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Military Poisons
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 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
Navy 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.
____________________________________________________________________________________
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
---------
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.
________________________________
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
________________________________
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.
===========
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.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.
U.S. Navy Fleet Activities Yokosuka contaminates Japan by using PFAS in hundreds of products and applications daily
By Pat Elder
March 13, 2024
There are hundreds of products containing carcinogenic PFAS that are routinely used and discarded by the U.S. Navy at Yokosuka. Here we have four products made with PFAS that the U.S. military says are irreplaceable because of national security concerns.
The tape is made of Poly Tetra Fluoro Ethylene (PTFE), a kind of PFAS, known commercially as Teflon. Nothing works better, although there is no way to safely dispose of this product in Japan without jeopardizing human life. The same is true with the other products shown here.
3M’s 74 Spray Adhesive bonds foam and fabric to a wide range of substances - better than anything. Viton, a product of the Chemours Company, is made with PFAS and is added to synthetic rubber. Nothing else does a better job and nothing cleans engine parts better than PFAS chemicals. 3M’s Novec Cleaner is loaded with PFAS. It is all irreplaceable, according to the U.S. military.
PFAS is superman.
An open letter to Katsuaki Kamiji, Mayor of Yokosuka City, Japan
Katsuaki Kamiji, Mayor of Yokosuka City, Japan
Dear Mayor Kamiji,
Your Request to the Japanese Minister of Defense (Feb 20, 2024) addressing carcinogenic PFAS entering the sea through the wastewater treatment facility at United States Fleet Activities Yokosuka is a historic document. You are a champion of human health over political expediency!
You have repeatedly asked for the results of the PFAS testing of the effluent at Fleet Activities Yokosuka, but the U.S. Navy refuses to respond. This is indefensible. The people of the great city of Yokosuka, Japan should be entitled to know the levels of the carcinogens routinely discharged into Tokyo Bay.
We must understand the history to confront the injustice taking place while the U.S. Navy continues to pollute the region and withholds scientific data concerning the environmental devastation.
In September, 2022, the U.S. Navy shocked the world when it released data showing Perfluorooctanoic acid (PFOA) at 12,900 ppt (parts per trillion) in industrial wastewater at United States Fleet Activities Yokosuka. Mainichi Shimbun reported that 8,592 ppt of PFOS were detected in the wastewater discharged from the base's treatment plant.
Mr. Mayor, you understand that these carcinogens are so powerful that one part per trillion in the Tokyo Bay’s water can contaminate aquatic, plant, and animal life. PFOA tends to congregate in the solid waste at wastewater treatment plants, so it is important to know how the PFOA-loaded sewer sludge is being “disposed.” If it is spread on farm fields, the crops are likely to be poisonous. Incinerating the material typically fails to break the compounds down, resulting in poisoned skies, rain, soil, and seas.
PFOS may bioaccumulate in fish filet up to 2,000 times the levels in the water. Yokosuka is in big trouble and so is Tokyo Bay, where industries and the military in the great cities of Tokyo, Kawasaki, Yokohama, and Yokosuka routinely discharge these chemicals into Tokyo Bay.
PFOS concentrations in the liver and blood of five species of fish in Tokyo Bay are shown here in parts per trillion.
PFHxS and PFBS were also found at dangerous levels in the fish. Many other PFAS compounds are known to bioaccumulate in fish tissue.
People are alarmed when PFAS levels exceed 50 ppt in drinking water, but few are thinking about the fish.
These chemicals infiltrate the water. They coat the sediment of the bays, rivers, and the ocean. They become part of the coastal shoreline and are dried by the sun and lifted by the wind. The carcinogens PFOA, PFOS, and PFHxS have been found in dust in homes in millions of parts per trillion near military installations in the U.S., threatening the smallest children.
The chief pathway to human ingestion, however, is through the fish we consume.
Mayor Kamiji, Although I only possess an embarrassing and cursory understanding of Japanese intellect, history, and culture, I don’t believe the Japanese people comprehend the threat here, although you sure do.
I remember reading a statement from your office in 2022 expressing concern for the fishing industry considering the levels of PFOS being released by the Navy.
This is astounding!
You understand the carcinogen PFOS bioaccumulates in fish and you’re willing to say it publicly. This is the mark of a great statesperson. I still cannot find a single Maryland politician willing to say the fish in the Chesapeake watershed are poisoned by the military’s activities.
We are all subjects to the same authority, and I don’t think the Japanese people are being singled out for harsh treatment if that makes you feel any better. The United States Navy has poisoned the seawater and fish here in Maryland as well, and we are also powerless to do much about it.
When we see elevated blood levels among segments of the Japanese population it is the result of eating the fish as well as drinking the water and breathing the dust and the air.
Yokosuka, Japan September 24, 2023
In late 2022, the Navy installed the red granular activated carbon (GAC) filters shown here at the wastewater treatment facility. This occured after the city’s vehement reaction upon learning of the dangerous levels.
Although GAC is effective in the removal of long-chain PFAS, the technology shows generally poorer performance in treating short-chain PFAS. Both short-chain and long-chain PFAS compounds are found in the seafood people eat.
On October 21, 2023, a year after installing the filters, the Navy suddenly reported that the operation of the granular activated carbon filters had stopped. The Navy told the city the values of PFOS, etc. were “stable.”
The Navy explained to the town that “It would be difficult to determine the cause (of PFAS releases) because the wastewater treatment facility processes all the wastewater from the large-scale Yokosuka naval facility.”
The mayor wrote that the GAC filters were discontinued after confirming that the water before and after passing through the granular activated carbon filter was below the provisional guideline values of 50 ppt. This may be true - at a certain moment in time – when mostly non-PFAS bearing waste streams flow in and out of newly installed GAC filters. But we don’t really know because the Navy won’t tell us.
The monitoring ought to be constant and the process must be transparent. People should know these levels like they know the day’s temperature.
Let’s examine how they’re using PFAS on base.
Congress directed the DOD to prepare a report outlining the uses of PFAS that are critical to the national security of the United States. In response, the DOD published a report on Critical Per-and Polyfluoroalkyl substance uses in August, 2023.
The U.S. government recognized that individual U.S. states were increasingly passing laws restricting the use of PFAS. In response, the military carved out all of its uses of the toxins and deemed them to be necessary for national security - the god of law.
Critical PFAS uses were identified in every major weapon system.
Here’s a quick listing of several broad categories of hundreds of ways the U.S. Forces Japan use PFAS.
A crime is inherent in the manufacture of each of these commodities.
· Energy Storage and Batteries
· Microelectronics and Semiconductors
· Castings and Forgings and Strategic and Critical Minerals
· Refrigeration and Air Conditioning, Cooling
· Electronics Thermal Control
· Fire Suppression in Naval Vessels, Aircraft and Vehicles
· Aqueous Film Forming Foam
· Lines, Hoses, O-Rings, Seals and Gaskets,
· Tapes, and Cables and Connectors
· Electronic/Dielectric Fluids
· Advanced Oils, Greases, Fluids, and Lubricants
· Precision Cleaning Fluids
· Degreasing/Cleaning Fluids
· Adhesives
· Insulation and Foam Blowing
· Resins for Specialty Materials
· Specialty Filters and Membranes
· Uniform fabrics, Fabric Liners, and Fabric Barriers
=====================
Mr. Mayor, You have spent too much time demanding accountability from the U.S. Forces Japan. Forget about the Status of Forces Agreement and the unfairness of it all. Verify the existence of the commercial products specifically mentioned in the DOD’s Report on Critical Uses of Per-and polyfluoroalkyl substances and go after the manufacturers of these products. 3M and Chemours come to mind. It is the only remedy available to you.
The Downs Law Group helps to make this work possible. Their support allows us to research and write about military contamination around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.
Military Base Virtual Triage
By Pat Elder
March 4, 2024
Virtual Triage provides veterans and their dependents with a method to link the diagnosis of their disease to the exposure of toxins commonly found on military installations.
It wasn’t easy settling on the 11 deadliest toxins here. We left some killers out. The contaminants below, however, are responsible for most of the suffering and death caused by the military.
Here’s the list of toxins we used to build the virtual triage spreadsheet:
2,4-D & 2,4,5-T (Agent Orange)
BENZENE
CARBON TETRACHLORIDE
HEXAVALENT CHROMIUM
METHYLENE CHLORIDE (Dichloromethane)
PFOS
PFOA
TETRACHLOROETHYLENE (PCE)
TOLUENE
TRICHLOROETHYLENE (TCE)
VINYL CHLORIDE (CHLOROETHENE)
===============
The NIH’s Pub Chem site provides the diseases and disorders associated with each of the contaminants above.
If your base is a Superfund facility, the EPA will have an exhaustive list of contaminants likely containing many of the toxins shown above. You can also search for the toxins at your installation on ProPublica’s Bombs in your backyard. This site describes levels of contaminants in groundwater, surface water, sediment, and soil.
Pub Chem shows there are 209 diseases and disorders associated with the 11 toxins above. We analyzed these illnesses and reported the military toxin associated with each one. For instance, glucose intolerance is associated with Benzene. Niemann-Pick Disease, Type C is linked to Toluene.
Thanks to Jim Sandoe for his invaluable contributions.
Please take a moment to examine Virtual Triage and see “Sheet 13” for the list of diseases and associated chemicals.===================================================
Can you help us purchase the PFAS test kits we hope to use this summer to test waters near military sites in Ireland, Northern Ireland, Germany, Japan, and South Korea? We will be purchasing 60 kits at a cost of $79 each. That comes to $4,750. Please consider making a tax-deductible contribution to Veterans for Peace.
===================================================
Air Force secretive about PFAS contamination at Martin Air National Guard base in Maryland
.By Pat Elder
February 14, 2024
16 A-10C Thunderbolt II (Warthog) aircraft assigned to the 175th Wing, Maryland Air National Guard, conducted an “elephant walk” at Martin State Airport, Middle River, Md., November 3, 2021. (U.S. Air National Guard photo)
The Air Force has been secretive about the environmental damage it has caused as a result of its reckless use of PFAS in firefighting foams and other applications at Martin State Air National Guard Base near Baltimore, Maryland. Although the DOD says the Preliminary Assessment and Site Inspection are completed for Martin Air National Guard base, the records have not been been made public. The records are important because they inform the public on the levels and extent of PFAS contamination in the environment.
Congress requires the DOD to conduct investigations and take action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, at National Guard facilities where there are known or suspected DoD PFAS releases.
The last we’ve seen from the Air Force is a four-page May 4, 2021 technical memorandum that documented eleven sites on base with sufficient evidence of PFAS contamination of the environment that warranted additional investigation. Since then, the Air Force has failed to release further documentation of the contamination.
History of contamination
Located on 750 acres of waterfront property in Middle River, Md., the Glenn L. Martin State Airport is operated as a general aviation facility by the Maryland Aviation Administration (MAA) and is the operations home for the Maryland Air National Guard.
The property was purchased by the State of Maryland from the Martin Marietta Corporation in 1975. As the former site owner, Lockheed Martin bears a degree of responsibility for the environmental damage done to the region.
Prior to 1991 investigations at the facility were conducted by the Defense Environmental Restoration Program (DERP). Sixteen toxic sites were identified as warranting further investigation. After several investigations the Maryland Department of the Environment (MDE) ruled that no further cleanup actions were necessary.
That changed in 1991 after bits of crushed, buried drums were discovered along the runway. Lockheed Martin became involved in the investigation when debris uncovered at the site suggested a link between Lockheed’s predecessor and the areas being probed.
The drums were found to contain toxic dried zinc-chromate paint. The Maryland Aviation Administration removed these drums and the MDE ordered additional studies when the drums were discovered. Tetrachloroethene [PCE], trichloroethene [TCE] and vinyl chloride [VC]) were detected at extraordinary levels in soil samples. These are the same chemicals that poisoned groundwater at Camp Lejeune, North Carolina.
Several volatile organic compounds (VOCs) were detected in groundwater at concentrations exceeding the EPA’s maximum contaminant levels for safe drinking water by more than a factor of 1,000 (Maryland Environmental Service [MES], 1994).
In groundwater samples, elevated concentrations of total petroleum hydrocarbons (TPH), VOCs, and semivolatile organic compounds (SVOCs) were detected, and concentrations of several metals (chromium, lead, and nickel) exceeded their respective MCLs. The TCE concentration at one well was four orders of magnitude greater than the Maximum Contaminant Level. High levels of petroleum–related benzene, toluene, ethylbenzene, and xylenes (BTEX) were detected in groundwater at several site locations.
Surface water
In 1997, the Maryland Aviation Administration looked at contamination in Frog Mortar Creek. Copper and Polycyclic Aromatic Hydrocarbons (PAH’s) were detected at high concentrations in sediment samples (Apex Environmental, 1998). However, Maryland Environmental Services, MES determined that the concentrations in sediment were comparable to levels found in other sediment samples collected in the Chesapeake Bay, and that they posed no public health or environmental concerns with respect to surface water or bottom sediment quality.
In December, 2020, the Lockheed Martin Corporation published an investigation report on PFAS at Martin State Airport that described the presence of 7 PFAS compounds totaling 15,520 ppt in the groundwater very close to shore of Frog Mortar Creek. Is this report intended to be a substitute for the missing CERCLA documents?
PFOA was reported at a concentration of 2,300 ppt which is 575,000 times over the EPA’s interim health advisory. The PFOS at 7,800 ppt is 390,000 times over the threshold.
The red dot shows the location of groundwater testing near Frog Mortar Creek that showed 15,520 ppt of total PFAS.
The base and runway are located at the confluence of the environmentally sensitive Middle River, Frog Mortar Creek, and Stansbury Creek in Baltimore County.
Aqueous film-forming foam containing PFAS compounds was used and discarded at several fire training areas on base. Highly toxic sites include maintenance buildings, hangars, and places where fuels and oils were stored. PFAS was allowed to flow into surrounding creeks and rivers through storm water outfalls. Oysters, crabs, and fish are contaminated and people shouldn’t eat them.
The red marker shows the Maryland Department of the Environment’s sampling site for water and fish in the Middle River.
In 2023, the MDE reported finding 9.62 parts per trillion (ppt) of PFOS in the water at the mouth of the Middle River where it enters the Chesapeake Bay, approximately 2 miles from the Air National Guard base. PFOS (perfluoro octane sulfonic acid) is known to bioaccumulate in fish at levels that are hundreds to thousands of times ambient water levels. The MDE did not report on any other PFAS compounds while the base is uses many types of PFAS, some that also bioaccumulate in fish.
It's not surprising, then, that the MDE says it found 12,400 ppt of PFOS in a White Perch and 18,340 ppt of PFOS in a Yellow Perch.
What does it mean? The EPA’s interim health advisory for PFOS in drinking water is .02 ppt. The Yellow Perch is nearly a million times above this limit. Women who are pregnant or may become pregnant ought to be warned. Everyone ought to be warned.
An obscure MDE website advises the public to avoid eating Yellow Perch from the Middle River while it says people can consume one white perch every other month. What else is the state doing to warn the public? It’s been over two years since a fish advisory was posted for Piscataway Creek which drains Joint Base Andrews, but we have never seen a sign where people fish.
The MDE also warns the public not to consume Channel Catfish in the Middle River. It says we should limit Large & Smallmouth Bass to one fish per month; Catfish to 4 meals a month; Brown Bullhead to 2 meals per month; and Spot to 5 meals a month. We don’t know how contaminated these fish are, although the MDE reported that a Largemouth Bass caught near Joint Base Andrews contained 94,200 ppt of PFOS, while the state says the fish taken from the Potomac River are still OK to consume.
The MDE says it’s OK to eat 6 crabs a month from the Middle River. The Maryland agency also advises the public to eat no more than 6 crabs a month from Back River, Middle River, and the Patapsco River, including Baltimore Harbor. The Maryland Department of the Environment has not published crab test results for PFOS or any other PFAS compound.
In 2020, PEER (Public Employees for Environmental Responsibility) tested backfin crabmeat in St. Inigoes Creek in St. Mary’s City, a half-mile from a small Navy base and found 6,650 ppt of total PFAS. We can expect higher levels of PFAS in crabs in the Middle River.
Crab tomalley or “mustard” is a delicacy for Marylanders, but we shouldn’t eat it and we shouldn’t eat the crabmeat without knowing it’s levels of toxicity.
The MDE says the public should avoid eating the crab tomalley, or mustard in Back River, Middle River, Patapsco River, and Baltimore Harbor. In all other areas of the bay, the public is advised to eat the tomalley “sparingly.”
Advising the public to eat crab tomalley “sparingly” is the state’s way of saying a little bit of poison won’t hurt you too badly. Tomalley in crabs caught near military and industrial sites may contain high levels of polychlorinated biphenyls, (PCBs), dioxin, mercury, and PFOA. Although PFOS tends to accumulate in fish, PFOA, a deadly kind of PFAS, settles in crustaceans. The MDE doesn’t track it, or at least they don’t share what they know.
Few care about this. The state wants to protect jobs related to the seafood industry and recreational fishing. It also wants to protect jobs provided by the military.
Although Lockheed Martin Corporation is apparently in charge, the state of Maryland bears some of the responsibility for the contamination from the Air National Guard base. The Maryland Air National Guard has both a federal and a state mission. In peacetime, the governor of each state commands the Air National Guard. Maryland Governor Wes Moore ought to be able to release the Preliminary Assessment and Site Inspection on PFAS from the base. He could also prevail on the MDE to do a better job protecting public health from the scourge of PFAS.
Jobs over the environment
An A-10 Warthog is shown here with a seven-barrel Gatling-style autocannon. Photo: US Air Force
The 175th Wing of the Maryland Air National Guard at Martin State Airport has been in the news lately, although it has nothing to do with PFAS. The Air Force is in the process of retiring the A-10 "Warthog" aircraft based at the airbase, jeopardizing hundreds of jobs of support personnel.
In a rare display of bipartisanship, Maryland’s federal and state officials are stumbling over each to stop the Warthogs from leaving the state, or they are asking the Air Force to keep the flying mission of the base intact with other fighter jets. Maryland U.S. Sen. Chris Van Hollen (D). and U.S. Rep. Dutch Ruppersberger (D) implored the Air Force to safeguard the jobs.
Every Maryland delegate from Baltimore County signed a letter to Air Force Secretary Kendall imploring him to keep the flying wing of the Air National Guard at Martin State Airport. Delegate Nawrocki from Middle River, commented, “The Maryland Air National Guard accounts for 545 direct jobs and many more indirect jobs in Baltimore County and the state. If we lost this fighter mission it would have a devastating impact on our local economy.”
In order to give the Maryland Air National Guard a better chance of retaining a flying mission, state officials plan to renovate the runway at Martin State. There is talk of substituting the Warthog with F-35 and F-16 aircraft.
________________________________________________________________________________
The Downs Law Group helps make this work possible. Their support allows us to research and write about PFAS contamination in Maryland and around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.
Stop Weapons Testing in the Potomac River!
By Pat Elder
February 8, 2024
A high-speed camera captures the U.S. Navy’s Railgun projectile at the Naval Surface Warfare Center, Dahlgren, Virginia.
The rocket flies at speeds up to Mach 7 (5,370 MPH) down the middle of the Potomac River. The Morgantown power plant in Charles County, Maryland is shown in the background. Start at 1:11.
Oystermen routinely report finding bombs and explosive fragments littered along the bottom of the Potomac River south of Washington. - Chesapeake Bay Magazine
Last year the Potomac Riverkeeper Network and the Natural Resources Defense Council filed suit against the Navy in U.S. District Court in Maryland charging that the Naval Surface Warfare Center Dahlgren has been violating the federal Clean Water Act by firing munitions and releasing chemicals into the Potomac River south of Dahlgren, VA, without a discharge permit.
The suit claimed, “If the Navy were ordered to secure a Clean Water Act permit for its Potomac River weapons testing activities, that would protect the recreational, aesthetic, and commercial interests of Plaintiffs’ members, because a permit would impose restrictions on the Navy’s discharges to ensure compliance with water quality standards in the river.”
On January 10, 2024 the Navy settled the lawsuit and agreed to apply for a pollution discharge permit from the state of Maryland. This a victory, although a lot depends “on whether the Maryland Department of the Environment will include adequate protections in the permit,” Dean Naujoks with the Potomac Riverkeeper Network told Inside Climate News.
We can hope this is the case, although Maryland’s Department of the Environment has a lousy track record regulating the U.S. Navy’s environmental crimes in the state. The agency historically acts as a rubber stamp for the DOD’s actions in Maryland so there is skepticism that anything will change.
Every year the Navy fires about 4,700 large-caliber projectiles from Dahlgren and sets off more than 200 explosions in the river. It also releases substances over the water 70 times a year to simulate chemical or biological attacks.
From 1918 to 2007 the Navy fired nearly 70,000 rounds of ammunition per nautical square mile in a 2.3 square mile area of the testing range called the ‘dense zone’—just downstream of Swan Point, Maryland and Colonial Beach, Virginia.
Let’s try to put this into perspective. 70,000 rounds of ammunition per nautical square mile: A nautical square mile is 6,076’ by 6,076’ or 847 acres. 70,000 projectiles on 847 acres - That’s almost 83 bombs per underwater acre. This is a catastrophe for aquatic life.
This is a monumental environmental crime. The Navy must stop its destruction of our river and the life it sustains. Naval Surface Warfare Center Dahlgren Division should be shut down and the Navy must repair the environmental catastrophe it has caused. Where is the indignation?
The Potomac Riverkeeper and the Natural Resources Defense Council have brought needed public attention to this issue, although little is likely to change in Maryland, which has jurisdiction over the Potomac River to the Virginia shoreline.
Naujoks said, “We’re not trying to stop the activity. We’re just saying you should have permits and limits on what you’re putting in the river.” We all want to see strong regulatory measures built into the pollution discharge permit, but the Maryland Department of the Environment (MDE) has failed to protect Maryland citizens from the most egregious and environmentally destructive behavior perpetrated by the military in the state. Ongoing releases of deadly toxins at naval facilities like nearby Indian Head Naval Surface Warfare Center, the Patuxent River Naval Air Station, the Webster Field Annex, and the Naval Research Laboratory Chesapeake Bay Detachment in Chesapeake Beach are generally greeted by MDE with a wink and a nod.
The MDE allows the public to consume toxic fish in the Potomac River poisoned by Joint Base Andrews and the other bases. The MDE protects its corporate and military clients at the expense of public health and the environment.
The Navy knows the harm it causes to human health and Maryland’s environment. The Navy is determined to continue what it’s doing while it hopes and expects the public attention will go away.
It won’t be too tough for them considering ATSDR’s clean bill of health.
The agency couldn’t find any dangers associated with the Navy’s weapons testing in its 2006 report: “ATSDR did not identify any exposure where local community members were exposed to NSF Dahlgren-related environmental contaminants that would be expected to cause any health concern, including cancer. The on-base drinking water system meets or exceeds federal requirements for monitoring and treatment. Neighboring residents relying on private groundwater wells are unlikely to be impacted by base-related contaminants. Anglers and hunters who follow base and VDH recommendations are unlikely to be exposed to harmful levels of environmental contaminants from fish, shellfish, of game captured from the base or it’s access points to the river.”
The United States government is telling us not to worry.
In March of 2023 the Bay Journal reported, “Jennifer Erickson, a Dahlgren spokeswoman, said in an emailed response to written questions that 74% of the projectiles fired downriver are inert and that most of the live ordnance is fused to explode above the water.
Are we expected to take comfort in the statement that most munitions explode in the air? The smoke from these explosions is toxic and it drifts over our neighborhoods.
The Navy’s spokeswoman also said that rounds that don’t detonate bury themselves in the river bottom, and that the “small quantities” of chemical simulants released “would undergo immediate dilution.” Previous assessments by the Navy concluded such tests produced “no observable environmental effects,” she said.
In the real world the “rounds” that don’t detonate are often most problematic. The salty-brackish water and river bottom consume everything over time. It is madness to suggest that chemical simulants released will undergo immediate dilution. If we could only live in a world like that! Chemicals used in explosives contaminate the water, sediment, aquatic life, and human life. Many compounds settle on the river bottom and pose a threat to our health when they are disturbed by oystering and bottom fishing.FTop of FormBottom of Form
The Navy says it has “performed analysis using the best available science to determine the activities conducted on the Potomac River Test Range do not significantly impact human health or the environment.”
Significantly? They know how to argue these things in court. Of course, they can always claim “sovereign immunity” if states or individuals sue them. The military has claimed sovereign immunity in US District Court cases when they’ve been sued for damages. That means they claim the right to poison us in the name of national security.
The Navy has reported surface water at Dahlgren contaminated with mercury and compounds at 3.8 million parts per billion (ppb) and 1,000 ppb of Trichloroethylene. They reported 9.6 million ppb of lead in the water.
The groundwater on the base contains Uranium 234 at 1,070 ppb. The soil is also contaminated with Thorium 234 at 200 ppb and Uranium 238 at 500.0 ppb.
The Navy apparently feels that these levels of toxicity do not “significantly” impact human health or the environment.
The Navy’s press release sounds convincing, “The Department of the Navy is committed to environmental stewardship and looks forward to working with the Maryland Department of the Environment as they make a permit determination under the Clean Water Act for activities conducted on the Potomac River Test Range.”
On Jan. 10, the Navy agreed to apply for a pollution discharge permit from the Maryland Department of the Environment within 30 days. Let’s see how long it takes the MDE to slap something together. In the meantime, the Navy’s destruction of the river will be allowed to continue.
“We made a strategic decision at the beginning of the case that we would not try to shut the Navy’s operations down. We’re not aware of any clear information about the extent of harm caused by the Navy’s activities,” said Bob Dreher, the lead counsel for Potomac Riverkeeper.
Dreher and his colleagues were successful in compelling the Navy to apply for a discharge permit under the Clean Water Act. It is a welcome development. The environmental community must keep an eye on the MDE.
The bottom of the Potomac River is riddled with 155 mm gun shells similar to these.
Firing, dropping, and discarding munitions into waterways and the ocean have long been widespread practices of the U.S. military. It’s only relatively recently that elements of DOD, particularly SERDP-ESTCP (Strategic Environmental Research and Development Program & The Environmental Security Technology Certification Program) have taken its environmental impact seriously.
Numerous bombs, shells, rockets, grenades, and other items are lying on the surface, resting underwater, or buried beneath soil and sediment along the Potomac River south of Washington. They may explode if disturbed.
Despite what the Navy, MDE, and the Agency for Toxic Substances and Disease Registry (ATSDR) tell us, the chemical constituents and explosive byproducts of these munitions pose a toxic threat to public health and natural ecosystems as they move through the environment.
Furthermore, munitions constituents may contain as much as one or two percent heavy metals such as lead, cadmium, chromium, nickel, copper, and barium. (See the list of heavy metals and other contaminants below.) While explosive compounds may disappear upon combustion, metals remain and may form a variety of compounds. Simply put, upon detonation the metals in munitions go into the air, onto the land, or into the water. Over a period of time, measurable quantities accumulate in the environment.
Any sampling plan should estimate those quantities and attempt to determine where they all went. That is, there should be a mass balance analysis.
Thanks to Lenny Siegal with the Center for Public Environmental Oversight (CPEO) for his insight.
This table from Naval Sea Systems Command identifies the weight of explosives in the Potomac River:
Ammonium Picrate is toxic to fish in very low concentrations. It is poisonous if swallowed or if it has contact with the skin, according to NOAA.
RDX is classified as a possible human carcinogen by U.S. EPA. People may be exposed if they breathe RDX fumes from explosions. Studies have reported adverse gastrointestinal, hematological, hepatic, and renal effects in people who have been exposed. (NIH) People may also be exposed to RDX by drinking contaminated water or by touching contaminated soil.
TNT - Considerable amounts of weaponry containing TNT have been fired into the bottom of the Potomac River. The metal shells of these munitions are corroding. TNT can have sublethal and chronic effects in aquatic biota, especially in organisms that live directly on the sea floor or in subsurface substrates. (NIH) Unfortunately, these chemicals may also enter the marine food chain and directly affect human health upon consuming contaminated seafood. Human effects have been noted in a variety of tissues and organ systems including the brain, liver, blood, reproductive organs, kidneys, urinary bladder, and eyes. It is mutagenic and carcinogenic.
Algal scum turns the water green near Dahlgren, along the shoreline of the Potomac River at the Route 301 bridge, September 2, 2003. - MDE
Phosphorus - Too much phosphorus can cause increased growth of algae and large aquatic plants, which can result in decreased levels of dissolved oxygen in the Potomac, decimating aquatic life.
Ethylbenzene has been found in fish samples around the world. (NIH) The toxin has been clearly associated with: Acute Kidney Injury, Prenatal Exposure Delayed Effects and Respiratory Tract Infections,
Tetryl can enter your body if you breathe it in the air, drink it in water, or get it on your skin. Tetryl is linked to contact dermatitis and Asthma.
Toluene - Fish and other aquatic organisms are sensitive to both acute and chronic toluene exposure. Toluene bioaccumulates in fish (EPA). It is associated with a several dozen diseases, including Cerebral Palsy, Chromosome Aberrations, Cognition Disorders, Prenatal Complications, Neoplasms, and Neuroectodermal Tumors.
The environmental impact of the Navy’s weapons testing on the Potomac River
is more dangerous than the Navy and Maryland are telling us.
The Navy is investigating 82 radioactive sites at Dahlgren. Depleted uranium munitions were tested on the banks of the Potomac and highly radioactive materials were almost lost in the river. Atomic bombs with a yield surpassing the “Little Boy” that destroyed Hiroshima were assembled and stockpiled here. The place is still radioactive. The Navy reported that groundwater contains Uranium 234 at 1070.0 ppb. The soil is also contaminated with Thorium 234 at 200 ppb and Uranium 238 at 500 ppb.
Elsie, Dahlgren’s atomic bomb. Dahlgren developed a
light case (Light Case LC.. Elsie.) for the atomic bomb.
The ultimate ELSIE design at Dahlgren was the Mark 8. It was much lighter than the Mark 1 “Little Boy” at only 3,230 pounds (Little Boy was 9,000 pounds) and measured in at 9.7 feet and long and 14 inches in diameter, half the diameter of Little Boy. Its yield was probably 20-50 kilotons.
The public should understand more about the contamination freely flowing from military bases in Maryland. It is possible to search the Pub Chem site of the National Institutes of Health for the contaminants found at Dahlgren listed below. Searching for a particular toxin will bring you to a page that will allow you to search for associated diseases and disorders. It is possible to perform a kind of “digital triage” by performing these searches to identify environmental contaminants that may cause someone’s illness.
Bombs in your backyard – ProPublica
Data provided by DOD
List of Toxins in Surface Water at Dahlgren
with highest concentrations reported
Acetone 100,000.0 ppb
Allyl chloride 93,5000.0 ppb
Aluminum 1,110,000,000.0 ppb
Aluminum phosphide 981,000.0 ppb
Antimony and compounds 29,300.0 ppb
Arsenic (cancer endpoint) 11,200,000.0 ppb
Barium and compounds 110,000,000.0 ppb
Beryllium and compounds 1,500.0 ppb
Bis(2-chloroethyl)ether 1,000.0 ppb
Bis(2-ethylhexyl)phthalate (DEHP) 26,000.0 ppb
Butyl benzyl phthalate 10,000.0 ppb
Cadmium and compounds 2,000.0 ppb
Carbon disulfide 13,000.0 ppb
Chromium (total) 23,200.0 ppb
Copper and compounds 21,800,000.0 ppb
DDD 660.0 ppb
DDT 100.0 ppb
Dichlorobenzene, 1,4- 1,000.0 ppb
Ethyl benzene 4,400.0 ppb
Fluoranthene 500.0 ppb
Heptachlor 90.0 ppb
Lead 9,600,000.0 ppb
Manganese and compounds 532,000.0 ppb
Mercury 3,800,000.0 ppb
Methylene chloride 4,000.0 ppb
Nickel and compounds 12,300,000.0 ppb
Phenanthrene 600.0 ppb
Pyrene 700.0 ppb
Selenium 4,000.0 ppb
Silver and compounds 4,100.0 ppb
Tetrachloroethane, 1,1,1,2- 3,000.0 ppb
Trichloroethylene (TCE) 1,000.0 ppb
Vanadium 76,500.0 ppb
Zinc 96,200,000.0 ppb
The Downs Law Group helps make this work possible. Their support allows us to research and write about PFAS contamination in Virginia, Maryland and around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.
Poisoning Gaza
By Pat Elder
January 31, 2024
The buildings and the people in them are burning while the soil, sea, air, and groundwater are being poisoned in Gaza. - photo AP News
Joshua Frank’s article, Making Gaza Unlivable ought to be read by everyone. Frank is the managing editor of CounterPunch. He describes the collapsing infrastructure and dire circumstances of Gaza in this January 12 story:
“Like the Allied forces of World War II, Israel is killing indiscriminately. Of the 29,000 air-to-surface munitions fired, 40% have been unguided bombs dropped on crowded residential areas. The U.N. estimates that, as of late December, 70% of all schools in Gaza, many of which served as shelters for Palestinians fleeing Israel’s onslaught, had been severely damaged. Hundreds of mosques and churches have also been struck and 70% of Gaza’s 36 hospitals have been hit and are no longer functioning. According to HRW, Israel is using a lack of food and drinking water as a tool of warfare.”
We’ll examine the deadly contamination that accompanies the Israeli onslaught, starting with Aljazeera’s coverage.
Aljazeera reports: “Thousands upon thousands of Israeli and western-supplied bombs dropped on Gaza bring not just death but a toxic legacy from explosive chemicals, dust, and debris from destroyed buildings that pollute the air and the ground. Israel’s military offensive in Gaza is leaving a new layer of toxic chemicals in Gaza’s soil, adding to those left behind from many wars it has waged before.”
More from Aljazeera:
Nada Majdalani is the Palestinian director of EcoPeace Middle East, an organization that brings together Jordanian, Palestinian, and Israeli environmentalists.
See Nada at 5:20 and again at 14:53.
She described the situation: “We are at the verge of an environmental catastrophe in terms of the spread of diseases and the accumulation of corpses in the streets. This makes Gaza susceptible to pandemic diseases.
She continued, “We are seeing collective amounts of threats to the environment and to the public health. The Israelis are utilizing chemical weapons like white phosphorus. This is affecting the air pollution. The residue from white phosphorus bombs is now in the atmosphere. With the rainy season we expect that these residues will precipitate with the rain. Unfortunately, many people are now utilizing rainwater for drinking. People are also drinking untreated, salty water. This is dangerous for people with kidney and liver diseases. There is a danger of parasitic infections, hepatitis, and chicken pox.”
Nada Majdalani explains that 97% of Gaza’s aquifer was unfit for human consumption before the war. Now, she says there are tremendous problems regarding solid waste and wastewater due to the shortage of fuels necessary to operate treatment plants. Consequently, untreated sewage is entering the Gaza Sea and is draining into the streets.
Now, there are reports that the Israeli military is pumping fuel and seawater into the tunnels throughout Gaza, a death blow to the drinking water aquifer.
Heavy metals like lead, zinc, chromium, copper, platinum, titanium, cadmium, nickel, and vanadium may be coursing through the streets and flushing into the sea, along with PFAS and phosphorus. Wastewater treatment facilities everywhere on earth are conduits for chemical contamination even when they’re working properly.
Raw sewage is flooding the streets and polluting the sea in Gaza.
According to AP News, blast fragments found on-site show that the vast majority of bombs dropped on Gaza are U.S.-made. The weapons include 2,000-pound “bunker-busters” that have killed thousands in densely populated areas.
2000-pound GBU-31 Joint Direct Attack Munitions (JDAM) are transported to the flight deck of the USS Harry S. Truman March 21, 2003 in the Mediterranean Sea. The bombs were used in Iraq. U.S. Navy via Getty Images
The JDAM bombs include precision-guided 1,000 and 2,000-pound “bunker-busters.”
“It turns earth to liquid,” said Marc Garlasco, a former Pentagon defense official and a war crimes investigator for the U.N. “It pancakes entire buildings.”
Washington has donated 100 BLU-109 bombs to Israel that are meant to penetrate hardened structures before exploding, the report said.
The 2,000-pound BLU-109 bomb was specifically designed to kill civilians by penetrating hardened targets below the ground where families may be taking cover. A delayed-action fuse detonates the 550 pounds of high explosive tritonal, ensuring complete destruction of the location.
Tritonal
Tritonal is made up mostly of 2,4,6-trinitrotoluene, known as TNT. It accounts for a large portion of the explosives-related contamination in Gaza. TNT presents various health and environmental concerns. Potential symptoms of exposure may include irritation of the skin and mucous membrane, liver damage, jaundice, cyanosis, peripheral neuropathy, muscle pain, kidney damage, cataract, dermatitis, leukocytosis, anemia and cardiac irregularities. (NIOSH 2016)
The most likely routes of exposure to TNT are from drinking contaminated water or skin contact with contaminated surface water or soil. Potential exposure to TNT also occurs through inhalation, or by eating crops grown in contaminated soil (ATSDR 1995) The European Chemicals Agency, ECHA says this substance may cause cancer, is suspected of damaging fertility or the unborn child, and is suspected of causing genetic defects.
General Dynamics has made fantastic profits peddling this deathly substance. The company employs more than 100,000 people worldwide and generated $42.3 Billion in revenue in 2023, more than the annual gross national income of most nations on earth. (115 nations.)
A kind of false circular reasoning holds that manufacturing weapons for use in Israel by Boeing, General Dynamics, Lockheed Martin and others is good for the American economy. Actually, the weapons are provided to Israel at U.S taxpayer expense while the product of the munitions adds nothing of positive value, like building hospitals or rebuilding crumbling infrastructure in the U.S. or Gaza.
Gabriel Black with the World Socialist Website has compiled an excellent survey of the weapons the US provides to Israel. Data from Reuters, the International Institute for Strategic Studies, and Al Jazeera suggests this fleet consists of:
F-35’s manufactured by Lockheed Martin
F-16’s by General Dynamics and Lockheed,
F-15’s made by McDonnell Douglas / Boeing.
These warplanes are equipped with bombs, missiles, and guidance kits largely manufactured in the United States.
According to Al Jazeera, Israel has dropped 25,000 tons of ammunition—about double the power of the atomic bomb dropped by the United States on Hiroshima in World War II.
RDX is also a killer
The explosive compound RDX helped make America a superpower. Now, it’s poisoning the world’s water and soil. ProPublica
The explosive charge in many conventional bombs often consists of RDX. Gazans may be exposed if they breathe RDX fumes from explosions. People may also be exposed to RDX by drinking contaminated water or by touching contaminated soil. RDX is associated with Liver Injury, Edema, Anemia, Hemosiderosis and Spinal Diseases
Joint Direct Attack Munition (JDAM)
Nov. 6, 2023 - 75 anti-militarist youth organizers blocked all entrances to Boeing manufacturing plant 598 near St. Louis, MO. @wearedissenters
The Joint Direct Attack Munition (JDAM) is an add-on kit that turns “dumb” bombs into “smart” ones. All of the world’s JDAMS are made by Boeing in a single factory in St. Louis, Missouri.
More than 1,100 General Dynamics workers in Ohio, Michigan, and Pennsylvania supply weapons to Israel. Many of the factories producing weapons are organized under the United Auto Workers (UAW) or the International Association of Machinists and Aerospace Workers (IAM). It is reminiscent of the 1965 Phil Ochs song, I ain’t marching anymore:
Now the labor leader's screamin'
When they close the missile plants.
Call it peace or call it treason
Call it love or call it reason
But I ain't marching anymore
The people of Gaza must do what they can to avoid breathing the smoke from bombs dropped by the Israelis. When modern apartment buildings are engulfed in flame they emit poisonous gases. This figure captures the science of deadly smoke inhalation.
The chemicals here are found in the smoke from the bombing of an apartment building.
Burning a massive apartment building may generate many thousands of toxic chemicals and gases while modern science hasn’t been able to keep up with the adverse health effects that may result from each.
Imagine all the materials that go up in flames. These likely include plastics, foams, textiles, carpets, human and animal corpses, wood products (treated lumber, plywood, flooring), asbestos, lead, paint, synthetic fabrics, electronics, furniture, household chemicals, etc.
The asbestos is particularly concerning.
Respiratory ailments, cardiac hazards, and cancers connected with exposures to an environment affected by these fires are far greater than those a generation ago, mainly because the chemical compositions used today to manufacture products and weapons have changed dramatically. The alarming number of cancers among veterans (and their dependents) exposed to deadly chemicals on American military bases tells the story. The American and Israeli governments and their militaries are criminal enterprises.
White Phosphorus
Smoke rises above the Gaza Strip after a white phosphorus attack by Israel on Oct. 11, 2023. This was the first full day of Israeli atrocities when many Gazans were burned alive. - Ali Jadallah/Anadolu via Getty Images
Although Syria has long complained of Israel’s use of Napalm, we don’t have evidence of its use in Gaza, although we know the Israelis are using White Phosphorus, another frightening incendiary weapon. It is extremely toxic to humans.
Gazans are exposed to white phosphorus by breathing in air that contains the chemical or by swallowing water or food contaminated with it. White Phosphorus is a chemical made from phosphate rocks. Manufacturers use white phosphorus to make products like bombs, computer chips and rat poison. It’s a brave new world.
White phosphorus bombs can cause injuries that are more serious and harder to treat than injuries from conventional bombs. White phosphorus causes very painful burns. People have reported seeing smoke coming from their injury as the white phosphorus continues to burn in their skin. It’s evil. Because white phosphorus dissolves easily in fat, it is absorbed through the skin and into the body, where it can cause damage to the kidneys. liver, and heart.
As Nada Majdalani explained, Gaza is entering its rainy season. Rainwater washout of bomb sites contaminates nearby waterways, their sediment, and the aquatic life people consume.
Pesticides
Israel has a history of spraying heavy doses of pesticides along the buffer zones with Gaza to deprive potential ‘terror elements’ of cover, but farmers in Gaza say their crops and livelihoods are damaged.
We saw Israel’s lax enforcement regarding PFAS and brominated fire retardants, so it is not surprising that the nation is swimming in pesticides. Environmental and Health agencies designed to protect public health are instead subservient to the corporate national security state.
The use of pesticides and insecticides in Israeli agriculture is among the highest in the world, another factoid for the BDS folks. The most contaminated fruits and vegetables are: apples, leafy vegetables, wheat, barley, strawberries and grapes.
It’s not surprising that Israel also has among the highest rates of non-Hodgkin lymphoma in the world. Israeli children are widely exposed to organophosphate pesticides.
There aren’t any grownups in the Israeli room. We are witnessing the maturing of a rabid fascist state. Israel is leading the way to a new world order! Addressing the rise of the far-right in America, Noam Chomsky explains, “The ground is well prepared for the rise of neofascism to fill the void left by unremitting class war and capitulation of the mainstream political institutions that might have combatted the plague.”
In solidarity with the brave people of Gaza!
Israeli government poisons the region with firefighting foams containing PFAS
By Pat Elder
January 27, 2024
Petroleum & Energy Infrastructures (Tashan) in Kiryat Haim
An obscure 2022 report by the Israeli Ministry of Environmental Protection on PFAS provides shocking data on levels of PFAS contamination in the groundwater near oil installations in Haifa, Ashdod, and Kiryat Haim.
The facility pictured above in Kiryat Haim in Haifa on the Mediterranean Sea has contaminated groundwater with 908,000 parts per trillion of PFOS. The levels are 45.4 million times above the U.S. EPA’s interim health advisory for PFOS. The water, soil, air, and fish are believed to be poisoned throughout the region.
The Kiryat Haim facility is owned and operated by Petroleum & Energy Infrastructures, PEI, which is fully owned by the government of Israel. PEI's customers include the Ministry of Defense and the Israeli Electric Corporation, also owned by the government of Israel.
Table 1 Concentrations of PFAS pollutants (in parts per trillion) in groundwater monitoring wells at selected industrial sites.
Bazan and PAZ Ashdod are public companies. Haifa Group is owned by Trance Resource Inc., an American Holding Company.
In 2001, many countries, including Israel, signed the Stockholm Convention, that limits the distribution of persistent organic pollutants, which accumulate in terrestrial and marine systems and have the ability to migrate over long distances. The convention came into effect in 2004 and is updated from time to time.
As of today, the convention has been ratified by 185 countries, including China, the Russian Federation, and the European Union. The United States and Israel have not ratified the treaty.
In 2009 PFOS was added to the Convention, and in 2019, the compound PFOA was added. The convention prohibits the production of firefighting foams containing PFOS and PFOA and limits the import and export of firefighting foams containing PFOS and PFOA. It permits emergency use of existing firefighting foams containing these compounds but prohibits their use for training purposes. Much of the world has switched to using environmentally safe fluorine-free foams.
The Convention requires each party to prohibit and/or eliminate the production and use, as well as the import and export, of a host of deadly chemicals. Parties must take measures to eliminate the production and use of the chemicals with a few specific exemptions for use or production.
In 2020, the Water Authority of Israel reported finding 47 ppt of PFOA and 330 ppt of PFOS in drinking water, but these levels were not thought to be threatening to public health. The U.S. EPA does not regulate PFAS in drinking water, although it has established an interim health advisory of .02 ppt for PFOS and .004 ppt for PFOA.
In 2020 Haaretz reported that the extraction of potable water in the Krayiot region was stopped following the discovery of high dangerous levels of PFAS. The Health Ministry assumed that the pollution comes from the use of this fire-retardant foam at a fuel storage facility in the area.
In 2021 the Israel Fire and Rescue Authority stopped using fire-fighting foam that contains PFOS and PFOA, while allowing other toxic PFAS substitutes to be used. A 2023 pilot study indicated widespread exposure to multiple PFAS compounds in placental tissue of 20 pregnant women in southern Israel. Elevated PFOA placental concentrations were associated with pregnancy-related complications.
Brominated Flame Retardants (BFR’s)
Israel Chemicals Limited - Industrial Products (ICL-IP) is the world’s largest producer of elemental bromine, supplying over 33% of global demand. It manufactures fertilizers and brominated flame retardants that are used in many electronics, furniture, and building materials.
Brominated flame retardants have been routinely added to consumer products, including computers, TVs, electrical cables, carpets, furniture and textiles. Source - Israel Chemical Limited
Israel Chemical Limited says brominated fire retardants are essential for meeting fire safety standards, although the U.S. Consumer Product Safety Commission moved in 2017 to ban products containing any organohalogen flame retardant. Organohalogens are organic compounds that contain chlorine, bromine, and fluorine atoms. The ban of this toxic class of flame retardants will take many years to implement and there is concern that manufacturers will move from organohalogens to other types of toxic flame retardants.
The Green Science Policy Institute explains, “Flame retardants continually migrate out of furniture and into indoor dust which is ingested by people and pets.” Most upholstered furniture manufactured in the U.S. before 2015 is likely to contain toxic flame retardants.
Signatories to the Stockholm Convention on Persistent Organic Pollutants are committed to eliminating brominated diphenyl ethers from the recycling streams as swiftly as possible. According to the European Food Safety Authority it difficult to locate reliable up-to-date data on the production of brominated flame retardants, although this is closely linked to the production of bromine. In 2008, the four leading countries were USA (40 %), Israel (24 %), China (20 %) and Jordan (12 %).
There are thousands of Israelis fighting for the environment, for truth, and for justice on many fronts against powerful opposition. We must expose Israeli and American contempt for environmental protections enshrined in international law.
Brominated Flame Retardants (BFR’s) act a lot like PFAS
BFR’s contaminate people, the environment, fish, and wildlife. BFRs have been linked to endocrine disruption and thyroid disfunction. They are associated with immunotoxicity, reproductive toxicity, cancer, and adverse influence on fetal and child development.
BFRs are still found in the bodies of newborn American babies. Children are the most vulnerable to the toxic effects because their brains and other organs are still developing. Like PFAS, hand-to-mouth behavior and play that is close to the floor increases the potential of children to come in contact with harmful chemicals. Several studies demonstrate that exposure is higher in children than adults. See more from the National Institute of Environmental Health Sciences..
Like we’ve seen with PFAS, fish contains the highest levels of BFRs and dominate the dietary intake of many, while meat, followed by seafood and dairy products accounted for the highest US dietary intake. House dust is also reported as an important source of exposure for children as well as adults.
Like PFAS, we’re also witnessing how regulators have been playing a kind of whack-a-mole game with the chemical manufacturers of flame retardants.
In a new study, published this summer in Environmental Pollution, researchers analyzed the breast milk of 50 U.S. mothers in the Seattle area and detected a total of 25 flame retardants, including 16 replacement chemicals and nine phased-out PBDEs.
An Israeli associate claimed that PFAS is certainly a great threat to the Israeli people, but the toxins seem to have taken all of the air out the room for discussions of other contaminants like BFR’s. It’s interesting! Generally, tuna, salmon, and trout are kosher, and so is caviar from a kosher fish, whereas prawns, crabs, octopus, lobster, and shrimp are not kosher. PFAS and BFR’s don’t discriminate based the species of fish or whether they’re kosher. The chemicals contaminate all fish. We need more study to understand the fate, transport, and bio accumulative nature of these chemicals in the eastern Mediterranean Sea and aquatic life.
Leviticus 11:10 has part of it right, “Anything living in the water that does not have fins and scales is to be regarded as unclean by you.” Leviticus apparently didn’t have PFAS and BFR’s in mind. The threat posed to human health by PFAS and BFR’s is rarely discussed in the Israeli media. Low levels of PFAS in drinking water are occasionally dismissed as non-threatening, while coverage of PFAS in fish and food, the most prevalent pathways to human ingestion, is generally taboo.
The Downs Law Group helps make this work possible. Their support allows us to research and write about PFAS contamination in Israel and around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.
Dangerous PFAS foam found on the beach at St. Mary’s College of Maryland
By Pat Elder, Class of ‘77
January 15, 2024
Carcinogenic foam at St. Mary’s College of Maryland -December 10, 2023
Highly toxic fluorinated chemicals have been identified on the waterfront at St. Mary’s College of Maryland. The foam shown above contained 18 different PFAS compounds totaling 1,680.4 parts per trillion, (ppt.). PFAS stands for per-and poly fluoroalkyl substances.
PFOS, (Perfluo octanesulfonic acid), was found at 1,301.5 ppt, which is 77.4% of the total.
The contamination likely originated from the nearby Webster Field Annex of the Patuxent River Naval Air Station in St. Inigoes, Maryland. There are no other known industrial or military sites on the St. Mary’s River and it is unlikely that the contamination came from the college.
In April 2021 the Navy reported that groundwater at Webster Field contained a total of 92,378 parts per trillion of total PFAS:
PFOS 84,757 ppt
PFOA 2,816
PFBS 4,805
TOTAL 92,378 ppt
Groundwater may seep into surface water. The Navy released data on the three PFAS compounds shown above. The actual totals on the base are likely to be much higher if all of the compounds found in the foams are tested and reported.
The toxins were detected at Building 8076, also known as Fire Station 3. The Navy held routine fire-training training exercises with aqueous film-forming foam, known as AFFF. The toxins contaminate the groundwater on the sandy spit and seep into the St. Mary’s River where they are carried by the prevailing winds from the south southwest to the college.
The Navy claims there is “no current complete exposure pathways to people from releases of PFAS to on or off base receptors.” This is the Navy’s way of saying they accept no responsibility for their criminal actions.
Although we don’t drink from the waters in the St. Mary’s River, we are poisoned by the presence of PFOS in the oysters, crabs, and fish. It is a chronic, accumulative poisoning.
At least 18 different PFAS chemicals are present in the river
at St. Mary’s College of Maryland.
The propensity of PFOS and other PFAS compounds to bioaccumulate in seafood has been firmly established. PFOS may gather in fish tissue up to 2,000 times the ambient water levels. The state of Maryland is aware of Largemouth Bass in the Potomac River watershed that contains 94,200 parts per trillion of PFOS and they’re OK to eat.
The Maryland Department of the Environments has repeatedly argued that it is not fair to compare the consumption of PFOS in drinking water to the levels found in seafood, while many of the nation’s top scientists say otherwise.
PFOS is recognized as a carcinogen by the state of California, but not by the state of Maryland. It’s devastating impact on human health at miniscule levels of consumption has been well documented.
PFDA, PFNA, and PFUnA were also found at dangerous levels at St. Mary’s. These compounds also bioaccumulate in fish.
PFDA (148.6ppt) - linked to liver, immune, developmental, and male and female reproductive effects in humans.
PFNA (98.3 ppt) - associated with liver disease, asthma, breast neoplasms, and prenatal exposure, delayed puberty.
PFUnA (60.7 ppt) – linked to diabetes mellitus type 2, eczema, and testicular diseases.
Eurofins PFAS Test for Oyster, Crab, and Rockfish
The chart shown here is taken from a report furnished by Eurofins Laboratory dated October 29, 2020, on an oyster and a crab caught at the mouth of St Inigoes Creek where it empties into the St. Mary’s River about 3 miles south of the college. The Rockfish was caught at Cornfield Harbor on the Potomac, about 6 miles south of the college. The toxins are found in firefighting foams and used in industrial applications on base. The Rockfish had 15,000 parts per trillion of PFOS alone!
The U.S. EPA has established an interim health advisory for PFOS in drinking water at .02 part per trillion, meaning the levels in the Rockfish are 750,000 times above the threshold.
The report on the foam was done by Cyclopure, Inc. Both Cyclopure and Eurofins are used by the DOD for environmental testing.
I published the results of the poisoned seafood in November of 2020 and sent them to 50 regional press outlets. Only the Bay Journal reported the results.
Earlier in the year, when I first reported high levels of PFAS in the water at our beach on the north side of St. Inigoes Creek, a spokesperson from the Maryland Department of the Environment questioned the legitimacy of the results, suggesting that if PFAS did exist, it likely originated at the landfill or a municipal firehouse. The St. Andrews Landfill is 11 miles away while the Valley Lee Fire Department is 5 miles away. Neither facility is near the water. The fire station on base where the chemicals are recklessly used and discarded is 2,000 feet across the creek from our property. Why, I wondered, was the state covering for the Navy?
In March of 2020 almost 300 people crammed into the Lexington Park Library for a public meeting hosted by the navy to address the contamination. Many expressed their concerns. The college responded to public concerns by testing the river for PFAS.
From north to south: St. Mary’s College of Maryland, the site of seafood testing, and the Naval Electronic Systems Engineering Activity, Webster Field Annex of the Patuxent River Naval Air Station.
On July 8, 2020, St. Mary’s College of Maryland published a PFAS Final Report that contained several misleading statements. St. Mary’s is a state-supported, 4-year liberal arts college.
The press release says that PFAS may have been released at Webster Field when the fact had been established by the Navy. The press release focuses on the drinking water. The college stated, “College drinking water is provided through three wells located on campus. The College has consulted with Maryland Environmental Services (MES), and requested MES specifically test our campus drinking water for PFAS. The final report confirms that the College’s drinking water is free of PFAS.”
Drinking water was never the issue. I tested my well which draws water from 300 feet below the ground in St. Mary’s City and found no PFAS. Most of the PFAS in our bodies is from the food we eat, especially the seafood.
The air is also likely to be contaminated at the college. The sediment and beach areas at the college are caked with PFAS. When the tide goes out the winds dry the carcinogens and lift them into the air. PFAS settles in our lungs and in our homes as dust. I tested the dust in my home in December 2023 and found 958.2 ppt of total PFAS, including 692 ppt of PFHxS and 132.7 ppt of PFOS. Dust is regarded as the most prevalent pathway of ingestion for small children.
The college called on Maryland Environmental Services (MES) to test water from the St. Mary’s River which showed total PFAS at 1.7 parts per trillion. The college stated in its release, “PFAS chemicals are not readily absorbed through the skin so the risk of swimming in the river is negligible, however drinking the water from St. Mary’s River is not advised for reasons separate from PFAS chemicals.”
We may gain a perspective of the mentality of Maryland Environmental Services in this ridiculous and dismissive statement above. Ask hundreds of firefighters across the country who are involved in class action suits because of the contamination they’ve suffered through dermal contact with their PFAS-laden turnout gear.
Michigan has issued warnings about eating the fish and coming into contact with the foam.
Michigan has taken steps to warn the public
about PFAS and the foam in surface waters.
Although we don’t know the identity of the compounds with the concentration of 1.7 ppt of PFAS in the St. Mary’s River, the state of Minnesota has set limits for PFOS at .05 ppt in some lakes due to concerns about the bioaccumulation of the carcinogen in fish. This is no laughing matter. This is about warning women who are pregnant or may become pregnant to be careful about consuming these poisons.
The Wisconsin Department of Natural Resources warns residents that levels of PFOS in rivers and lakes above 2 parts per trillion are a danger to public health. (WQC is water quality criteria)
More on MES
MES is an independent state agency that provides environmental services to public and private entities, but mostly to state and local governments. It has no regulatory authority and functions as a non-profit business arm of the state.
The agency has been dogged by concerns about its quasi-governmental nature and the lack of accountability demanded of the agency. MES can circumvent procurement standards without the oversight that normal state agencies encounter. MES runs privately owned facilities. The organization does not file a Federal Form 990. Alarm bells ought to go off.
MES operates 89 wastewater treatment plants across the state, as well as multiple landfills and incinerators. These facilities are likely to be releasing high levels of PFAS into the environment while Maryland lags behind many states in regulating the carcinogens. The state has resisted attempts to regulate the toxins being released from these sources, although MDE says it has begun testing wastewater treatment plants across the state to gather data on the presence of PFAS in the influent, effluent, and sludge that result from the wastewater treatment processes.
We still haven’t seen any of these results.
The Maryland Environmental Service has had a controversial history. Its former CEO Roy McGrath embezzled several hundred thousand dollars from the agency. McGrath served as director of MES for 3½ years and left the MES to become Governor Larry Hogan’s chief of staff in May 2020. After McGrath accepted an unusually generous severance payment, he was awarded the job as Governor Hogan’s Chief of Staff. McGrath resigned after less than 3 months on the job, after the payments became public. McGrath had worked on campaigns with Hogan since 1992.
McGrath was declared a wanted fugitive when he failed to show up in a federal court for a trial on corruption charges in Baltimore in early 2023. He was killed during an FBI “agent-involved shooting” on April 3, 2023.
Independent analysis of water and seafood concentrations ought to be conducted in the St. Mary’s River. We learned that we cannot trust the state from the bogus report the Maryland Department of the Environment produced on PFAS in oysters.
MDE falsified oyster data. The MDE looked at PFAS in oysters and used an analytical level of parts per billion, meaning for any one compound, if levels were under 1,000 parts per trillion, they said there was no detection. The state says the oysters are OK to eat and they never tested the crabs, while we found 2,050 ppt of total PFAS in one oyster and 6,650 ppt of total PFAS in a crab.
In April of 2021 I sent a letter to the St. Mary’s County Health Department asking if it was OK for my daughter, with plans to have children, to eat the crabs, oysters, and rock fish caught from the river. I sent them my test results and I asked for a simple yes or no answer.
I received the following response from the Manager of the Environmental Program Manager, State of Maryland:
“Currently there are no known thresholds for natural waters or oyster tissue for PFAS. Maryland Department of Environment (MDE) does not currently have any advisories for contaminants in oysters. The only known PFAS thresholds are associated with drinking water, where the risk of exposure is greatest. The Environmental Protection Agency (USEPA) is currently researching the issue and MDE looks for their guidance related to sampling (surface waters and fish or shellfish tissue) and standard/approved methods, as well as considering a threshold for advising the public. MDE does not have any additional information regarding PFAS levels in surface waters or oysters at this time.”
So much for the yes or no answer. The state prefers to sit on the sidelines. They don’t say the fish are OK and they don’t say they are dangerous. MDE’s new fish advisory allows consumption of tens of thousands of parts per trillion of these chemicals. Smallmouth Bass in the Potomac north of Washington containing blood plasma with 574,000 ppt remains OK to eat.
PFAS-laden foam travels with the tide from the Naval Electronic Systems Engineering Activity, Webster Field Annex of the Patuxent River Naval Air Station on St. Inigoes Creek. This photo is from Rosecroft Point, just below St. Mary’s College of Maryland.The Downs Law Group makes this work possible. Their support allows us to research and write about PFAS contamination in Japan and around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Join the Veterans & Civilians Clean Water Alliance Facebook group.
Akashi River in Hyōgo Prefecture, Japan has record level of PFAS Contamination
By Pat Elder
January 5, 2023
Prefectural Assemblyman Maki Maruo (left) visited the Environmental Conservation Division in Kobe City Hall and submitted a document requesting industrial waste businesses to investigate the source of the waste.
Maki Maruo is a member of the Hyogo Prefectural Assembly, and he is very concerned about Perfluorooctanoic acid (PFOA) levels in the Akashi River. PFOA is believed to be the deadliest of all PFAS compounds. Maki is worried about the health of the people he represents.
In 2023 Maruo and others conducted PFAS testing of the Akashi River basin in Kobe City's Nishi Ward, and others.
The site of the record levels of PFOA is 12 kilometers from the sea,
not far from Kobe.
One site identified by Maruo’s group identified an area in the Akashi River with 100,000 ppt of PFOA. The civil engineering firm Seishin Kaihatu is responsible, according to the lawmaker. This is the highest recorded release of PFOA anywhere on earth.
Maruo was forceful with his words. “This is a great crime against humanity. Perhaps the company does not understand the consequences of its actions. It is the responsibility of the Ministry of the Environment to protect the Japanese people and the environment. Both entities are responsible for endangering human health.”
Toxic contamination flows from the Seishin Kaihatu site.
Levels are said to be 2,000 times higher than the target value.
13 locations had water levels that exceeded the Japanese government’s “provisional target value” of 50 parts per trillion (ppt) for the combined total of PFOS and PFOA. The Japan Ministry of the Environment watches from the sidelines.
PFAS concentrations in waters called effluent that pour from sewage treatment plants worldwide have been found to range up to 5,663.3 ppt, according to various studies. In 2022 at the U.S. Navy’s Yokosuka base on Tokyo Bay, the Navy reported 12,900 ppt of PFOA in wastewater draining to the sea.
Akio Koizumi, professor emeritus of environmental hygiene at Kyoto University, told the Kobe Shimbun, "We suspect that chemical substances treated as industrial waste may be leaking.” The Japanese people should listen to this great environmental prophet.
PFOA is leaking furiously, but it’s not a leak that can be easily fixed. It is a “leak” that is part of the daily routine. Certain industrial processes necessitate the release of the carcinogens and no one in Japan seems to have a better plan.
This is the site of the highly toxic water draining
from Seishin Kaihatu into the Akashi River.
Many look to the Japanese government to solve this politically charged human health crisis. Political realities rule out vigorous regulation in the U.S. and much of the industrialized world. Japan is the world’s hope, and it starts with the Ministry of the Environment.
The Kobe Shimbun reported:
Although carcinogens and other risks of PFAS have been pointed out overseas, no health hazards have been confirmed in Japan, according to the Ministry of the Environment. However, since the target values are being exceeded in rivers across Japan, the Ministry has indicated that it will conduct research on the harmful effects of PFAS.
Japan is 5-10 years behind much of the developed world on this, but the country is likely to catch up in a hurry, as its amazing history suggests.
A Minister of the Environment spokesperson explained, “Since there are no legal regulations, we will ask businesses that are thought to be the source of the pollution to take voluntary action if high values are found.”
Polluting businesses are allowed to regulate themselves because there are no laws saying they can’t. This is dangerous public policy that will change as the Japanese people learn how dangerous these chemicals are. University professors like Koizumi and Kouji H Harada of Kyoto University, along with Kunitoshi Sakurai of Okinawa University and a host of others have been trying to communicate the dangers. Generally, the press has been reluctant to cover the story in a meaningful way, aside from parroting official sources.
California classifies PFOA as a deadly human carcinogen. Exposure to PFOA in the tiniest concentrations has been associated with dangerously high cholesterol levels, pancreatic tumors, increased liver enzymes, decreased vaccination response, thyroid disorders, pregnancy-induced hypertension, testicular cancer, and chronic kidney disease.
It’s been almost 5 years since Linda Birnbaum, director of the U.S. National Institute for Environmental Health Sciences said the safety threshold for PFOA in drinking water should be under .1 part per trillion. Birnbaum explained, “If you look at the data, pancreatic tumors are present at very, very low concentrations from PFOA.”
It’s not surprising that the incidence, prevalence, and mortality of pancreatic cancer in Japan is the highest in Asia, while Japan is expected to continue seeing large increases in pancreatic cancer cases.
Chronic kidney disease is also closely linked to PFOA. Studies based on several community-based screening programs suggest that Japan has the highest prevalence of chronic kidney disease anywhere on earth.
Certainly, pancreatic cancer and kidney disease may be caused by multiple factors, but these findings deserve further scrutiny, especially when Japan is swimming in these carcinogens.
Since Dr. Birnbaum warned us five years ago, the U.S. EPA has established an interim health advisory of .004 ppt for PFOA in drinking water. The U.S. still does not have mandatory regulations.
EPA scientists set the advisories while political appointees decide whether to enforce them.
Japan’s advisory is set at 50 ppt, a level that is 12,500 times greater than the EPA threshold. The interim health advisory was set at .02 ppt for PFOS, demonstrating the American scientific view that PFOA - among all 15,000 varieties of PFAS, is thought to be the deadliest.
We tested the tap water in Toyonaka, Osaka and found 4.9 ppt of PFOA. This doesn’t sound like a great deal to the Japanese public, but it is still more than a thousand times over what the U.S. says is dangerous. The installation of a simple PFAS water filter cleaned the water from all PFAS. The Japanese ministries of the Environment and the Ministry of Health, Labor, and Welfare and Health ought to be more involved.
Generally, PFAS contamination in streams and rivers throughout Japan pose a greater threat to health than the contamination in the tap water.
The Japanese government’s provisional target of 50 ppt in surface waters fails to protect human health! Tiny levels begin the process of bioaccumulation in aquatic life. Consequently, fish and people are poisoned. Still, many will say they don’t drink from the toxic waters of the Akashi River, so this is not a big deal.
PFOA in these record concentrations can be extraordinarily dangerous for many reasons, but primarily because it bioaccumulates in certain species of fish and in clams and crabs at many times over the Japanese target of 50 ppt. Sewer sludge is loaded with PFOA and spread over fields that grow contaminated crops. Beef, pork, and chicken are also contaminated.
Asked if there is a difference between eating or drinking PFAS contamination, Dr. Birnbaum replied, “No. Both are routes of ingestion. Whether you eat it or drink it, PFAS go to the same places in the body and do the same thing. We need appropriate fish advisories and regulation of what’s in our food.”
PFOA coats the sediment on riverbeds and along the banks. When the waters recede, the chemicals dry in the sun and are lifted into the air as dust to settle in our lungs and our homes.
What’s in your dust, Japan?
Food is the primary exposure pathway of PFOA for adults, while dust is the most prominent way children are contaminated. Drinking water is the major exposure pathway in communities with contaminated water, while water service throughout Japan is rapidly mobilizing to meet the threat. It has always been about the food, although Japan is slow to realize this.
Japan may be slow to catch on to the threat posed by PFAS, although the message is spreading exponentially.
Kobe City Councilor Shinji Kagawa is organizing a conference for 400 set for April in Kobe that will feature Professor Emeritus Koizumi of Kyoto University. Kagawa is working with Maruo and Kaoru Kobashi, a prominent environmental activist. More to follow.
I plan to return to Japan over the summer with the Veterans for Peace Speaking Tour directed by Rachel Clark. I will lecture about the threat of PFAS posed by industrial, residential, and military sources. Information and awareness of the dangers of PFAS are growing exponentially in Japan. It is exciting to watch this dynamic nation come to grips with these dangerous carcinogens. This year we hope to raise enough funds to expand our tour and provide PFAS testing services to volunteers throughout the country. Please consider supporting us when we solicit contributions in future newsletters. - Pat
The Downs Law Group makes this work possible. Their support allows us to research and write about PFAS contamination in Japan and around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
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.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Join the Veterans & Civilians Clean Water Alliance Facebook group. (2.5 K members and growing rapidly.)
Adding Insult to Injury
The former Loring AFB in Maine is highly contaminated with PFAS.
Plans to redevelop the base into a fuel facility may be jeopardized.
By Pat Elder
December 26, 2023
22 sites have substantial concentrations of PFAS. Nearby streams and rivers are profoundly impacted. – Figure by Air Force Civil Engineer Center
Limestone, Maine, December 22. 2023 – A widely circulated article in The County newspaper “PFAS found on former Loring base could delay $4B fuel production project” contains numerous inaccuracies and important omissions regarding PFAS contamination caused by the Air Force at the former Loring Air Force base.
The Air Force is not being truthful to this community about the massive, toxic, and eternal contamination it has left behind. Frightening levels of PFAS contaminate the soil, air, water, and fish. Apparently, developers and the state don’t think it’s a big deal and are eager to re-develop the former air force base.
Seriously eroded journalistic performance and expectations have brought us to the point where “official” blather is taken as gospel truth. Here, the consequences may be deadly.
Excerpts from the article appear below in bold, followed by pertinent analysis.
The County: LIMESTONE, Maine, December 22, 2023 — One of the chemicals categorized as per- and polyfluoroalkyl substances, or PFAS, has been found in an old airport hangar at the former Loring Air Force Base, which could delay the base’s largest redevelopment project in years. Washington D.C.-based DG Fuels plans to construct a massive $4 Billion aviation fuel production facility on the former base.
Breaking News! PFAS has been found at the old Air Force base.
PFAS was slathered everywhere: maintenance shops, crash sites, ditches, ponds, streams, tank farms, nose docks, fire houses, runway foaming, hangars, fuel dump areas, wash racks, hard stands, multiple drains, landfills, burn house, jet engine maintenance areas, fuel tank farm, and the sludge drying bed area.
The toxins have permanently contaminated groundwater and surface water.
The County: The PFAS discovery raises legal questions about cleanup responsibilities if hazardous materials are found in the future. Data from the U.S. Air Force’s ongoing investigation of the site won’t be compiled before the start of construction on the DG Fuels facility in late 2024 or early 2025, creating uncertainty about the timing of the project.
These legal questions have been settled by the Air Force in U.S. District Court. The Air Force claims it is not legally liable for the irreparable and eternal contamination it has caused. If states try to sue the Air Force for poisoning property and life, the Air Force will claim sovereign immunity. In the name of national security, the Air Force argues it has the right to poison Maine. They treat Germans and Japanese and people across the country and around the world the same way.
The Air Force is likely to drag its feet before releasing anything further that will damage the DG Fuels deal. Besides, the existing record is enough to incriminate the Air Force.
“The PFAS discovery?” The Air Force used AFFF here from the early 1970’s until 1994. They’ve known it was dangerous since the mid-1970’s and they have a precise record of releases in groundwater, surface water, and fish. They know how much they’ve used, and where they released it. They know what they’ve done, and they don’t give damn.
The Air Force walks away from their criminality in Maine and everywhere else, and so far, they’ve been able to pull it off.
A Brook Trout like these caught near the former Loring AFB contained 1,080,000 ppt of PFOS. We don’t know the concentrations of other PFAS chemicals found in the fish.
Maine’s government, although a national leader in other aspects of PFAS management, could do a better job in this regard. Ten years ago the Maine Department of Environmental Protection reported catching a Brook Trout near the base with 1,080,000 parts per trillion of PFOS in its fillet. That concentration is 54 million times over what the EPA says is safe in drinking water. [1,080,080 / .02 = 54,000,000].
This is a crime, and the state is not prosecuting it. Maine is fully aware of the frightening concentrations of PFAS in streams and lakes and throughout the environment. They’re not calling out the Air Force and they want this attention to go away.
Loring has been an environmental trainwreck for two generations. It was placed on the EPA’s National Priorities List of sites in 1990. The entire region is profoundly impacted. PFAS just adds a new lethal/legal dimension.
The County: The U.S. Air Force began investigating at Loring in 2015 after finding non-dangerous levels of a PFAS known as aqueous film forming foams, or AFFF, in 21 of 22 sites of groundwater, surface water, soil and sediment and within some fish tissue.
Non-dangerous levels? The County must have gotten that from the Air Force.
First, let’s look at the highest groundwater levels for the 11 compounds reported by Wood Environment & Infrastructure Solutions, Inc. in the Final Site Inspection Report for Aqueous Film Forming Foam (AFFF) areas at former Loring Air Force Base, Maine. December 2018.
The EPA says we shouldn’t be consuming more than 1 part per trillion of PFOS or PFOA in drinking water. The EPA says these things but does not enforce them. Maine keeps the combined total of PFOS, PFOA, PFHpA, PFNA, PFDA, and PFHxS in drinking water under 20 parts per trillion, but the state allows thousands of times these levels to be consumed in fish and food. Eggs from one farm in Fairfield averaged 37,000 ppt of PFOS and 1,900 ppt of PFOA, but they’re OK to eat, according to the state. Clams, chickens, milk, deer, have all been found to be highly contaminated while Maine is willing to let the Air Force, with its annual $222 Billion budget, about three times greater than Maine’s entire GDP, walk away with no liability.
The Air Force is not alone in contaminating Maine with these chemicals.
The 8,770 ppt of PFOS shown above is especially alarming because groundwater poisons the surface water and PFOS bioaccumulates in the food we eat. Many of the other compounds listed above do as well. These poisons are flowing beneath the surface, and they are destined to impact the region’s health forever.
Let’s examine surface water levels at one location on the old base.
(Special thanks to the Environmental Working Group, Inc. for their continued diligence.)
The top 5 toxins in groundwater and surface water are almost identical.
The 1,440 ppt of PFOS in surface water is ghastly. Everything around is poisoned, including the water, the air, the animals, fish, and humans. It will remain forever. PFOS may bioaccumulate in fish up to 2,000 times the levels of the carcinogens in streams. PFOS levels this high in surface water may result in fish with more than a million parts per trillion of the toxins and that’s what we see at Loring.
The County: Last year, the Air Force partnered with global company Wood Environment and Infrastructure for a more extensive investigation of AFFF spread at Loring. So far, no levels of that PFAS have been found in the local drinking water supply, said Mark Kinkade, public affairs officer for the Air Force Installation and Mission Support Center.
Wood Environment published the revealing 2018 Site Inspection.
The Air Force will always try to steer the conversation toward the drinking water and that’s because there are reasonable, and relatively inexpensive solutions for this contamination. When the Air Force says the drinking water at all of its bases is under 70 parts per trillion, we have no reason to doubt them. Sadly, 70 ppt is too high to protect public health! The Air Force refuses to acknowledge that the EPA has replaced its initial Lifetime Health Advisory of 70 ppt for PFOS and PFOA combined, with an Interim Health Advisory of .02 ppt for PFOS and .004 ppt for PFOA. The Air Force can do and say whatever it wants.
The County: The PFAS does not exceed 70 parts per billion, the amount identified as dangerous under the Environmental Protection Agency’s Comprehensive Environmental Response, Compensation and Liability Act, known as CERCLA, part of a federal “superfund” used to clean up hazardous waste sites. The EPA replaced its 70 parts per trillion advisory (trillion not billion) with separate advisories for PFOS at .02 and PFOA at .004 ppt. in drinking water.
This is convoluted and that’s just fine with most of the folks who are paying attention.
The County: The Air Force’s overall investigation at Loring is continuing and won’t yield enough data to help form clean-up plans until at least early 2025, according to the Air Force. That causes concern for Loring officials, as DG Fuels intends to start construction by late 2024 or early 2025.
The Air Force holds all the cards. They always hold them. They never fold them.
Clean-up plans? There are no plans. How do we stop or attempt to clean the flow of groundwater into surface water over thousands of acres? How do we reach deep into subsurface soil to clean it? How do we clean up DNA-modified toxic invertebrates? How do we clean up thousands of perpetually contaminated acres of sediment around Loring? What’s the plan for remediating carcinogenic airborne dust? How do we clean the humans, the fish, and the wildlife? The carcinogens may not break down in the environment for thousands of years and perhaps longer.
“[The timeline] is way too long,” Carl Flora, president and CEO of Loring Development Authority said. “We’ll be meeting with our attorneys to discuss the legal aspects of this problem.” Among those issues, Flora said, will be a potential agreement between DG Fuels and Loring that would allow DG Fuels to continue operations at the facility and not be required to demolish buildings if more hazardous materials are discovered after the company’s production facility is built and operating.
DG Fuels CEO Michael Darcy said he currently does not expect a major delay in his company’s construction timeline. DG Fuels hopes to demolish the former hangar.
This is a $4 Billion deal and DG Fuels does not expect a major delay. That says a lot. It’s likely no one will be responsible for “cleaning up” the PFAS and Mainers will do their best to forget about it.
The Air Force has poisoned the fish forever.
Results are in parts per billion. - Loring AFB AFFF Site Inspection, Wood Environment, 2018
The runway is at the top right. Greenlaw Brook receives drainage from several aqueous film-forming foam (AFFF) areas. Surface runoff and groundwater transports PFAS to the Storm Drainage System which discharges into the East Branch Greenlaw Brook where a Brook Trout was found with 457,000 ppt of PFOS. Greenlaw Brook flows southwesterly to the Little Madawaska River which empties into the Aroostook River. A no fish consumption advisory is in effect on Greenlaw Brook.
Let’s examine all of the toxins in the fish reported by the Air Force. Increasingly, states that are testing fish only report on one compound – PFOS.
TABLE 3.0-6 Summary of Fish Tissue Analytical Results Site Inspection Report for Aqueous Film Forming Foam Areas at Former Loring Air Force Base, Limestone, Maine
A Smallmouth Bass caught in Durepo Reservoir contained 114,000 ppt of PFOS in its fillet while a Brook Trout had 46,300 ppt, according to the 2018 Site Inspection.
Earlier this year Maine issued a fish advisory for the Durepo Reservoir because of the PFAS contamination caused by the Air Force. The public is advised not to eat the Smallmouth Bass and to limit Brook Trout to four 8-ounce meals per year. Four servings of fish containing 46,300 ppt of PFOS are allowed yearly.
Does this advisory protect human health? The Durepo Reservoir is the secondary water supply source for the Town of Limestone.
To its credit, Maine is clear that women who are pregnant or may become pregnant should not eat any fish from inland waters anywhere in the state, so that’s good. How widely has this advisory been circulated?
Maine is not a special case. It is disposable property, as far as the Air Force is concerned. Besides, the Air Force is on a mission and the health of people and the planet don’t factor into it.
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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. Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
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