step before the agency bans the toxic weedkiller.
The announcement disappointingly restates what the agency found in a critical health assessment released by the EPA, in May 2023, highlighting the significant risks DCPA poses to humans – particularly to farmworkers and pregnant people. The weedkiller is sold in the U.S. under the brand name Dacthal.
“The EPA’s own conclusions and the overwhelming scientific evidence underscore the ongoing risks of the toxic pesticide DCPA,” said Environmental Working Group Senior Toxicologist Alexis Temkin, Ph.D. “As long as DCPA continues to be legal, the chemical will continue to pose real dangers to farmworkers, people who are pregnant and other vulnerable populations exposed to it.”
The EPA’s conclusion is based on its analysis of research by AMVAC – the agrochemical giant that is the only manufacturer producing DCPA for the U.S. market – showing that DCPA can harm the developing fetus, even at very low doses. Although the EPA asked for the study in 2013 because of emerging concerns about the threat DCPA poses to human health, AMVAC didn’t submit it until 2022 – nine years later.
Since 2018, EWG has sounded the alarm about DCPA due to serious concerns about the harm it can cause to exposed people. The organization called for a ban on the herbicide in 2021 public comments to the agency and in official comments submitted to the agency in July 2023.
The EPA classified DCPA as a “possible carcinogen” in 1995, and it’s been banned in the European Union since 2009.
“It’s past time for the EPA to ban DCPA,” said EWG President Ken Cook. “The agency should have taken action to cancel DCPA uses 10 months ago, when it first released these findings, and must now act immediately to protect farmworkers and others from this dangerous weedkiller.”
DCPA can drift from the fields where it is sprayed, and it is regularly detected in dust samples from the homes of farmworkers and those living in farming areas. A 2021 study from a group of researchers found an association between DCPA in dust samples and higher risk of childhood leukemia.
A 2019 study led by scientists at the University of California at Berkeley School of Public Health found that more than 50 percent of adolescent girls from farmworker communities in the Salinas Valley had been exposed to DCPA.
A 2022 peer-reviewed study by EWG scientists identified DCPA as a pesticide of concern, due to its toxicity and capacity to harm the thyroid, and its classification as a possible cause of cancer.
Other EWG research found that, even though the EPA had evidence of DCPA’s health risks, up to 200,000 pounds of the chemical was sprayed during some years in California – even while the agency continued to delay taking action.
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The Environmental Working Group is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action. Visit www.ewg.org for more information.
Areas of Focus Food & Water Farming & Agriculture Farm Pollution Food & Farm Workers Toxic Chemicals Pesticides Agency must take immediate action to cancel weedkiller Disqus Comments Press Contact Sarah Graddy sarah@ewg.org (202) 939-9141 April 1, 2024Navy report on PFAS at Pearl Harbor, Hawaii comes up short
By Pat Elder
March 31, 2024
Contamination at Joint Base Pearl Harbor-Hickham threatens human health.
The Navy is creating a narrative about PFAS in Hawaii by waging a sophisticated psychological campaign orchestrated to confuse the public while closing the books on huge swaths of perpetually contaminated land and water. We’ll look at the Navy’s Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023, Pearl Harbor-Hickham, Oahu.
The highly significant, yet relatively brief 238-page preliminary assessment was released to the public in mid-March, 2024 even though the State of Hawaii Department of Health reviewed the document in 2021.
The Navy began releasing PFAS preliminary assessments all over the country seven years ago. What took so long in Hawaii?
The Navy’s superficial study coincides with the Army’s report on PFAS in December, 2023, in which the Army glossed over contamination on eight bases while dismissing an additional eight bases from further PFAS-related scrutiny. Compelling evidence suggests the Army is prematurely shutting down PFAS investigations throughout Hawaii. Now we see the Navy doing the same thing.
We still don’t have any data from these Navy facilities.
Congress requires the DOD to follow the Superfund, or CERCLA process in its investigation and “remediation” of PFAS contamination. CERCLA is the Comprehensive Environmental Response, Compensation and Liability Act. Hawaii is just now beginning to enter into the CERCLA process for PFAS.
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The Navy in Hawaii is dreadfully behind the rest of the country in the CERCLA “clean up” process.
The Naval command continues to adhere to the EPA’s outdated Health Advisory of 70 parts per trillion for a combination of PFOS and PFOA even though the EPA has instituted an interim health advisory of .02 ppt for PFOS and .004 ppt for PFOA in drinking water. The Hawaii Department of Health has set Environmental Action Levels of 7.7 ppt for PFOS and 12 ppt for PFOA.
There are many more PFAS compounds in drinking water and the environment the Navy steadfastly refuses to address.
Preliminary assessments include a historical record search and interviews with DoD employees (in the chain of command) who have historical knowledge of the operations that may have contributed to a potential release. It’s like kicking the tires. Theoretically, the information collected helps the Navy determine whether there is a “potential” historical release and if further investigation is warranted. If the Navy doesn’t thoroughly examine sites, it can rule them out in this crucially important first round of the CERCLA process – and that is exactly what we see with the Navy’s Preliminary Assessment. They’re not kicking many tires and it will save them a lot of money on “cleanup.”
The Navy will allow a small handful of sites to proceed to the site inspection phase of the CERCLA process so we must keep an eye on future reports. The site inspections are accompanied by data describing PFAS in multiple environmental media. There is a noticeable trend that shows all three branches are releasing less and less data in the site inspections. While the Navy has shared volumes of data with much of the country, that information has been largely withheld in Hawaii.
The skimpy 238-page report covers ten facilities in Honolulu. By comparison, Naval Air Station Point Mugu’s Preliminary Assessment (PA) contains 3,159 pages. Naval Air facility El Centro’s PA has 744 pages, while Hunter’s Point has 447 pages and Port Hueneme has 462 pages. These bases are in California.
The Patuxent River Naval Air Station in Maryland, a much smaller facility than Joint Base Pearl Harbor Hickam, released its Preliminary Assessment back in 2018. They examined 48 sites and 16 of them moved on to the site inspection. Critics say most of these sites should have moved on to the site inspection phase.
At JBPHH, the Navy examined 18 locations on 10 facilities and identified 13 locations to be further scrutinized in the site inspection.
The Navy’s Preliminary Assessment includes the following facilities:
· Joint Base Pearl Harbor Hickam
· Naval Computer and Telecommunications Area Master Station (NCTAMS)
· Pearl Harbor Solid Waste Management Unit 13 (SWMU 13)
· Pearl Harbor Solid Waste Management Unit 6 (SWMU 6)
· Navy Munitions Command, East Asia Division Unit Pearl Harbor
· Fleet and Industrial Supply Center Pearl Harbor.
· Pearl Harbor Naval Submarine Base
· Pearl Harbor Naval Shipyard
· Naval Computer and Telecommunications Area Master Station - Naval Facilities Engineering Command Pacific National Priorities List site
· Pearl Harbor Naval Complex (PHNC) National Priorities List Site
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A prevalent theme runs through the Navy’s rationale when describing potential pathways to the human ingestion of these carcinogens. They want the public to forget that these toxins may migrate off their installations!
We can gain an understanding of the psychology inherent in the Navy’s report by analyzing the following section pertaining to three areas that used aqueous film-forming foam, or AFFF.
Human Health Exposure Pathway Evaluation
Figure 3-10, shown and analyzed in 5 brief sections below, appears in the Navy’s preliminary assessment. It analyzes three sources of PFAS contamination:
· Ford Island - Building 467 Fire Station #4.
· Richardson – Fleet Training Group Firefighting (FLETRAGRU) Training Area.
· Pearl Harbor Main Base - Building 206 Fire Station #1.
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Exposure pathways identified by the Navy include:
· Dermal contact from surface soil
· Inhalation of particulates
· Ingestion of plant/animals
· Dermal contact from surface water
· Ingestion of fish/shellfish
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Figure 3-10 Preliminary Assessment Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023
The Navy: “Incidental ingestion and dermal contact with surface soil in areas with exposed dirt at all sites are potentially complete exposure pathways for all listed current and future receptors, although PFAS are not known to be absorbed dermally and information pertaining to health effects from dermal exposure is limited.”
Military Poisons: The scientific consensus is that dermal exposure to PFAS is of relatively low concern for most people - compared to ingesting contaminated food or drinking tainted water. Still, dermal exposure may be an important pathway for some. Firefighters across the U.S. are filing lawsuits against turnout gear manufacturers, claiming that the PFAS in their protective turnout gear caused cancer through dermal contact. Also, several states have moved to post signs warning recreational swimmers to avoid the PFAS foam.
The Navy: “Onsite occupational workers could potentially be exposed during the workday, with duties that might include landscaping/grounds maintenance.
If the property ownership changes, future residents could potentially be exposed to contaminants of potential concern in soil during outside activities (e.g., gardening) or to contaminants of potential concern in house dust originating from site soil at the Marina Park sites.”
“Because the fire stations are on a secured military base, it is unlikely that trespassers or recreational users would have on-site access (this rationale applies for all on-site pathways for these receptors). However, the Marina Park Former FLETRAGRU fire-fighting training area is an unrestricted area used for recreation, thus current and future dermal contact may occur.”
Military Poisons: The Navy makes the dust sound relatively insignificant. Carcinogenic dust is a major route of exposure, and it endures forever. PFAS coats the banks of Pearl Harbor’s streams and shoreline. When the streams ebb and the tide falls, the toxic sediment dries and is lifted into the wind. It settles as dust in our lungs and in our homes. Hawaii’s Department of Health ought to be testing people’s homes. It’s up to the activists to make it happen.
The graphic here shows the concentrations of PFAS in the dust of homes in a neighborhood outside of the Shepherd Field Air National Guard Base in Martinsburg, West Virginia.
Sources - Final Expanded Site Inspection Report for Per- and poly fluoroalkyl substances Shepherd Field Air National Guard Base – November 2020. - and PFAS Exposure Assessment - National Center for Environmental Health Agency for Toxic Substances and Disease Registry, Martinsburg, West Virginia – January, 2022.
Dust containing 16.4 million ppt of PFHxS and 13.9 million ppt of PFOS were found in a home in a neighborhood outside of the base. In Martinsburg, the Air Force reported that groundwater on the Shepherd Field Air National Guard Base contained 80,000 ppt of PFHxS, while they reported 8,100 ppt of the toxin in surface water on base. Consequently, residents showed elevated levels of PFAS in their blood, another “environmental media” that ought to be tested, like they’re doing throughout Japan.
The red dot is the location of the pump house at Adit 1. The location is 1,000 feet from Pearl Harbor. It leaked 5,000 gallons of PFOS containing 200,000 parts per trillion of PFOS. The floor of the pump house is made of porous material. This area is contaminated forever, and the dust is likely to be highly poisonous. The Navy kept this a secret as long as it could.
Figure 3-10, continued -
The Navy: “VOC’s are not COPC’s for any of these PFAS, so this pathway is incomplete.”
Military Poisons: C’mon, Navy! Write it so people can understand it. VOC’s are volatile organic contaminants like benzene, ethylene glycol, formaldehyde, methylene chloride, tetrachloroethylene, toluene, xylene, and 1,3-butadiene. Enough exposure to these will kill you as well. COPC’s are contaminants of potential concern. PFAS are the COPC’s du jour et pour toujours! (of the day and forever.)
The Navy: “Inhalation of particulates from surface soil is considered potentially complete for all current and future on-site receptors. Winds can cause the formation of fugitive dusts by suspending surface soil particulate matter in air. Shallow excavations and earthwork would also enhance the generation of soil dusts.”
Military Poisons: “Potentially complete”? Still, it’s rare to read such candor from the Navy. The continued agitation by activists in Hawaii pays dividends, although this Goliath is not easily moved.
Figure 3-10, continued -
The Navy: “Bio-uptake is considered an incomplete pathway for most current and future on-site receptors because no agricultural or hunting activities occur at the sites and occupational workers and construction workers are not expected to eat produce or animals obtained from these sites. If the property ownership changes, future residents could potentially be exposed during gardening activities. However, such exposure would likely be insignificant compared to other pathways.”
Military Poisons: How about a thousand years from now and what about off-site receptors? We can expect profound contamination of the entire food web, starting with the soil, sediment, surface waters, and invertebrates.
Figure 3-10, continued -
The Navy: “Because of the close proximity of waterways to the Bldg. 467 Fire Station Number 4 and Marina Park former fire-fighting training area, contaminants of potential concern in site surface soil could migrate to the off-site water body of Pearl Harbor. Exposure pathways in these waterways are considered insignificant for recreational users/trespassers, however, because of expected low exposure time, frequency (based in part on Pearl Harbor access restrictions) and concentrations. Exposure of current and future onsite workers and future residents is considered incomplete. If exposure to these receptors were to occur, it would occur off site, and they would have the same exposure as a recreational user/trespasser.”
Military Poisons: The Navy has created a parallel universe and prefers to live in it.
Figure 3-10, continued -
The Navy: “The same rationale for incidental ingestion and dermal contact in waterways apply to bio-uptake pathways.”
Military Poisons:
Most of the PFAS in our bodies is from the “Ingestion of fish/shellfish,” an inconvenient truth for Hawaii.
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Preliminary assessments are all about the environmental sites that proceed to the site inspection phase of the CERCLA process.
With this preliminary assessment in Hawaii, only sites identified as Group A, B, or C are recommended for further evaluation for PFAS in the Site Inspection. Therefore, only 13 sites from the 10 facilities will be further scrutinized. The descriptions of two of the Group D sites which were eliminated from further inspection were redacted. The Navy is only admitting they used the carcinogenic foams at seven “Group A” locations on these facilities. We’ll examine this below.
Like the Army - the Navy is focusing on the firefighting foams while they use PFAS in hundreds of products and applications every day. Congress directed the DOD to prepare a report outlining the uses of PFAS that are critical to the national security of the United States. Lots of things fit that bill! In response, the DOD published a report on Critical Per-and Polyfluoroalkyl substance uses in August, 2023.
Today, the contamination in Hawaii has more to do with the everyday, routine use of PFAS in products and applications, like tape made with Teflon, adhesive sprays made by 3M, or Viton, made by the Chemours Company, that is added to synthetic rubber. 3M’s Novec Cleaner is loaded with PFAS. It is all irreplaceable, according to the U.S. military. Almost all of it winds up in the sewer effluent, the sewer sludge, or the landfill - three locations not covered by the preliminary assessment.
Groups A,B,C,D in the Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023
Group A: Known release sites (fire suppression for crashes, hangar tests); or repeated small quantity release sites (fire fighting training area [FFTA]), first occurring in the mid-1960s, where AFFF suppressants known to have contained PFAS were documented to have been used. Group A sites are considered the most likely to have impacted the subsurface soil and/or groundwater.
Group B: Potential release sites, including areas where AFFF suppressants known to have contained PFAS were documented to have been stored or used and/or lacked documented housekeeping practices, but have no known releases (e.g., fire stations, hangars, flight lines, runways, AFFF handling/storage areas).
Group C: Electro-plating facilities that may have utilized vapor suppressants containing PFAS.
Group D: Potential other secondary sources of PFAS releases (areas with documented housekeeping practices or where compounds containing PFAS were not intentionally released, including landfills, sludge disposal areas, and oil-water separators). These areas do not have documentation of past use of AFFF or PFAS.
Eliminating landfills from the Site Inspection is unwise. The Navy admits that firefighting foams “may have been released” to the landfills. We know many industrial items containing PFAS are disposed of in landfills. Sludge disposal areas, both on base and off base are typically heavily impacted by the carcinogens. Where does the sludge go? We can’t burn it, we can’t bury it, and we can’t spread it on agricultural fields.
Here’s a task for researchers to learn about the role played by the Hawaii Department of Health during their review of this preliminary assessment back in 2021. Go all the way to the last two pages of the document to see the comments by the Hawaii Department of Health and the Response to DOH comments by the Navy.
Environmentalists ought to keep an eye on Table ES-1 below.
The Downs Law Group helps to make this work possible. Their support allows us to research and write about military contamination around the world.
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If you spent time in the military and you think you or your dependents may be sick as a result of your service, think about joining this group to learn from others with similar issues.
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Clock ticking to fight foolish EPA analysis allowing toxic weedkiller paraquat
It seems like an April Fools’ Day joke – the Environmental Protection Agency is defending its analysis permitting the use of the weedkiller paraquat, despite its links to Parkinson’s disease. With ironic timing, the EPA has set an April 1 deadline for public comment on why its analysis is laughable.
Paraquat has also been associated with increased risk of non-Hodgkin lymphoma, childhood leukemia and more. Dozens of countries have already banned its use.
While the EPA says paraquat is too toxic for use on U.S. golf courses, it still allows use of the herbicide on farms. This threatens the health of the people who apply it, other farmworkers and those who live or work near crop fields where it’s used.
In California – the only state that readily discloses data on paraquat use – a just-released EWG analysis found that 5.3 million pounds of the chemical were sprayed between 2017 and 2021. And most of it took place in 10 counties, several of which are majority Latino and lower-income.
A recent study confirms that in California, paraquat exposure at work or at home, whether from direct exposure or from drift through air, is linked to Parkinson’s disease.
The EPA doubled down on its approval of paraquat in February by issuing an interim decision that said its position was justified by its review of the science. But as EWG has shown, that justification contains five fatal flaws – including ignoring the alarming evidence about the links between paraquat and a range of serious health harms:
- The agency dismisses a growing body of research linking paraquat to Parkinson’s disease.
- It ignores new evidence about the potential health risks of paraquat that has emerged from legal action against its maker, Syngenta.
- The EPA ignores the fact that paraquat is used far more heavily in some areas than others, including the communities highlighted in EWG’s California analysis.
- It continues to exclude from its paraquat analysis some of the ways people who work in or live near farm fields are exposed to toxic chemicals.
- And the agency fails to properly balance the costs and benefits of a paraquat ban, as other nations already have.
People concerned about paraquat have until April 1 to submit written comments to the EPA highlighting these momentous errors and urging it to ban the weedkiller. The agency’s notice about its analysis explains the simple steps involved in filing comments through a government website, a process that can take just a few minutes.
EWG is crafting detailed comments to submit to the agency critiquing the analysis. The comments will underscore the danger paraquat can pose to anyone exposed. EWG will also repeat its call for the agency to block domestic paraquat uses, which would bring the U.S. in line with 60-plus countries that have enacted such a ban.
Syngenta makes paraquat in China and the United Kingdom. The Swiss-based company, which was acquired by a Chinese state-owned chemical conglomerate, has long understood the weedkiller’s health risks. But it spent decades hiding this knowledge from the public and the EPA. In another ironic twist, the Chinese, Swiss and U.K. governments ban the use of paraquat due to potential health risks from exposure.
The looming April 1 deadline is a prime opportunity for the public to remind the EPA about the foolish decision it’s making by ignoring the dangers of paraquat.
Even if the EPA continues to allow the use of paraquat, states can act. Federal pesticide law sets a floor, not a ceiling, so states can pursue bans of the weedkiller. Such moves would protect public health until the agency does.
Areas of Focus Farming & Agriculture Food & Farm Workers Toxic Chemicals Paraquat Pesticides Disqus Comments Authors Anthony Lacey March 29, 2024Monthly Highlights from the Russian Arctic, February 2024
Ensuring complete and reliable access to environmental information in Russia has never been fully guaranteed. Following the Russian invasion of Ukraine on February 24, 2022, it became even more difficult. Some information ceased to be published altogether, such as daily oil production data and annual reports from certain industrial companies. Independent environmental organizations have been banned or closed.
The Arctic region plays a crucial role in comprehending the process of global climate change. Russia owns approximately one-third of this territory, including the exclusive economic zone of the Arctic Ocean. To understand and examine trends, we monitor new legislation, plans of industrial companies, the Northern Sea Route, international economic sanctions, accidents, and emergencies in the Russian Arctic, as well as provide commentary on the news.
Our previous monthly highlights for January can be found here.
1. Environmental issues in the Russian ArcticOn February 1st, a bill was introduced to the State Duma proposing a ban on the operation of old worn-out oil pipelines
The bill suggests limiting the possibility of extending operation period of old pipelines to only once. This will hinder the use of deteriorating oil pipelines and potentially incentivize investments in the depreciation funds of enterprises.
The explanatory note to the bill notes that oil companies often operate pipelines laid in Soviet times, and the age of some of them is completely unknown. The absence of restrictions on the number of industrial safety assessments allows obtaining a positive conclusion an unlimited number of times, which, combined with corruption, leads to the degradation of pipelines and accidents. For example, according to the prosecutor’s office of the Khanty-Mansi Autonomous Okrug, almost all ruptured oil pipelines in the region had a positive conclusion of the last assessment.
Oil spill near Usinsk, Komi Republic, 2017. Photo: Internet magazine “7×7” / semnasem.orgBellona сomment: This bill was introduced to the State Duma by a member of the Russian Communist Party from the Komi Republic, which underscores the scale of the oil spill problem for the region. It was developed with the involvement of the independent environmental organization Committee to Save the Pechora, which, together with Greenpeace Russia (before its closure), has been trying to promote this initiative for 8 years.
Pipeline ruptures in Komi occur regularly, and 90% of them are associated with pipe wear. Moreover, the majority of oil spills (up to 70%) are concealed and do not appear in the reports of either Rosprirodnadzor or the media. However, this is not just a problem in Komi. According to official data for the whole of Russia, there are annually from 8 to 12 thousand accidents on oil pipelines.
Despite the potential benefits of this initiative for the environment, there is no certainty that the bill will be adopted. According to statistics, the majority of bills introduced to the Duma by members of the Communist Party are rejected.
Russian Geographical Society is recruiting volunteers for its new environmental organization “Arctic Volunteer” until the end of FebruaryThe new environmental movement “Arctic Volunteer” was established in 2023 by the Russian Geographical Society (RGS) as part of the youth environmental and social project “Arctic. Big Cleanup” with the support of the Presidential Grants Fund. The description of the movement states that “it gives young Russians the opportunity for self-realization and career growth, a chance to participate in the socio-economic life of Arctic regions and solve complex and relevant problems.”
Bellona сomment: The creation of a new environmental movement by a state structure is one of the vivid examples of the trend in recent years to replace independent environmental non-governmental organizations with associations controlled by state structures. The goal of this is to show the public, especially young people, what kind of public environmental activity is welcomed by the state (physical garbage collection or tree planting), and which is not, as well as to take control over this activity.
At the same time, while all international independent environmental NGOs, including Bellona, Greenpeace, and WWF, have been expelled from Russia, and local environmental NGOs and movements are constantly under pressure, including closure and administrative or criminal prosecution of employees and activists, it seems like a logical step for the Russian dictatorship to organize active public to engage in activities that are safe for the state under the banner of environmental protection replacing independent initiatives and public control.
Interview with Scientists on Russia in the Context of Climate ChangeScientists from the Program on New Approaches to Research and Security in Eurasia (PONARS) have studied the impact of climate change on Russia and Russia’s role in global efforts to combat climate change or obstruct climate action. The main findings of the study indicate that Russia is already suffering from various consequences of climate change and is poorly prepared to adapt to them. While the rest of the world is moving towards renewable energy sources, the Russian government, heavily reliant on fossil fuels, is unwilling and unprepared to phase them out, which could potentially benefit the entire Russian society, emphasize the study’s authors.
2. Heightened Industrial Activity in the ArcticDevelopment of the Pizhemskoye titanium deposit in the Komi Republic will begin in 2026
Deputy Chairman of the Komi Government Anton Vinogradov announced that the Rustitan Group of Companies plans to launch the first stage of the Pizhemskoye titanium deposit development project in the Komi Republic in 2026.
The deposit is one of the world’s largest in terms of titanium and quartz reserves. Titanium ore reserves are estimated at 7 billion tonnes, while quartz sands are estimated at 1 billion tonnes. The projected investments in its development for the first stage are estimated at 52 billion rubles (EUR 521.2 mln), and for the second stage – 120 billion rubles (EUR 1.2 billion).
Bellona comment: Despite Russia being one of the world leaders in titanium production, the ore for its production was imported from other countries, until 2022 primarily from Ukraine. This legacy of production chains created back in the Soviet era did not stimulate investments in domestic mining until the annexation of Crimea in 2014. Work on the development project of the Pizhemskoye deposit has been ongoing since 2006, but only now, when due to the Russian invasion of Ukraine the supplies of Ukrainian ore have significantly decreased (although they continue through intermediaries), the project has real chances of implementation.
In 2022, another facility, owned by Rosatom, started extraction of titanium ores in the Tomsk region, also within the framework of import substitution of titanium ores to supply the Russian titanium producer VSMPO-Avisma (which produces 90% of Russian titanium and is under US and Canadian sanctions).
The geological features of the Pizhemskoye deposit allow for open-pit mining, which will inevitably lead to degradation of natural landscapes and pollution of surface waters. Ore processing is planned in the Ukhta region at ore dressing and chemical-metallurgical plants using chlorine and hydrochloric acid. In addition, there is a plan of construction of the Sosnogorsk – Indiga port railway, with a length of 559 km through the Komi and Nenets Autonomous Districts, using convict labor.
Arctic LNG-2 invites companies to collaborate on the construction of a large gas power plantNovatek, through its subsidiary LLC “Arctic LNG-2”, invites construction companies to declare their interest in the construction of a gas power plant on the Gydan Peninsula to support the operation of the planned second and third lines of the Arctic LNG-2 gas liquefaction plant.
Arctic LNG-2. Photo: LaNatalyBellona comment: A large gas power plant in the Arctic zone is an additional powerful source of greenhouse gases that will contribute to climate change. However, the extent to which these plans will materialize in the face of escalating economic sanctions against the Arctic LNG-2 project remains unclear.
Novatek tries to optimistically implement the project according to plan, although to date there are no buyers even for the LNG produced on the first line, the second line is likely to be launched with delays if buyers are found, and the construction of the third line has already been suspended. In such conditions, Novatek’s optimism seems like an attempt to convince potential buyers from Asia that the economic situation on the project is stable, although in reality, this is no longer the case.
3. Sanctions affecting Russian industry in the Arctic regions and the international situation in the ArcticIn February, the USA, the United Kingdom, the EU Council, Canada, Japan, and Australia imposed new sanctions in response to Russia’s aggression against Ukraine, timed to coincide with the two-year anniversary of the war
This time, the sanctions were mainly aimed at individuals and legal entities directly or indirectly involved in the activities of Russia’s military-industrial complex, as well as those involved in the abduction and resettlement of Ukrainian children or facilitating it.
Additionally, the list of goods banned for export to Russia due to their potential military use has been expanded. The sanctions also affect third countries to prevent circumvention of previously imposed restrictions, particularly it concerns shadow fleet vessels and traders facilitating the trade of Russian oil to bypass price ceilings.
United Kingdom
On February 22, the UK added 50 companies and individuals to its sanctioned list, including Turkish, Chinese, and Belarusian entities. New targets include ammunition manufacturers, electronics production companies, as well as diamond and oil traders. Among the companies from the Arctic region the updated list includes Novatek’s “Arctic LNG-2″ project and its management, the diamond mining company “AGD Diamonds” in the Arkhangelsk region, members of Novatek’s board of directors, and the management of the diamond company Alrosa.
USA
The new US sanctions list, published on February 23, consists of over 500 companies and individuals, including those operating in the Murmansk Sea Trade Port: Novatek-Murmansk (a subsidiary of Novatek, involved in the construction of large-tonnage marine facilities in the Murmansk region, including parts of the Arctic LNG-2 plant), Sevmorneftegeofizika (the largest marine geophysical company in Russia, a subsidiary of Rosgeologia), “KRDV Murmansk” (a subsidiary of the Ministry for the Development of the Russian Far East, managing company of the Arctic zone and the Far East), “Arctic Marine Engineering and Geological Expeditions” (conducts engineering and geological surveys on the Arctic shelf), as well as “SUEK” (Siberian Coal Energy Company, the largest coal company in Russia).
Furthermore, restrictions were imposed on “Almazyuvelirexport”, the state exporter of diamonds and precious metals, on the subsidiary of Rosatom “Rusatom Arctic,” established in 2023 to assist in the development of the Arctic region, and the state Corporation for the Development of the Far East and the Arctic (KRVD), as well as on the Far Eastern Shipbuilding Complex “Zvezda”, which is currently building 15 tankers for transporting LNG from the Arctic LNG-2 plant. “Zvezda” has been added to the SDN list, which means the inability to use the US dollar for settlements and the risk of secondary sanctions for all counterparties.
The Zvezda shipyard. Photo: Kremlin.ruEuropean Union
On February 23, the EU adopted the 13th package of sanctions, which included 194 legal and natural persons. This time, the sanctions targeted Russian companies and their executives associated with the defense complex, representatives of judicial and regional authorities, including those who contributed to the abduction and relocation of Ukrainian children. Additionally, foreign companies assisting Russia in circumventing previously imposed sanctions were included in the sanctions list, and the list of goods banned for export to Russia was expanded.
Canada
Canada has added 163 companies and individuals to its sanctions list and imposed a ban on the purchase of Russian diamonds and products containing them.
Previous sanctions affect Novatek’s Arctic LNG-2 projectAccording to the Barents Observer, Novatek’s 400-meter floating storage facility on the Kola Peninsula has been idle for six months. The vessel “Saam” arrived in the Ura Bay of the Barents Sea at the end of June 2023. It was intended for Novatek’s marine transshipment complex in the Murmansk region. It was planned that ice-class gas carriers would deliver gas from plants in Yamal and Gydan to the storage facility, and regular vessels would then transport it from there to buyers around the world. Based on ship movement data, the “Saam” has been idling in a remote bay since its arrival. It appears that the vessel has not transferred any batches of liquefied natural gas during this time.
According to Reuters, Novatek plans to open an office in China to assist in trading liquefied natural gas in Asia amid sanctions. This move was taken to find customers for LNG from the Arctic LNG-2 project in the face of US sanctions.
The third line of the Arctic LNG-2 project, according to TotalEnergies, has been suspendedOn February 7, 2024, the head of the French company TotalEnergies, Patrick Pouyanné, announced during a teleconference dedicated to the results of 2023 that the construction of the third line of the Arctic LNG-2 project has been suspended. TotalEnergies is no longer involved in project management due to the inclusion of the project in US sanction lists.
India is seeking alternative oil suppliers instead of Russia due to US sanctionsAccording to Bloomberg, the tightening of US sanctions is affecting oil trade between India and Russia. Russia remains a key oil supplier to India, but there are signs that Indian oil refineries are seeking to increase purchases from other countries.
Bellona comment: The EU and G7 sanctions pressure on the Russian economy continues to gradually intensify, although, for the most part, it is highly targeted at specific legal or natural persons. In a situation where international business usually utilizes endless chains of offshore firms and subsidiary structures, such tactic is not very effective, especially in the short and medium term.
A more effective way to significantly decrease Russian government income, and therefore limit its capability to fund military operations, is by imposing bans on importing Russia’s main export products like oil, gas, and metals. Additionally, implementing secondary sanctions on companies in third countries that still purchase Russian goods can further contribute to this effort. An example of this approach could involve imposing sanctions on projects like Arctic LNG-2.
Therefore, Bellona has joined an open letter from around 300 European, Ukrainian, and international NGOs to the EU and G7 countries calling for stricter price restrictions on Russian oil, a complete ban on LNG imports, a cessation of imports of oil products from third countries refining Russian oil, more rigorous control over shadow fleet vessels transporting Russian oil, and decisive measures to reduce fossil fuel consumption in their countries.
Russia has extended permission for a German trader to purchase gas from Yamal LNG until 2040Following Russia’s invasion of Ukraine in 2022, the German Government on April 4, 2022, transferred the Gazprom Germania group of companies – a subsidiary of Gazprom – under the management of the Federal Network Agency due to the company’s opaque legal relations and its importance to the country’s gas infrastructure. In May of the same year, by decree of the President of the Russian Federation, any transactions with this company were prohibited, which, after coming under the control of the German government, changed its name to Securing Energy for Europe.
As an exception, special permission for transactions to purchase Russian LNG was valid until the end of 2024. On February 9, by the order of Prime Minister Mikhail Mishustin, permission for LNG supplies from the Yamal LNG plant was extended until 2040.
Bellona comment: The search for new buyers of Russian LNG cannot be called successful, and Russia has to cling to the remaining clients in Europe and play by their rules.
On February 14, Russia suspended its annual contributions to the Arctic CouncilRussia suspended its contributions to the Arctic Council, expressing disagreement with its activities, which it believes do not align with Russian interests. The Russian Ministry of Foreign Affairs stated that Russia plans to resume payments after the practical work, such as ecosystem preservation in the Arctic and conducting research, is restored with all council members. There is no talk of Russia leaving the Arctic Council at the moment.
However, on February 6, the Russian Ambassador at Large for the Ministry of Foreign Affairs suggested that Russia could exit the Arctic Council if its activities “do not correspond to Russian interests”.
Representatives from Norway, currently chairing the council, oppose Russia’s exclusion, emphasizing the importance of shared responsibility for addressing Arctic region issues.
Flags of the members of the Arctic Council – eight states and six organizations of indigenous peoples of the north, and the flag of the Arctic Council itself. Photo: Arctic Council Secretariat / Linnea NordströmBellona comment: The Arctic Council is an intergovernmental organization of Arctic states founded in 1996, consisting of Russia, Norway, Denmark, Iceland, Canada, the United States, Finland, and Sweden, as well as representatives of Arctic indigenous organizations.
In response to Russia’s invasion of Ukraine in February 2022, Arctic Council countries refused to participate in meetings and joint projects with Russian officials. In March 2023, Russia changed its approach to cooperation in the North and removed any mention of the Arctic Council from its Arctic State Policy Foundations until 2035.
The suspension of payments is another political step by Russian authorities to distance themselves from Western countries, similar to their withdrawal from the Council of Europe, which was also preceded by the suspension of contributions. The refusal to make payments will not significantly affect the council secretariat’s work or project activities, which are funded by other sources, except for the possibility of implementing projects directly in the Russian Arctic with Russian participants, which is not currently happening anyway.
In this situation, it would be wise for other council members to focus on the remaining two-thirds of the Arctic territory, including both scientific research and the development of joint policies to limit pollution and factors influencing climate change.
4. Northern Sea Route and shipping65% of companies operating on the Northern Sea Route have zero transparency levels of environmental information
The Institute of Geography of the Russian Academy of Sciences conducted a study which revealed that out of 31 shipping companies operating on the Northern Sea Route, only two have a sufficient level of transparency of environmental information: Atomflot and the Far Eastern Shipping Company. Both companies belong to the Rosatom State Corporation and together manage 63 vessels (7% of the total number of vessels that entered Arctic waters under the Russian flag in 2022).
Bellona comment: In our January digest, we wrote that Russia topped the Top 10 list of countries with the largest number of vessels in the Arctic zone. According to the Arctic Council report, vessels under the Russian flag make up approximately half of the fleet operating in the Arctic. Of these, 93% belong to companies that do not publish reports on their environmental impact.
And those two companies that do publish reports do not show detailed statistics on emissions, in particular, they do not separate data on emissions of pollutants and greenhouse gases from stationary and mobile sources.
5. Accidents, emergencies, and violations of environmental legislation in the Russian ArcticIn February, two local environmental accidents were covered in the media: an oil spill in the Komi Republic at the facility owned by Lukoil-Komi, which could lead to oil products entering a stream, and pollution with coal dust in Murmansk due to coal transshipment at the Murmansk Commercial Port.
Companies of the timber industry holding “Segezha Group” were conducting continuous logging within the boundaries of planned protected natural areas in Karelia, namely “Maksimyarvi”, “Zaonezhsky”, “Kuzharvi”, “Lake Nyuk”, and “Vygozersky-2” (the last two territories are located in the Arctic zone). Representatives of the scientific community and environmental organizations noted that logging has disturbed at least 5 animal habitats and 29 sites of plant and fungal growth listed in the Red Books of Russia and Karelia. The share of the area occupied by protected natural areas in Karelia is twice as low as in neighboring regions of Northwestern Russia (5.6% compared to 11.2% in the Arkhangelsk region and 13.5% in the Murmansk region).
The post Monthly Highlights from the Russian Arctic, February 2024 appeared first on Bellona.org.
Bellona nuclear digest. February 2024
After Russia’s full-scale invasion of Ukraine in February 2022, Bellona ceased its activity in the aggressor country. On 18 April the Russian general prosecutor’s office declared Bellona to be an undesirable organization.
However, we continue to monitor events in the field of nuclear and radiation safety relating to Russia and Ukraine, which we believe are of interest to foreign readers. We analyze the situation in order to assess the degree of Russia’s international influence on other countries and the risks connected with this. We present you with a survey of these events for February 2024, with comments by experts of Bellona’s nuclear project Alexander Nikitin and Dmitry Gorchakov.
Follow the links to read the last three digests for January, December and November. Subscribe to our mailing list to make sure you don’t miss the next digest. Download a PDF of this digest here.
In this issue:NUCLEAR EVENTS IN UKRAINE AND THE WAR
1. Zaporizhzhia NPP. Event timeline for February 2024
INTERNATIONAL NUCLEAR EVENTS AND THEIR CONNECTION WITH RUSSIA
2. Sanctions on the second anniversary of Russia’s invasion of Ukraine
3. European Union doubled purchases of nuclear fuel from Russia in 2023
4. USA increases export of enriched uranium from Russia during discussion of new measures for its reduction
5. Plans to build new NPP in Armenia
6. Urenco continues cooperation with Russia
EVENTS IN THE RUSSIAN NUCLEAR SECTOR AND IN ROSATOM PROJECTS ABROAD
7. Rosatom’s mining division reports overfulfilling the plan for uranium production in 2023. But the figures raise questions
8. Disputes over legal disputes concerning Hanhikivi NPP in Finland
9. Rosatom projects abroad in brief
SEPARATE EXTENDED COMMENTARY ON A SIGNIFICANT EVENT OF THE MONTH
10. Rosatom’s “government hour” at the Russian State Duma
On 6 February, IAEA Director General Rafael Grossi met with Ukrainian President Volodymyr Zelensky in Kiev. Grossi informed the president about the main goals of the upcoming mission at the Zaporizhzhia NPP, and discussed the present safety situation and potential risks.
The IAEA delegation also met with Energy Minister Herman Halushchenko, the head of the State Nuclear Regulatory Inspectorate Oleh Korikov and the head of the Nuclear Energy Generating Company Energoatom Petro Kotin. The main topics of discussion were risks of licensed Ukrainian staff being dismissed from their positions at the ZNPP, and also the end of the operational life of nuclear fuel used in plant reactors.
The IAEA team in the western section of the turbine hall of unit 4, where the IAEA mission experts were not granted access for a lengthy period prior to Grossi’s visit. Photo: IAEAHerman Halushchenko noted that around 400 employees with licenses to perform necessary functions had been dismissed from the plant. The Permanent Mission of Ukraine to the IAEA emphasizes that refusing access to plant staff violates the third of the seven indispensable pillars of ensuring nuclear safety and security in the course of an armed conflict, which states that “the operating staff must be able to fulfill their safety and security duties and have the capacity to make decisions free of undue pressure”.
On the second issue, Grossi stated that the IAEA would insist that the IAEA experts carry out an assessment of the state of fuel in power units.
On 7 February, Grossi visited the ZNPP for the fourth time since the outbreak of war in Ukraine. During this visit, Grossi noted that since the five concrete principles for the protection of the plant were declared in May 2023, the facility had not been shelled. These principles, among other things, state that there should be no attack from or against the plant, and that the ZNPP should not be used as a storage or base for heavy weapons or military personnel.
But nevertheless, there are other dangers that the ZNPP faces: on eight occasions, the plant has been completely disconnected from an external power supply, and forced to use emergency diesel generators (most recently in December 2023). Also, after the destruction of the Kakhovka dam in June 2023, measures had to be taken to find alternatives sources of water for cooling reactors.
Grossi also stressed the importance of the IAEA experts having access to supervise implementation of the five concrete principles and seven indispensable pillars of nuclear safety and security, which the IAEA set out at the start of the conflict, and also being permitted to ask questions. “There were situations where there were suggestions that they look but not talk,” said Grossi.
Grossi and his team visited the turbine hall and the main control room of unit 4, which is the only one in hot shut-down state, and where the presence of experienced staff is especially important. In recent months, the IAEA experts have not had the opportunity to examine some parts of turbine halls.
Additionally, during his visit Grossi was satisfied that at present there is sufficient water for the plant’s own needs, but the measures taken will not satisfy the plant’s requirements if and when the NPP starts to produce electricity again. At present, to cool reactors in shutdown mode, water is taken from sprinkler ponds, which are supplied by 11 wells on the plant territory. Grossi also examined four new diesel steam generators, which will be used to process liquid waste. So far there is no information as to whether these generators will make it possible to put unit 4 into cold shutdown mode.
During Grossi’s visit to the plant, the General Director of Rosenergoatom Alexander Shutikov and his Deputy for Corporate Affairs Dzhumberi Tkebuchava were also present.
The meeting with the IAEA team headed by Grossi was attended by the General Director of the Rosenergoatom concern Alexander Shutikov (first on the left) and his Deputy for Corporate Affairs Dzhumberi Tkebuchava (second on the left). Photo: Zaporizhzhia NPPGrossi was informed of a detailed plant maintenance plan (in January the IAEA mission experts at the ZNPP were informed of this), and inspected the mine barriers installed at the plant (IAEA experts also made a report about them in January).
According to Grossi’s statement, the visit confirmed the crucial role of the permanent presence of the IAEA at the plant, and that the mission’s work would continue. “Until the conflict ends without a nuclear accident with radiological consequences, we will not be able to say that our job is complete,” he said. Following his visit to Kiev and the ZNPP, Grossi planned to hold meetings in Russia. Initially, a visit in mid-February was discussed, and then rescheduled for late February. Eventually the meeting with Russian president Vladimir Putin and Rosatom management took place on 6 March.
Grossi was accompanied on his visit to the plant by the 16th team of the IAEA Support and Assistance Mission in Zaporizhzhia (ISAMZ).
On 13 February, they visited the ZNPP training center, where they observed staff training, including operators of the main control room, undergoing additional training on simulators for other power units besides the ones they worked on. The team was informed that previously there were two types of licenses for main control room operators at the ZNPP: one type for units 1-4, and another for units 5 and 6 (the third stage of the plant). The IAEA experts were told that “authorizations” for operators would now be valid for all six reactor units.
On 14 February, the IAEA experts observed Rostekhnadzor, the Russian nuclear regulator, inspecting authorizations of the operating staff at the main control rooms of units 2, 3 and 4. They were informed that new rules had been introduced, stipulating that main control rooms of units in cold shutdown required at least three staff members, and units in hot shutdown required four. On 19 February, the IAEA experts had the opportunity to examine the regulatory authorizations of personnel in these units again. The group was informed that many of the operating staff were in the process of transitioning from the Ukrainian licenses to “authorizations” issued by Rostekhnadzor.
On 14 February, Russia reported explosions in Enerhodar after a drone strike. The IAEA experts visited the town on 15 February, where they were shown damaged buildings (plant representatives stated that there had been four drones). Two of the four sites mentioned in the reports were inspected – Enerhodar City Hall and a school garden. Traces of damages were visible, but the remains of drones were removed before their arrival, the team was informed.
At the end of the month, experts were informed that on 25 February another drone attack had taken place in Enerhodar, where the target was a roof with telecommunications equipment. The following day, the IAEA experts went to Enerhodar to examine the building, but they were only able to see it from the outside, and no signs of damages were visible at the time of the visit.
The team continues to report sounds of explosions and other signs of military activity in the area. Explosions can sometimes be heard close to the plant. Experts cannot properly determine the origin or direction of explosions, with the exception of a major explosion on 22 February, which according to ZNPP information was part of “field traning”. Separately, members of the mission were informed by ZNPP representatives that a mine had exploded outside the perimeter of the territory, without causing physical injuries or casualties.
On 28 February, an explosion was heard at some distance from the plant, followed by the sound of gunfire close to or on the site. Experts were informed that Russian troops had taken measures to “protect the plant” against drones in this area, but the ZNPP itself did not come under attack, and there were no damages or casualties. The IAEA experts requested access to the territory, but they were told that there were no damages that could be inspected, and that this territory was outside the plant’s control.
Grossi, commenting on these reports, said that reports from mission experts indicate possible military actions near the site and called on all sides to observe the five principles for protecting the plant.
At other nuclear plants in Ukraine, air raid signals are frequently heard. The staff at the Khmelnitskyi NPP has had to take shelter several times.
Yuri Chernichuk and Rafael Grossi with a map diagram of the Zaporizhzhia NPP. Photo: IAEAOn 20 February, the plant lost the connection to its last back-up external power line, the 330 kV Ferrosplavana-1 line. The only external powerline, the 750 kV Dneprovska line, remains in operation, which connects the ZNPP with the united energy system of Ukraine. On 22 February, the Permanent Mission of Ukraine at the IAEA informed the agency that damage took place on territory controlled by Ukraine 12 km from the open switchyard at the ZNPP as a result of artillery fire by Russian forces, and that it was impossible to carry out repair works because of continued shelling. The power line was not restored over the course of February.
During this time, the IAEA group visited the 750 kV electrical switchyard with the only connected line, and saw spare parts for the repair of the second line, but were told that there were no plans to carry out renovation work. They also observed tests of one of the emergency diesel generators of unit 4, which is in hot shutdown mode.
At the end of February, the experts were informed that all scheduled preventative maintenance activities on safety-related equipment had been suspended until the 330 kV powerline is reconnected, except for routine testing of the safety systems, including the emergency diesel generators.
Over the course of the month, experts of the IAEA mission continued to make walkdowns of the territory and plant rooms.
Information on walkdowns described in IAEA updates and information circulars by the Permanent Mission of the Russian Federation at the IAEA is given below:
28 January -2 February
Unit 1: safety systems rooms of the reactor department and the central hall.
Unit 3: turbine hall.
Six back-up diesel power plants and three shore pump stations were examined, and the SNF site.
7 February with Rafael Grossi
Sprinkler ponds.
4 diesel steam generators.
Unit 4: turbine hall, main control room.
4-9 February
Unit 2: turbine department, safety systems rooms of the reactor department, central hall, back-up diesel power facilities, unit pump station.
Special buildings 1 and 2, training demonstration center.
12-16 February
Training centre.
Unit 2: reactor hall, safety systems rooms, turbine hall, emergency diesel generators
(by the spent fuel pool cooling pump a lubricant oil leak took place, later the spill was cleaned up; a water leak was observed in another pump of the same safety system).
Experts were not given access to the western part of the turbine hall.
19-23 February
750 kV electrical switchyard (spare parts for the repair of a second of four 750 kV lines were seen, so far there are no plans to start repair works).
Units 1-6: main control rooms, safety parameters collected in units 2,3 and 4, regulatory authorizations of personnel examined.
Chemical laboratory and back-up diesel plant of unit 4 (observed tests on one emergency diesel generator).
26 February – 1 March
Hydroengineering structures, including cooling pond and sprinkler ponds, cooling towers, and the isolation gate of the discharge channel of the Zaporizhzhia Thermal Power Plant.
Experts were not given access to the isolation gate of the cooling pond (it was last examined in November 2023, they were also not given access in December 2023 and January 2024).
Two fresh fuel storage facilities.
Unit 5: safety systems rooms (routine testing of some safety system pumps was being carried out), reactor department, spent nuclear fuel pool.
Firstly, the lack of answers to the question as to what will be done with nuclear fuel in reactors operational life of which is expiring. At present, a decision on this problem has not been made public, which means that none has been taken. The issue is complex, as the decision must be passed in coordination with the nuclear fuel manufacturer, the scientific support group and the regulatory body. None of these structures can be from Russia, as the fuel is not of Russian manufacture, so it is unclear how decisions will be coordinated and passed on this very complex issue.
Secondly, it is unclear who will carry out works in the process of the announced technical maintenance. Technical maintenance is an important part of the operation of nuclear power units, which involves much more than just “dusting off” the surface of equipment, as all systems and mechanisms must be tuned, tested and checked.
Thirdly, there are ongoing “cat and mouse” games between the ZNPP management and the IAEA inspectors, who find they are not granted access to some sections of the plant, including turbine halls. If these games continue, this may only mean one thing – there is something to hide, which draws concern from all observers.
And finally, it is important to note the high-ranking Rosatom representatives who met with and accompanied Grossi at the ZNPP. It is unclear whether this was designed to make up for Likhachev’s absence, who in two years has never visited what he calls “a site of attention and responsibility [of Rosatom]”, or whether there was a need to reach an agreement on something that would not subsequently become known to the wider public, although this is unlikely, as there are more Ukrainian agents at the ZNPP than anywhere else in the occupied territories» International nuclear events and their connection with Russia Sanctions on the second anniversary of Russia’s invasion of Ukraine ↑
On 23 February, the USA levied sanctions against several dozen Russian companies. They mainly affected the mining and metallurgy sector and Russian LNG projects, but this is also the sixth set of sanctions against Russia that includes affiliated companies of Rosatom that support Russia’s development of the Arctic region, and also an enterprise of the Russian nuclear weapons complex:
– Rusatom Arctic – an affiliated company of Rosatom founded in December 2023 to assist Russia’s development of the Arctic region;
– Innovation Hub – performs the functions of business accelerator for Rosatom, including an investment portfolio, a project office and research and development center;
– The Alexandrov Research Institute of Technology – a key enterprise of the nuclear weapons complex, which plans, tests and supports nuclear power and sea power reactors, including for submarines.
Additionally, the SDN list was joined by Transcontainer, the country’s largest owner of containers and operator of fitting platforms (part of the Delo company group, in which Rosatom owns a 49% share package) and the Far Eastern shipping complex Zvezda, a company which builds up to 15 specialized LNG tankers designed to support export in the Arctic LNG-2 project, and also construction of the nuclear icebreaker of the 10510 Leader design.
Inclusion on the SDN list means not being able to use the dollar for settling accounts, and carries the risk of secondary sanctions for all counteragents.
New sanctions on 23 February were also announced by Canada. The list of sanctioned companies included the Russian Federal Nuclear Center – Zababakhin All-Russia Research Institute of Technical Physics (RFNC-VNIITF), which solves scientific problems connected with providing and maintaining the reliability and security of Russian nuclear weapons.
On 1 March, the Japanese government also introduced new restrictive measures for Russia. The list of companies facing economic sanctions included Atomflot, which owns the Russian fleet of nuclear icebreakers, and the United Shipbuilding corporation (which includes the Baltic Shipyard that builds nuclear icebreakers of the 22220 design).
Christophe de Margerie ice-class LNG carrier, designed for servicing the Yamal LNG project, accompanied by the icebreaker 50 Let Pobedy, 2021. Photo: AtomflotOn 23 February, the European Union introduced 13th package of restrictive measures against Russia, which did not affect the Russian nuclear industry. There are also no Rosatom companies in sanctions by the UK announced on 22 February, or by Australia, announced on 24 February.
So far global sanctions against Rosatom are not foreseen. In an interview with Reuters on 19 February, IAEA Director General Rafael Grossi noted that Europe still strongly depends on Rosatom, which supplies about 50% of the world’s enriched uranium, and that sanctions would cause an impasse in the nuclear industry in many countries. Meanwhile, on 28 February Rosatom General Director Alexey Likhachev reported that in 2023 the foreign turnover of Rosatom came to $16.4 billion (around 1.5 trillion rubles, which was more than half of Rosatom’s revenue for the year), more than $12 billion of which was on markets of “friendly countries”. In the same speech Likhachev also mentioned that Rosatom was developing models for non-nuclear weapons and military equipment. Some of them have already been put into mass production and are used in Ukraine. (Perhaps this means products manufactured by the consortium of Rosatom companies, most of which are included on the sanction lists of western countries).
Commentary by Bellona. Dmitry Gorchakov: «As we can see, sanctions still do not affect the main areas of foreign activity of Rosatom – construction of NPPs and deliveries in the nuclear fuel sphere. The main problems that affect these Rosatom projects are connected with general sanctions against Russia in financial and logistical spheres. Nevertheless, we can see that besides Rosatom structures connected with the nuclear weapons complex, sanctions are also being levied against structures connected with ship building (in particularly with icebreaker construction), and also with the Northern Sea Route.This policy may be justified if it pursues the goal of undermining plans for the economic development of the Arctic region of Russia, which focuses on increasing production and exporting resources (non-ferrous metals, LNG, oil etc.)» European Union doubled purchases of nuclear fuel from Russia in 2023 ↑
This is shown by data from the European statistics board and the UN service for international trade Comtrade, which was analyzed by Bellona. We have already published a detailed article about this on our website.
An analysis of transborder trade operations with the customs code 840130 (irradiated fuel assemblies or fuel elements) show a more than twofold increase of import to EU countries of fresh nuclear fuel in cash terms – from 280 million Euros in 2022 to 686 million Euros in 2023. In physical terms this means an increase of deliveries from 314 tons of nuclear fuel to 573 tons.
In the EU, only five countries purchase nuclear fuel for 19 reactors of Soviet design – VVER-440 or VVER-1000. They are the Czech Republic, Slovakia, Bulgaria, Hungary and Finland. These countries are most vulnerable and dependent on deliveries in the nuclear fuel sphere, despite the lack of sanctions and bans on these deliveries from Russia to Europe.
As we have described in our digests previously, practically all operators of NPPs in these countries signed contracts with new fuel suppliers after Russia invaded Ukraine in 2022. So current purchases may be connected with the need to fill storage facilities for the upcoming transitional period.
According to data, the Czech Republic more than doubled its import of fresh nuclear fuel from Russia in comparison with 2022 (from 90 to 199 tons), Slovakia almost tripled import (from 80 to 229 tons). Hungary increased purchase volumes in 2022 and maintained this level in 2023. At the same time, according to our assessments fuel supply reserves at the Dukovany NPP in the Czech Republic may now be sufficient for five years.
Bellona requested commentary from the NPPs operators of all five countries and the Euratom Supply Agency, and despite the lack of specific figures in their replies, we received confirmation that the plants are increasing supply reserves, and that in future years purchases will drop.
Commentary by Bellona. Dmitry Gorchakov: «From all appearances, the increase of import in 2022-2023 reflects the purchasers’ desire to receive volumes of contracted fuel earlier to ensure a reliable supply during the period of a change in suppliers, and possible difficulties with supplies if sanctions against the nuclear industry are toughened, or if there is some other worsening in relations between Russia and the EU.Rosatom itself may also profit from the increase in uranium purchases in the USA and fuel in Europe, as besides an increase in turnover this will help it to fulfill contracts before sanctions are applied or restrictions made by certain parties. However, this does not change the fact that strategically, the nuclear fuel market in the EU for Rosatom is practically closing down, along with the market of enriched uranium in the USA.
Given the current contracts for the change in suppliers, by 2030 deliveries of nuclear fuel to EU countries from Russia may drop by at least 60% to the level of 2022 – around 70-100 tons per year. Russia may lose purchasers for 10-15 power units in the EU with a capacity of 7 to 9 GW. Currently, only Hungary has no designated plans to change its fuel supplier, and given the development of the Paks II NPP project, this country will maintain close cooperation with Rosatom in the medium term» USA increases export of enriched uranium from Russia during discussion of new measures for its reduction ↑
Boris Schucht, Chief Executive Officer of Urenco, the major western supplier of enriched uranium, has announced that the company has sufficient capacities to replace Russian supplies on the US market if the law banning imports of Russian uranium is passed in the USA. The Biden administration initially did not support a ban on Russian nuclear fuel, as US NPPs strongly depended on Russian supplies. But now the government supports a ban after two years of accumulating supplies at power stations, and multi-million investments in the delivery chain of nuclear power from western companies, including Urenco, Orano in France and Centrus in the USA.
Urenco currently plans to expand all three of its enrichment facilities in the USA, the UK and the Netherlands. Schucht noted that the portfolio of Urenco’s orders has increased to $14 billion compared with $12 billion a year ago.
Nevertheless, during discussion of the law banning the import of enriched uranium from Russia, the import of enriched uranium from Russia to the USA grew in 2023 to a record level of $1.2 billion, 40% more than the import volume for 2022. With rising prices, import also increased in physical volumes by around 20%, from 588 tons in 2022 to 702 tons in 2023.
Volume of import of enriched uranium from Russia to the USA. Infographic by Bellona based on data from the Comtrade serviceSchucht also said that Urenco is holding talks with the governments of the UK and the USA on potential investments in new plants for production of high-assay low-enriched uranium (HALEU). In July last year, the UK government allocated Urenco £9.56 million for planning a plant and processes for HALEU manufacture at a site in Capenhurst in Cheshire, as part of the strategy to oust Russia from the world energy market. In January, the USA also announced a tender for the sum of $500 million from companies to provide enrichment services for producing HALEU.
HALEU is required for advanced nuclear reactors and will be used in small modular reactors (SMR). At present, the only commercial supplier of this uranium is the Rosatom-affiliated company Tenex. The lack of alternative suppliers causes problems for several US reactor projects. For example, in December 2022, TerraPower announced a delay in construction of a planned new reactor with a capacity of 345 megawatts in Wyoming, citing a lack of fuel.
Last year, Centrus launched a demonstrational enrichment cascade, and in November 2023 made the first delivery of 20 kg of HALEU to the US Department of Energy. The contract with the US government involves the production of 900 kg of HALEU in 2024, which will be stored at a storage facility built by Centrus in Piketon, Ohio. The Department of Energy is contractually required to provide storage cylinders, but in its annual report Centrus states that difficulties have arisen with deliveries of these specialized “5B Cylinders”, and the company now expects that it will be unable to deliver the planned volume of HALEU.
Until a commercial chain of HALEU deliveries is established, the US Department of Energy plans to dilute its supplies of HEU to provide a primary source of HALEU.
Urenco production site. Photo: Urenco Global Commentary by Bellona. Dmitry Gorchakov: «The measures taken in the West to reduce dependence on Russia in supplies of enriched uranium are not sufficient to put a swift end to cooperation with Rosatom. Even plans announced to expand facilities of European companies will at best help to reduce dependence on Russia for enrichment services by around 60% by 2030.Plans for independent development of HALEU are even vaguer. At the same time, the market reaction is observed in the increase of purchases of still-permitted products from Russia and creating supplies, similar to what is happening on the nuclear fuel market for VVER reactors in EU countries (see above)» Plans to build new NPP in Armenia ↑
In late January 2024, Rosatom head Aleksey Likhachev reported that the corporation was holding talks with several countries on building new nuclear power units. These include discussions on a third unit in Belarus, and for another four-unit plant in Turkey. Likhachev also said that over the next one-and-a-half to two years, Armenia should also settle on a format for developing nuclear power in the future.
The resource of unit two of the Metsamor NPP currently operating in Armenia with a capacity of 430-440 MW has been extended to 2026, and work is underway for further prolongation by another 10 years. In 2021, the Armenian government discussed the fact that from 2026-2027 it would be necessary to start building a new NPP, so that when the present plant reaches the end of its service life a new plant can begin operating. Besides Russia, proposals from other countries are also being examined, the government stated.
In January 2022, Russia and Armenia signed a memorandum of cooperation for building new nuclear power units, where they expressed readiness for cooperation in building new nuclear power units of Russian design on the site of the Armenian NPP. There was also discussion of the possibility of building a small-capacity NPP of Russian design.
Later that year, in May 2022, the USA and Armenia also signed a memorandum on cooperation in the nuclear power sphere.
In June 2022, the press-service of the Armenian NPP announced that specialists from Armenia and Russia had begun to discuss the future project for a new nuclear power unit in Armenia. In particular, the option for a VVER power unit of 1000-1300 MW is under examination.
In May 2023, Armenian Prime Minister Nikol Pashinyan reported that Armenia showed an interest in US technologies of small modular reactors. In the same month, Maria Longi, coordinator of US assistance to Europe and Eurasia at the US Department of State, announced at hearings in Congress that in a number of countries, including Armenia, the US was assessing the possibility of building small modular nuclear reactors which could lead to greater energy independence both from Russia and from China.
In June 2023, South Korea and France joined the list of potential candidates for building the NPP. In autumn, it was reported that the governmental commission in Armenia was intensively studying three options for building a new nuclear plant – a Russian plant, the feasibility study of which were submitted to Armenia in February 2023, while the feasibility studies of US and South Korean proposals were also being studied (at that time the French were still only holding negotiations). Armenia’s Deputy Minister for Territorial Administration and Infrastructure Akop Vardanyan noted that in the project proposed by Russia, the capacity of 1200 MW was a problem, as this is too high for Armenia’s small energy system. When asked whether a unit of smaller power could be ordered from Russia, for example of 600 MW, Vardanyan replied that this project would be very expensive, perhaps no cheaper than the 1200 MW unit (which Rosatom General Director Aleksey Likhachev also pointed out).
The American proposal features small modular reactors of 77 MW – 6 units of 462 MW in total, or 300 MW versions of pressurized water reactors or boiling water reactors (some of these reactors have yet to receive licenses). In South Korea there are two versions for reactors – 1000 MW and 1400 MW, and also small modular versions which are at the licensing stage.
In January 2024, in a discussion of the procedure for analysis and further steps to build the new nuclear power unit in Armenia, installing small modular reactors, and also selecting necessary technologies, Pashinyan stated that while he was not aware of all the professional details, he considered the option of modular reactors politically interesting.
On 7 February, the Armenian information and analytical center VERELQ published an interview with Igor Yushkov, leading analyst at the National Energy Security Fund and an expert at the Financial University under the Government of the Russian Federation. In his opinion, if Armenia decides to give its preference to the US option to build the new reactor, this will be perceived as a blow to Russian interests, and will be interpreted as a political gesture. In the Russian media space and political circles, this step will be seen as a turning point in Armenian foreign policy.
Commentary by Bellona. Alexander Nikitin: «It is highly likely that the country selected to build the new Armenian NPP will be a political decision, and at present Russia’s chances are not high.One may only imagine how Russian interests will be protected, which Russian government experts are currently discussing. Evidently, here political pressure will be used (perhaps even with the option of attempting to cause a regime change in Armenia, which will come as no great surprise to anyone), or economic pressure (funding and perhaps the offer of a complete or partial “Build-Own-Operate” format). In the latter case, not only financial support will be offered, but the possibility of sending SNF or radioactive waste back to Russia, which for Armenia, with its earthquake-prone territory, may be a very attractive offer» Urenco continues cooperation with Russia ↑
On 13 February, the Authority for Nuclear Safety and Radiation Protection of the Netherlands (ANVS) issued three permits for transportation of enriched uranium hexafluoride from Russia (Siberian Chemical Combine in Seversk, trading under the brand JSC TENEX), intended for Urenco Nederland B.V. in Almelo. The permits are valid until 13 February 2027 and allow for six deliveries in the validity period. One permit is for 120 small uranium samples, one is for 24 empty uranium containers and one is for 24 containers filled with fissile enriched uranium.
Diagram for processing reprocessed uranium from the presentation by the Director of the Nuclear Fuel Division of EDF, March 2022. Source: HCTISNThis came to the attention of the Laka Center for documentation and research of nuclear energy in the Netherlands. One aspect that has sparked indignation among a number of NPOs is that in 2022 Urenco reported that several days after Russia’s invasion of Ukraine, it took the strategic decision to annul contracts with Russian suppliers immediately. The Urenco press-secretary explained that here fulfillment of work for Électricité de France SA (EDF) was involved. The route for uranium from France passes through Russia, as it must be converted to uranium hexafluoride before Urenco can process it. According to company representatives, as there are no sanctions against deliveries of uranium from Russia, Urenco cannot back out of the existing contract.
The work here concerns the processing of French spent nuclear fuel. In 2018, Tenex and Électricité de France (EDF) signed a long-term contract valued at $1 billion for comprehensive services for conversion and enrichment of reprocessed EDF uranium, and also technical maintenance of packaging containers for this material. The term of the contract was from 2022-2032. After conversion at the plant in Seversk, part of the uranium will be sent to Urenco for enrichment. The fuel assemblies will be produced at the Framatome plant in Romans-sur-Isère.
On 5 February, unit 2 of the Cruas-Meysse NPP in southeast France was relaunched with a first full core of processed uranium fuel. The EDF aims to use reprocessed uranium (RepU) in several reactors with a capacity of 1300 MW by 2027, to reach a level of over 30% of RepU used in French nuclear reactors by 2030.
The Cruas-Meysse NPP. Photo: Etienne Baudon Commentary by Bellona, Dmitry Gorchakov: «The present situation of the continuing cooperation of Urenco and EDF with Rosatom shows the deep historical mutual dependence between major nuclear companies.On the one hand, this shows that for the nuclear sector as a whole, ending this cooperation is unprofitable and may lead to serious losses. Establishing new delivery chains may require time and investments, and a drastic unilateral annulment of contracts may lead to lawsuits. So without political will and pressure from civil society in western countries, these ties will not end of their own accord or be reduced.
On the other hand, all of this shows the importance of transparent and open relations in the nuclear sector, including in western countries» Events in the Russian nuclear industry and in Rosatom projects abroad Rosatom’s mining division reports on overfulfilling the plan for uranium production in 2023. But the figures raise questions ↑
On 19 January, in preparing Rosatom’s public report for 2023, the Executive Director of Atomredmetzoloto Viktor Svyatetsky reported that in 2023, Rosatom’s Mining Division had fulfilled the plan for uranium production by 103%, exceeding the division’s planned figure by 90 tons.
According to these figures, the production plan came to 3000 tons, and the total volume of production in 2023 came to 3090 tons, which exceeds production for the previous year by almost 600 tons.
At the same time, in recent years uranium production in Russia by Atomredmetzoloto has been dropping steadily. The company’s 2022 annual report states that production in the previous year came to 2508 tons, which is 127 tons lower than production for 2021 and 338 tons lower than production for 2020.
According to Svyatetsky, these high figures were achieved thanks to investments in production and use of new technologies. One example is the Priargunsky Mining and Chemical Production Association, where despite a decrease in uranium content in ore mined in existing fields, there was an increase in the volumes of processing low-grade ores by the heap leaching method.
Historical figures for uranium production in Russia (blue) and data for 2023 (yellow), based on the figures published by Atomredmetzoloto. Infographic by Bellona Commentary by Bellona. Dmitry Gorchakov: «According to the figures announced by the management of Atomredmetzoloto on overfulfilling the plan for uranium production, production in 2023 came to over 3000 tons, which considerably exceeds the level of production in recent years. No significant expansions of productions or even plans for this expansion were observed over the previous year. Otherwise, at the press conference it would have been more logical to announce a more impressive figure on exceeding production by almost 600 tons compared to last year, than merely overfulfilling the plan by 90 tons. So it is unlikely that the figures given correspond to reality.The practice of concealing real figures with tall tales of overfulfilled plans when annual figures actually drop is becoming typical for Rosatom’s affiliated structures. We have already observed the same phenomenon this year, concerning electricity generation at Russian NPPs. The real generation indicators in 2023 dropped compared to 2022, but Rosatom has not yet announced them, and instead states that the plan has been overfulfilled.
The main volume of uranium production by Rosatom’s affiliated companies comes from outside Russia – from Kazakhstan, through the joint enterprises Uranium One (an affiliated company of Rosatom) and NAK Kazatomprom. Rosatom’s uranium production in Kazakhstan is approximately double the amount of uranium production within Russia» Priargunsky Mining and Chemical Production Association, Krasnokamensk, Zabaykalsky Krai. Photo: Rosatom Disputes over legal disputes concerning Hanhikivi NPP in Finland ↑
On 26 February, Rosatom head Aleksey Likhachev announced that after the first stage of hearings at a Court of Arbitration in Paris, the actions taken by Finland in the project of the Hanhikivi NPP were ruled to be unfounded and politically motivated. According to Likhachev said, subsequent legal proceedings will specify the material damages involved.
The following day, the General Director of Fennovoima Matti Suurnäkki reported that Fennovoima was not involved in any arbitration proceedings in Paris. He said that the dispute between Fennovoima and Rosatom would be examined at the arbitration court of the International Chamber of Commerce in Stockholm, that the procedure was in the initial stage, and no decisions on this issue had yet been passed.
Fennovoima annulled the contract for construction of the Hanikivi-1 NPP with Rosatom in April 2022, two months after Russia invaded Ukraine. However, Fennovoima states that the contract was annulled not because of the war but owing to Rosatom’s own problems and a number of delays in the project (the contract for building and supplying the NPP was signed in 2013). Rosatom believes that this was just a pretext, and that the true reason was political.
The construction site of the Hanhikivi NPP, February 2022. Photo: FennovoimaSubsequently, both Fennovoima and Rosatom initiated legal proceedings against one another. In August 2022, Fennovoiuma demanded that Rosatom pay a debt of almost 2 billion Euros. Rosatom filed lawsuits for a total sum amounting to around 3 billion Euros.
In December 2022, Rosatom announced that the Dispute Review Board (DRB) had confirmed the illegality of Fennovoima’s actions on annulling the contract, and stated that Rosatom had the right to demand compensation for losses incurred.
Fennovoima had a completely opposite interpretation of the DRB’s ruling, saying that the board had found that Fennovoima essentially had the right to annul the contract, given the delays in the project, but that the board could not take a position on whether Fennovoima or Rosatom were to blame for these delays. Fennovoima believes that the DRB even supported Fennovoima’s demands for compensation on many points.
Commentary by Bellona. Alexander Nikitin: «After all of the military operations in which Rosatom has played an active part, no European courts, let alone boards and chambers of commerce, will take the side of a corporation that collaborates with an aggressor whose policies have done enormous damage to companies and entire countries. Therefore, the legal proceedings that Likhachev mentions may continue, but the result here seems predictable – Rosatom will receive nothing in compensation» Rosatom’s projects abroad in brief ↑On 8 February, Akkuyu Nuclear reported that in the reactor compartment of unit 1 of the Akkuyu NPP, a “clean area” had been organized – a workspace to carry out controlled assembly of a reactor (installation of equipment components into the design position, loading a dummy core before switching between cold and hot shutdown modes of the reactor plant).
Several days later, on 12 February, Rosatom head Alexey Likhachev and Turkish Minister of Energy and Natural Resources Alparslan Bayraktar held a working meeting (details of the meeting are not reported) and visited the NPP construction site. Before Likhachev’s visit, a stator generator was installed in the turbine hall of unit 1 – the heaviest piece of equipment in the unit. The stator, like most of the main turbine equipment of all units of the Akkuyu NPP, was manufactured in France.
On 28 February, at a speech in the State Duma, commenting on Rosatom’s projects abroad, Likhachev stated that Turkish president Recep Erdoğan had publicly announced that a political decision had been made to allocate another site to Rosatom, in all likelihood the Sinop site.
“Talks are now underway in the format of Rosatom and the Turkish Energy Ministry, and the technical appearance, control system and economic parameters of the project are under discussion. In Rosatom’s understanding, it will be possible to build a plant at the Sinop site similar to the Akkuyu plant, with the same kind of reactors. So far, issues for managing the financing of the project have not yet been decided. The Turkish government is generally satisfied with the construction process of the Akkuyu NPP, which gives prospects for expanding cooperation in this sphere,” Likhachev said.
An unnamed representative of the Turkish Energy Ministry, commenting on Likhachev’s statements to the TASS news agency, said: “At the present stage we cannot provide any specific information. Yes, talks on this matter are continuing, they have not been completed. This is a long process, and it has been going on for some time. There is still no information about any final decisions.”
At the Energy and Climate Forum held on 7 March in Istanbul, Turkish Energy Minister Alparslan Bayraktar said: “As far as construction of the second NPP in Sinop is concerned, there are two interested countries. They are Russia and South Korea. And of course, for Sinop we are paying attention to Russia and Rosatom. We already have serious work experience at the Akkuyu NPP site, so we wish to apply it to the Sinop site as well. Our talks are continuing with both parties.”
On 7-8 February, Likhachev also visited the Kudankulam NPP in India, and in a meeting with the Head of the Indian Department for Atomic Energy Ajit Kumar Mohanty, discussed options and resources for accelerating the ongoing construction of units 3-6. Both delegations also discussed strengthening ties in other spheres of civil nuclear cooperation. On 8 February 2024, Mohanty and Likhachev signed an addendum to the intergovernmental agreement of 2008. In December last year, the Indian External Affairs Minister Subrahmanyam Jaishankar and Russian Deputy Prime Minister Denis Manturov signed three agreements at a meeting in Moscow concerning Kudankulam. However, their content has not been made public.
Aleksey Likhachev at the Akkuyu NPP on 12 February. Photo: Rosatom Commentary by Bellona. Alexander Nikitin: «Turkey and India remain “quiet”, but not completely faithful (like Belarus for example) allies of Russia, as they are very strongly connected with the West economically and politically. On the other hand, the considerably successful construction in these countries of Rosatom’s first NPPs increase the probability of new agreements being signed. In all likelihood, the situation will once more depend largely on the domestic policy of these countries, and geopolitics in general.Turkey’s economy is not in the best position, so it needs economically attractive projects, like the construction of the Akkuyu NPP. At the same time, Erdoğan is in his last presidential term and is now trying to observe a balance in relations between the West and Russia, i.e. to find and take advantages for himself from both sides (for example the case of Sweden’s acceptance into NATO).
Putin is far more dependent on Erdoğan than Erdoğan is on Putin, as Azerbaijan is an unconditional ally of Turkey, and Syria and the Kurds are no friends of Erdoğan. So the Bosphorus may be closed off at any time, turning the Black Sea and Azov Seas into big lakes for Russia, and Likhachev’s dreams may be dashed overnight.
There is no such political and geographic interconnection with India, but there is also no absolute certainty, as India has its own relationship with the West and its own elections approaching. In other words, not everything is so simple and straightforward in Rosatom’s plans in Turkey and India, so we will continue to monitor and comment on the situation surrounding these projects» Commentary by Bellona. Dmitry Gorchakov: «With the increasing number of visits by high-ranking Russian officials to India recently and constant reports of new agreements signed, but without the details been made public, one gets the impression that one or both sides are not very happy with the progress of the ongoing construction of the NPP of Russian design in India.
Objectively, this may be shown by the constant delays in construction, which we keep track of in our digests. So the frequency of these talks which do not lead to announcements on expanding cooperation or opening new construction sites may show that they are going through a difficult stage.
It is telling that in his recent speech at the “governmental hour” at the State Duma (see below), Rosatom head Alexey Likhachev slightly embellished both the prospects of transferring the Sinop NPP in Turkey to Rosatom, and the course of court proceedings concerning the Hanhikivi NPP in Finland. The official representatives of these countries commented on both situations in a more moderate tone, which may even cast doubt on Likhachev’s interpretation of events. Thus, it is clear that in his public statements, especially within the country, Likhachev tries to portray things in the most positive light for himself and Rosatom, sometimes misleading the public» Separate extended commentary on a significant event of the month Rosatom’s “government hour” at the Russian State Duma ↑
On 28 February, a “government hour” was held at the Russian State Duma with Rosatom General Director Alexey Likhachev and a number of his deputies. Bellona provides a brief survey of this event in the form of an extended commentary by the Head of Bellona’s Nuclear Project Alexander Nikitin:
«Rosatom was the first Russian state corporation to be invited to a meeting as part of the “government hour” by the Russian State Duma since its election in September 2021. It is notable that although by law (No. 317 FZ of 01.12.2007) the state corporation Rosatom is not a structure of the Russian government and its head is not a member of government, and State Duma regulations (article 41) state that only the Chairman of the government and members of government are invited to the “government hour” to answer questions from deputies.Thus, the exception that the Duma made on 28 February 2024 by inviting Rosatom may mean that the corporation’s status has now risen to at least the level of a ministry or even higher, given how close Rosatom is to the Russian president and his administration.
Judging from the atmosphere at the meeting, each of the parties had their own agendas to follow at the event. Rosatom is not just about energy, it is also about nuclear weapons, so deputies on the same “wavelength” as Putin, who has recently speculated on the possibility of using nuclear weapons, were unsparing in their flattery, praise, encouragement and promises of all kinds of assistance to the department that manufactures nuclear bombs.
Rosatom, in its turn, is interested in an increase in budget financing to build new NPPs and to strengthen its business which is inexorably expanding within the country, and according to Likhachev now numbers over 460 companies working in 100 different fields. As was made clear, Rosatom today on the one hand is the main distributor of budget funds for many state programs, and on the other is a multifaceted business holding, holding assets in many different sectors of the economy.
Rosatom is a participant and user of funds in many federal and state programs. According to the Head of the Auditing Chamber, 70% of all budget funds are spent and managed by Rosatom as part of the state program “Development of the nuclear energy and industry complex”. This program completely finances the construction of nuclear icebreakers and creation of infrastructure for treating waste of hazard classes 1 and 2 (non-radioactive). The program “Scientific and technological development” accounts for 25% of budget funds which Rosatom receives and distributes. The bulk of NPP construction abroad and several other Rosatom businesses are also financed from the budget.
Just in case, Likhachev first reminded deputies that “the main service [of Rosatom] and its first mission… is the state defense order, which is annually fulfilled by 100%, despite huge growth in a number of sectors.” He also emphasized that “in future the volumes [of the defense order] would increase”.
Likhachev went on to discuss Rosatom’s great success, and continued in a “peacetime” spirit, i.e. as if the war did not exist. Practically the only mention of the war that is now in its third year was connected to a question from a deputy concerning the ZNPP.
In his reply to a question about the “well-being” of the ZNPP and the town of Enerhodar, Likhachev said practically nothing worthy of attention. He only stressed that the ZNPP was “our individual duty and responsibility”. Additionally, he distorted facts, saying that there had been shelling of the SNF facility, and that the physical protection of the plant (if this means the fence around the ZNPP site) had been destroyed by the Ukrainian armed forces. In summer-autumn 2022 there was indeed shelling near this area, but the site itself was not hit.
The IAEA have drawn attention to problems of shortages and low qualification of staff at the ZNPP. Likhachev essentially confirmed the IAEA’s concern, saying that only 4,700 people at the plant had signed a contract with Rosatom, and that several hundred more people had been sent to the ZNPP from other plants. Thus, Likhachev admitted that the staff shortage at the NPP is now around 50%, if one bears in mind that before the occupation around 11,000 people were employed at the ZNPP
It is also noteworthy that Rosenergoatom has plans for activity on this site until 2026, which may mean that it does not intend to leave the ZNPP. Likhachev confirmed Rosatom’s active involvement in the occupation and the active development of captured territories. He reported that Rosatom “had embarked on activity on sites in new regions – the industrial waste ground in the Luhansk People’s Republic and Gorlovka, the Gorlovsky chemical plant in the Donetsk People’s Republic.”
It is interesting that Likhachev failed to discuss the approach to the issue of capital expenses for building NPPs, the lengthy duration of construction and how these factors affect the rates of nuclear-generated electricity for the population. This is a separate topic that deserves analysis and detailed coverage, but it is noteworthy that according to Likhachev, a government decision is being prepared to limit maximum capital expenses on construction of new nuclear units which Rosatom plans to build in Russia, and expenses that exceed established norms will be compensated for by Rosatom at its own expense.
Likhachev confirmed that Rosatom intended to bring nuclear power generation to 25% in the energy balance by 2045, building 42 power units of high, medium and small capacity, increasing generation in the Urals, in Siberia and the Far East. Additionally, he said, it is planned to operate Russian NPPs for up to 60 years, with possible extension to 100 years.
At the parliamentary hour, there were much talk and numerous promises about fourth generation technology, i.e. the construction of the Brest Pilot and Demonstration Power Complex, and the prospects in this field. Such categoricalness and unquestioning certainty of success is somewhat disconcerting, along with the claim to be 10 or more years ahead of the competition. Even Russian nuclear experts have serious doubts about this project. Additionally, the long and torturous experience of operating shipboard nuclear liquid-metal plants, which the navy was eventually forced to abandon, shows that everything is not so straightforward, simple and clear.
The “Breakthrough” project under which the Brest reactor is being built has been continuing for 16 years. The physical launch of the BREST-OD-300 reactor is scheduled for 2026, so the “celebration” is not far off.
Without a trace of doubt, Likhachev announced that Rostom’s position on international markets was solid and promising. He stated that in 2023 Rosatom “had a record $16.4 billion in revenue in foreign markets, more than $12 billion of which was generated on the markets of friendly countries.” The only unanswered question today is how long these countries will remain “friendly” under changing geopolitical conditions, since the market is not really about “friendship,” but primarily about politics, economics, ecology, and other components that can change unexpectedly and swiftly, while affecting the market.
Rosatom is actively involved in non-nuclear processes related to achieving Russia’s so-called technological sovereignty, as Likhachev constantly emphasized in his report, while deputies discussed Rosatom’s global technological leadership. For example, there was discussion about Rosatom’s success in digitalization, and that Russia’s wind power industry is developing rapidly only thanks to Rosatom (without mentioning the fact that today Russia is barely approaching 1% of solar and wind generation).
The deputies praised Rosatom for its unique Atom electric car (without even comparing it to Chinese products), and for record cargo transportation through the Northern Sea Route (NSR), noting that in 2023 it was as much as 34 million tons (for comparison, more than a billion tons of cargo are transported through the Suez Canal, which the NSR is trying to compete with).
Likhachev again proudly reported on the world’s only floating nuclear power plant (of course, without explaining that the main equipment already required for it is taken from scuttled military vessels) and lamented that the limiting factor for the construction of floating nuclear power plants is Russian shipbuilding, which is not fast enough in manufacturing hulls, so they have to be ordered from China.
All the figures and results discussed in parliament can be considered as separate domestic results, or perhaps even achievements. But it is impossible to assess them objectively after listening to the report, because there were no comparisons with worldwide achievements in developed countries and companies. It seemed that for some reason the parliamentarians were not even interested in comparisons with others. There were simply statements by Likhachev and deputies to the effect that we are the best and the first, and an atmosphere of euphoria and jubilation caused by everything that Rosatom does.
Lastly, there was no mention of such important and costly problems as the environmental safety of the nuclear industry, including the elimination of the Soviet nuclear legacy, nor was there any explanation of when and with what funds the eighteen NPPs that have reached the end of their service life will be decommissioned over the next decade (today only four are in the process of being decommissioned). In addition, it will be interesting to see how 42 new NPP units will be built over the next twenty years at a rate with a restricted maximum sum of capital expenditures» Recommended publications ↑
On 25 February, Novaya Gazeta published the article (subsequently posted on the Bellona website) by Bellona’s nuclear project expert Dmitry Gorchakov, “Rosatom loses domestic energy”, analyzing the causes of a decrease in generation of Russia’s NPPs in 2023 for the first time in 10 years.
The article describes both the accumulated causes in Russia’s aging nuclear reactors, and how operational problems at three NPPs in 2023 caused generation to fall below the expected result. In addition, three important consequences of this situation are described, which threatens the implementation of Rosatom’s goals of increasing the share of nuclear energy to 25% by 2045.
Firstly, Rosatom intends to extend the service life of old RBMK reactors for an additional five years. Secondly, in the coming years Rosatom will increasingly be occupied with building new nuclear units inside the country, reducing foreign activity. And thirdly, problems with Russian equipment, especially turbines, force Rosatom to rely on foreign deliveries, primarily from France, in their foreign projects. This cooperation increases the competitive ability of Rosatom’s proposals, but at the same time means a certain dependency on the West.
On February 28, Bellona held a forum in Oslo on the topic “War and the Russian Nuclear Industry.” Experts from the Bellona nuclear project spoke at the forum about the history of the organization’s activities in Russia, the closure of Russian offices after February 24, 2022, reformatting and new goals and objectives of the Bellona nuclear project. A detailed description of the event and video recordings of performances are available on Bellona’s website and YouTube channel.
The post Bellona nuclear digest. February 2024 appeared first on Bellona.org.
Stand Up Against Corporate Fraud: Support Stronger Auditing Standards!
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Stop the Big Utility Tax Coalition statement on California PUC’s monthly fee proposal
CALIFORNIA— The California Public Utilities Commission, CPUC, issued a proposed decision yesterday outlining a new structure for utility bills, which would include a $24 monthly fee for most PG&E, SCE and SDG&E customers.
According to an analysis by opponents of the plan, a $24 monthly fee would result in overall utility bills going up for millions of families who live in smaller homes and apartments, or who take steps to reduce their energy use. The bottom line is, under this proposal, utility bills would significantly increase for millions of working- and middle-class consumers.
The Stop the Big Utility Tax Coalition released the following statement, attributable to Bill Allayaud, director of California government affairs for the Environmental Working Group:
The CPUC’s proposal is exactly what Californians should be worried about — a big utility tax that is twice the national average and totally uncapped. We all note many references to this only being the “first step” towards many other fixed charge increases in the near future.
Simply put, it is a blank check to profitable utilities that gives them a guaranteed revenue stream for the costly projects that drive expensive electricity rates. Consumers by contrast will now have two ways for their bills to go up, through a monthly charge that is expected to increase over time along with constantly rising energy rates.
This proposal is precisely what utilities have been lobbying for, with consumers left holding the bag. The only firewall between consumers and utility exploitation is the passage of A.B. 1999 (Irwin), which would impose much-needed caps on these unchecked and outrageous taxes.
About the coalition
Across California, more than 240 community organizations and leaders are joining together in the Stop the Big Utility Tax coalition to fight a proposal that would hike electricity bills for millions of working- and middle-class families in the state.
Areas of Focus Energy Utilities Federal & State Energy Policy Renewable Energy California Disqus Comments Press Contact Alex Formuzis alex@ewg.org (202) 667-6982 March 28, 2024Are Concerts and Festivals Harmful to the Environment?
2023 was a big year for concert tours and music festivals. Artists like Taylor Swift, Beyoncé, and Drake had sold-out tours. They brought in an estimated $9.17 billion in ticket […]
The post Are Concerts and Festivals Harmful to the Environment? first appeared on Dogwood Alliance.California lawmakers introduce bills to protect children from lead exposure
SACRAMENTO, Calif. – Two bills introduced this legislative session aim to safeguard children’s health from the lasting and devastating effects of lead exposure through drinking water, an urgent threat in the state.
Assembly Bill 1851, by Assemblymember Chris Holden (D-Pasadena), would set up a state-funded pilot program to test for lead in drinking water in up to 10 school districts with plumbing installed before January 1, 2010. The Environmental Working Group and Children Now are co-sponsoring the bill. On March 19, it passed out of the Assembly Environmental Safety and Toxic Materials Committee.
Assembly Bill 2671, by Assemblymember Dr. Akilah Weber (D-La Mesa), would protect babies, toddlers and children by ensuring lead-free drinking water at family care homes. EWG and California Public Interest Research Group, or CALPIRG, are co-sponsoring the bill. It was referred to two committees on March 4.
Lead is a potent neurotoxin that can permanently harm children’s intellectual development and affect their behavior and ability to concentrate. Even in tiny amounts, it can lower a child’s IQ, slow growth and harm hearing. Studies show lead’s harm cannot be reversed. There is no safe level of exposure to lead.
Together, the two bills would create important new protections to shield children from the damaging effects of lead in drinking water.
Require lead tests in some school districts
The goal of Holden’s bill is to lower lead levels to zero. If enacted, it would help identify and clean up any faucets on campuses with potable water that release lead above 5 parts per billion, or ppb.
“Lead consumption among youth and disenfranchised communities occurs at a higher rate. Assisting schools with the resources and appropriate standards to ensure the water our children drink is safe will help us protect our schools, students and communities,” said Holden.
“Children do not become more resistant to lead’s toxic effects once they transition from day care to kindergarten, so California should take the responsible step of aligning child care and school lead testing standards,” he added.
Holden has long championed drinking water safety. He authored a law in 2018 requiring licensed child care centers in the state to test their tap water for lead contamination.
The results of those tests, released last year, revealed alarming levels of lead. The drinking water in nearly 1,700 licensed child care centers statewide – one in four – topped 5 ppb, the allowable threshold in California.
Over 260 centers found levels between 50 and 1,000 ppb – 50 to 200 times the limit. One center found levels as high as 11,300 ppb. That’s 2,200 times the amount of lead California allows in child care center drinking water.
Because of the lifelong serious health harms linked to childhood lead exposure, the American Academy of Pediatrics recommends lead in drinking water not exceed 1 ppb.
"Even in minuscule amounts, lead can irreversibly damage young minds and bodies, leading to developmental delays, cognitive disorders and lifelong health complications,” said Susan Little, EWG senior advocate for California government affairs.
“We must act swiftly to protect our children from the devastating effects of lead exposure, which can rob them of their potential and inflict a lifetime of suffering,” she said. “Lead is not just a neurotoxin; it's a ticking time bomb that threatens our kids' health and well-being.”
“Lead exposure is a health, education and racial justice issue for our kids,” said Ted Lempert, president of Children Now, a statewide children’s advocacy organization. “We thank Assemblymember Holden for authoring this legislation to protect students from lead in drinking water, and we are pleased to partner with EWG to co-sponsor the bill.
“Children Now is committed to ensuring that schools have the support and resources they need to keep kids safe,” said Lempert.
Licensed child care centers must use water filters
Weber’s bill responds in part to the alarming results of drinking water tests at the state’s licensed child care centers. If enacted, it would require the installation of lead-removing water filters at the 28,000 family care homes where tests were not conducted.
“We know that lead exposure is linked to slowed growth and development of children, and that it damages the brain and nervous system,” said Weber. “Children are some of the most vulnerable residents in our state, and we cannot continue to allow them to be unintentionally poisoned in the same facilities where they are cared for.”
Drinking water is a significant source of exposure to lead. According to the Environmental Protection Agency, the most common sources of lead in water are lead pipes, faucets and fixtures.
“Parents expect their kid’s child care facilities to be safe – not to come with a daily dose of lead-tainted water,” said Jenn Engstrom, CALPIRG state director. “Rather than wait for more testing to show that our kids have been drinking lead, we should be doing everything we can now to get the lead out. That means starting with filters first.”
With the introduction of these two bills, the Golden State’s elected leaders continue to sound the alarm about the threat of childhood lead exposure and the urgent need to safeguard Californians’ health.
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The Environmental Working Group is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action. Visit www.ewg.org for more information.
CALPIRG, the California Public Interest Research Group, is a statewide nonprofit organization that works to protect public health and consumers. Learn more at https://calpirg.org/
Children Now is a non-partisan, whole-child research, policy development and advocacy organization dedicated to promoting children’s health, education and well-being in California. The organization also leads the Children’s Movement of California, a network of over 4,800 direct service, parent, youth, civil rights, faith-based and community groups dedicated to improving children’s well-being. Learn more at https://www.childrennow.org
Areas of Focus Family Health Toxic Chemicals Lead Disqus Comments Press Contact Aimee Dewing aimee.dewing@ewg.org (818) 216-2639 March 28, 2024National conservation groups respond to BLM methane waste rule, support action to limit waste of taxpayer-owned oil, gas
In response to the Biden administration releasing its final U.S. Bureau of Land Management (BLM) methane waste rule, the Western Environmental Law Center, Environmental Defense Fund, The Wilderness Society, Earthjustice, and Western Organization of Resource Councils released the following statements today.
The final rules released today take steps to reduce waste from routine venting and flaring of gas at well sites.
According to the Biden administration, oil and gas operators vented or flared approximately 150 billion cubic feet of methane in 2019 — or about $400 million of natural gas on federal and Tribal lands. That is enough natural gas to meet the needs of 2.1 million households, which is nearly as many households as in the states of New Mexico, North Dakota, Utah, and Wyoming combined. If that gas were captured, it could generate tens of millions of dollars in revenue for states and tribes to fund education, infrastructure, and health services.
“Eliminating waste from routine venting and flaring of associated gas conserves domestic energy resources, ensures taxpayers benefit from the development of publicly-owned minerals, lessens oil and gas production’s negative impact on the climate, and protects the health of frontline communities,” said Erik Schlenker-Goodrich, executive director of the Western Environmental Law Center. “The health risks increase the closer people live, work, and go to school near oil and gas facilities – it’s crucial federal agencies move forward on strong implementation and enforcement of these new rules.”
“Strong Interior Department methane waste rules are integral for the United States to protect taxpayers from wasted energy resources,” said Jon Goldstein, Senior Director of Regulatory and Legislative Affairs, EDF. “Taking action to limit methane waste on public lands offers a win-win-win for taxpayers, producers and communities harmed by this waste and associated pollution.”
The waste of natural gas through venting and flaring on federal and Tribal lands has been a persistent problem for decades.
“Methane from oil and gas development on public lands harms communities, invaluable natural resources, and the climate,” said Ben Tettlebaum, Director and Senior Staff Attorney at The Wilderness Society. “This rule takes steps to reduce methane waste from venting and flaring, which not only makes good economic sense, but also has conservation and climate benefits.”
“When oil and gas operators leak, vent or flare methane, taxpayers and communities suffer,” said Robin Cooley, Deputy Managing Attorney, Rocky Mountain Office, Earthjustice. “BLM has a critical role to play in reducing oil and gas waste. Along with EPA’s new rules to control methane pollution, it is vital for these federal agencies to swiftly implement and enforce rules to protect all Americans.”
Venting and flaring emit not only methane but also harmful pollutants including ozone- or smog-forming volatile organic compounds (VOCs) and hazardous pollutants that have serious public health impacts on communities living in basins with oil and gas production or in proximity to federally-owned or Tribal minerals.
The impact of wasted methane extends beyond economic concerns. Tribal communities in North Dakota are particularly affected by methane waste, suffering not just from economic harm but disproportionate health impacts from venting and flaring. Representative Lisa Finley-DeVille (ND4a) co-founder and VP of Fort Berthold POWER, Western Organization of Resource Councils member and Dakota Resource Council board member said. “The BLM waste rule addresses the royalties lost from unfettered oil and gas production, but for my community on Fort Berthold Reservation, the fact that routine venting and flaring from existing and new wells is not eliminated means the continued waste of tribal resources. Not only do we lose out on revenue through royalties and taxes but we also have to pay the higher costs of healthcare due to exposure to the wasted gas. ”
BLM has authority and a legal responsibility to eliminate the waste of public resources. Reducing methane waste protects taxpayer resources,supports local economies and has important co-benefits such as reducing climate pollution and protecting public health.
In December 2023, the U.S. Environmental Protection Agency (EPA) finalized tougher clean air standards that, for the first time, establish protective limits on methane pollution from both new and existing oil and gas sources, including efforts to limit flaring from newly drilled wells.
Contacts:
Erik Schlenker-Goodrich, Western Environmental Law Center, 575-751-0351, eriksg@westernlaw.org
Kelsey Robinson, Environmental Defense Fund, 512-591-3404, krobinson@edf.org
Kerry Leslie, The Wilderness Society, 415-398-1484, kerry_leslie@tws.org
The Western Environmental Law Center (WELC) uses the power of the law to foster thriving, resilient western U.S. lands, waters, wildlife, and communities in the face of a changing climate. We envision a western U.S. abundant with protected and interconnected ecosystems, powered by renewable energy, and cared for by communities brought together in an ecology of kinship.
One of the world’s leading international nonprofit organizations, Environmental Defense Fund (edf.org) creates transformational solutions to the most serious environmental problems. To do so, EDF links science, economics, law, and innovative private-sector partnerships. With more than 3 million members and activists and offices in the United States, China, Mexico, Indonesia and the European Union, EDF’s scientists, economists, attorneys and policy experts are working in 28 countries to turn our solutions into action. Connect with us on Twitter @EnvDefenseFund.
The Western Organization of Resource Councils (WORC) is a network of nine grassroots organizations in seven Western states with 19,935 members, many of them ranchers and farmers committed to common-sense reform in agriculture, oil and gas development, coal mine reclamation, and rural economic development. Headquartered in Billings, Mont., WORC also has an office in Washington, D.C.
Dakota Resource Council’s mission is to promote sustainable use of North Dakota’s natural resources and family-owned and operated agriculture by building member-led local groups that empower people to influence the decision-making processes that affect their lives and communities.
Earthjustice is the premier nonprofit environmental law organization. It wields the power of law and the strength of partnership to protect people’s health, to preserve magnificent places and wildlife, to advance clean energy, and to combat climate change. Earthjustice is here because the earth needs a good lawyer.
The post National conservation groups respond to BLM methane waste rule, support action to limit waste of taxpayer-owned oil, gas appeared first on Western Environmental Law Center.
AM I AN ACTIVIST?
CELDF’s Consulting Director, Tish O’Dell, submitted her testimony, “Am I an Activist?” to the 2024 Spring Activism Peace Chronicle publication. Tish has been involved in community rights and Rights of Nature work starting in her own community of Broadview Heights, Ohio, which led to the adoption of Ohio’s first Home Rule charter amendment creating a Community Bill of Rights banning fracking and recognizing Rights of Nature. She has since gone on to work with dozens of Ohio communities on anti-fracking, anti-pipeline, right to a livable climate, fair and free elections and water privatization issues. Today, Tish works with communities all over the country and internationally.
Here’s an excerpt from Tish’s testimony, “I recently helped to organize a Truth and Reckoning event for Nature and the Great Lakes. We invited people to give testimony from lived experience and knowledge about various topics related to our current culture and how each impacts the Great Lakes and Nature as a whole. We heard from a Catholic nun, a college professor, a medical doctor, a journalist, an environmental lawyer, a former EPA contractor as well as many others including Indigenous people, college students, and community members too. It was an impactful day, listening to their truths, hearing about their part in the system and culture that we have all been born into, and ultimately how to reckon with those truths.”
“Am I an “activist”? If anyone would have asked me this question a year ago, I would have quickly replied “yes”. Ask me today and I might say no. We live in a time where there is more chaos and less order than when I was a younger woman or at least that is how it seems looking back and through the lens of my personal reality. Maybe reading this, some of my words will resonate with you, maybe they won’t. And that’s ok. That is one of many recent lessons I have learned.”
To read Tish O’Dell’s full testimony, click here.
Learn more about the Truth and Reckoning event hosted by CELDF in October of 2023, and listen to the many testimonies given on CELDF’s YouTube Truth & Reckoning Playlist.
The post AM I AN ACTIVIST? appeared first on CELDF.
Email Citi & Chase: Reject financing for Petroperú
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What is food dye?
From popsicles to pistachios and from meat to mac and cheese, synthetic food dyes are everywhere. Their vibrant colors make food appealing and increase our appetite.
But many dyes also pose serious health risks.
Made with petroleum-oil-based chemicals, artificial coloring has been associated with various health harms. Health concerns include behavioral and developmental issues in some children and the potential for increased risk of cancer.
The U.S. is one of the few industrialized countries without strict regulations on these harmful chemicals. Many countries, including Australia, Japan and those within the European Union, either restrict or ban these chemicals from use.
EWG is particularly concerned with the potentially harmful effects of seven food dyes: Blue Dye No. 1, Blue Dye No. 2, Green Dye No. 3, Red Dye No. 3, Red Dye No. 40, Yellow Dye No. 5 and Yellow Dye No. 6.
Uses of artificial food coloringFood dyes are used to create the bright colors often found in products marketed to children. Many ultra-processed foods, or foods industrially produced and made with ingredients not available at home, contain at least one, while others may contain a mixture of dyes.
So do tens of thousands of products in EWG’s Food Scores database, which rates the health hazards of packaged foods, including many types of breakfast cereals, ice cream and candy products. A large number of name brands, such as Mott’s Applesauce, Peeps and Minute Maid Fruit Juice, contain food dyes.
Common food dyes are also found in over-the-counter medication, mouthwash and children’s vitamins.
These chemicals are also often used in cosmetics and personal care products. Our Skin Deep® database includes thousands of products made with these dyes. While some of these products may lead to possible ingestion, such as lip balms and lipsticks, most products are not expected to be ingested and pose less of a health risk.
Get Your Free Guide: EWG's Guide to Food Additives Health issuesSome children are sensitive to the effects of artificial colorings, according to a study by the California Office of Environmental Health Hazard Assessment, or OEHHA. Food dye may aggravate symptoms associated with behavioral difficulties, including inattentiveness, impaired memory and restlessness.
Red No. 40, Yellow No. 5 or Yellow No. 6 – which account for 90 percent of food dyes used in the U.S. – are especially linked to those health effects. The EU requires any food products containing these three dyes to have a warning label that reads “may have an adverse effect on activity and attention in children.”
The Food and Drug Administration does not require the same warning. And it does little to restrict the use of food dye in food. The agency has approved all of these food dyes for general use “consistent with good manufacturing practices,” so restrictions are vague and ineffective.
The FDA’s current acceptable daily intake levels are based on outdated studies that do not reflect the potential health hazards of synthetic dye. To protect children’s health, these levels need to be much lower, according to the OEHHA.
Here are specific health risks associated with these seven food dyes:
- Blue Dye No. 1: A study observed developmental delays and behavioral difficulties in animals. Another study found associated developmental effects on the nervous system.
- Blue Dye No. 2: Consumption of this chemical caused an increased incidence of tumors in rats. Limited individual studies have been conducted.
- Green Dye No. 3: An animal study found a significant increase in bladder tumors associated with the consumption of this chemical. Limited individual studies have been conducted. It is the least used of these seven dyes.
- Red Dye No. 3: Ingestion of this chemical caused cancer in rats. It is banned from use in cosmetics, as enforced by the FDA.
- Red Dye No. 40: Hazardous to children’s brains during critical periods of development.
- Yellow Dye No. 5: In sensitive children, as little as one milligram of Yellow No. 5 can affect behavior, causing irritability, restlessness and sleep disturbance.
- Yellow Dye No. 6: Studies found potential contamination with benzidine or other cancer causing chemicals.
These chemicals were last reviewed by the FDA decades ago, some as early as 1969. Other dyes linked to health harms have not been reviewed in more than 40 years. Reevaluation by the FDA is not required, even when new evidence points to potential health hazards.
In 1990, the FDA banned Red Dye No. 3 in cosmetics but did not ban its use in food, despite proof it causes cancer. The FDA pledged to ban Red No. 3 in food but three decades later it has not acted. This chemical is still found in over 3,300 products in Food Scores.
The EU banned Red No. 3 completely in 1994, with the narrow exception of maraschino cherries.
Last year, California passed a bill authored by Assemblymember Jesse Gabriel (D-Encino) and co-sponsored by EWG banning the use of Red No. 3. It will take effect in 2027. Under market pressure, companies nationwide, such as Peeps maker Just Born, have pledged to stop using it in their products.
This year, state lawmakers in Illinois, New York and elsewhere have introduced several bills aiming to ban a number of harmful additives, including Red No. 3.
Last week, Pennsylvania legislators introduced a bill to ban six food dyes and three other chemicals. If these bills become law, the manufacture or sale of food containing these chemicals would be banned in those states.
Gabriel has introduced another bill to address the use of hazardous food dyes in school food by preventing public K-12 schools from serving any food with one or more of the remaining six dyes.
States and, under pressure, the food industry, are already taking some steps to protect consumers’ health. But the safety of U.S. food products requires swift nationwide action. It’s time for the FDA and other federal agencies to step up and join the movement. Despite new leadership, the FDA has not yet followed through on the agency’s pledge to ban BVO and did not ask for more funding to review the safety of food chemicals in the agency’s most recent budget request.
Lowering your exposure to food dyeIf you want to moderate your daily intake of food dye or lower it as much as possible, here’s where to start.
- Consult EWG’s Food Scores. The database accounts for the presence of food dyes when determining scores. When you’re on the go, use our Healthy Living app to find products without food dyes.
- Read food product labels. The FDA requires companies to list food dyes on product labels. Try to avoid products that use dyes.
- Avoid ultra-processed foods when possible. Most food dyes are found in processed food, limiting your consumption can improve long-term health.
Choose brands that use natural alternatives to dye in their products. Kraft replaced the yellow dye in its mac and cheese with turmeric, paprika and annatto in 2016.
Areas of Focus Food & Water Food Family Health Children’s Health Toxic Chemicals Food Chemicals Regional Issues California Disqus Comments Guest Authors Alexandra Hopkins, EWG Communications Intern March 27, 2024Pages
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