FIVE-YEAR CERCLA REVIEW – Former George AFB – Superfund ID: CA2570024453

GeorgeAFB.Info
BaseFamilyHousing.Info
Frank Vera
PO Box 1313
Jamestown, CA, 95327-1313
Phone: 209-782-4541

31 December 2015
By Email: [email protected]

Mr. Donald Gronstal
BRAC Environmental Coordinator (George)
Air Force Civil Engineer Center
3411 Olson Street
McClellan, CA 95652-1003
916-643-3672 ext. 211
[email protected]

Re: FIVE-YEAR CERCLA REVIEW – Former George Air Force Base, CA – EPA Superfund ID: CA2570024453

Introduction

 The right tool for the job DOD or US Environmental Protection Agency (EPA)

A scorpion asks a frog to carry it across a river. The frog hesitates, afraid of being stung, but the scorpion argues that if it did so, they would both drown. Considering this, the frog agrees, but midway across the river the scorpion does indeed sting the frog, dooming them both. When the frog asks the scorpion why, the scorpion replies that it was in its nature to do so.

When we, the Federal, State, Local Regulators, Restoration Advisory Board (RAB) members, and the public, are dealing with the Department of Defense and its employees, it would behoove us to remember who and what we are dealing with. The Department of Defense (DOD) and all of its components are an instrument of war, and its employees, by their very nature, are secretive, competitive, deceptive, combative, vengeful, and above all are driven to win at all cost. Unfortunately, the DOD and its employees have chosen not to lead by example and comply with all relevant Federal, State, and Local environmental laws that were designed to protect the environment, the public, the DOD’s civilian employees, military personnel and their families; instead, the DOD and its employees have chosen to follow their base nature.

During the last half century, the United States (U.S.) has spent trillions of dollars in the name of national defense to build and maintain its military forces and infrastructure.  In the process, the DOD has generated billions of tons of hazardous and radioactive waste, earning the DOD the distinction of being the nation’s largest polluter.

Despite spending hundreds of millions dollars, the Defense Environmental Restoration Program (DERP) and the Installation Restoration Program (IRP) have achieved little of their primary purpose: the “permanent cleanup of the DOD’s hazardous waste sites.”  It is doubtful this goal will ever be achieved without a major overhaul of the attitude of the DOD’s senior management and its employees.  Only then can the DOD achieve its goal “to demonstrate prudent environmental stewardship on its lands by cleaning up and restoring them in a timely and fiscally responsible manner.”

The environmental cleanup at the DOD’s Base Realignment and Closure (BRAC) installations is further complicated by the local government’s pressure on the DOD to prematurely transfer the contaminated installation (former base) to local control for redevelopment in order to minimize the adverse impact that the base closure had on these communities, including lost jobs, failed businesses, and a diminished tax base.

The DOD’s Flawed Environmental Assessment and Cleanup DERP / IRP

The DOD’s and its components’ (Air Force, Army, Navy, and Marines) Environmental Restoration Program (DERP) and the Installation Restoration Program (IRP) were flawed from their inception because:

• The DOD employee is compelled by law to secrecy, and by his or her training to defeat the opposition at any cost. Unfortunately, the DOD acts like we are the Opposing Council or enemy, and not the American veterans and citizens they swore to protect.
• The DERP and IRP were developed and implemented by DOD attorneys with the goal of shielding the DOD from responsibility and liability.
• The DOD routinely twists the “letter of the law” to circumvent the “intent of the law.”
• The DOD employee mandate is to transfer the property to non-federal interests and, if possible, to transfer the responsibility and liability for the contamination as well.
  • “Our mandate is to transfer the property.”
    Steve Mayer BRAC Environmental Coordinator (BEC) for McClellan AFB, CA
• The DOD directive is to avoid its responsibility to its service members and their families who were injured because of the toxic exposure at its Superfund Sites.
  • Fort McClellan, Anniston, AL – “The cost of attempting to identify all these individuals, including the cost of media advertising, would be a significant burden on the Army’s budget and at a time when the Army is furloughing personnel due to a shortage of funds,” Elizabeth King, the Pentagon’s liaison to Congress
    • “The email, obtained and authenticated by The Washington Times, was written in response to unsuccessful efforts by Rep. Paul Tonko, New York Democrat, to get legislation passed in the last Congress that would require notification to veterans who were stationed at Fort McClellan, in Anniston, Alabama, before it was closed for widespread contamination 15 years ago.” The Washington Times
  • Marine Corps Base (MCB) Camp Lejeune, NC – For years, the DOD/Navy blocked the release of records about the nature, extent, and the completed exposure pathway (CEP) to service members and their families at the MCB Camp Lejeune. It took a demand letter from Senate Judiciary Committee Chairman Patrick Leahy (D-Vt.) and a bipartisan group of eight other senators to force the DOD/Navy to release more than 8,000 unredacted DOD documents related to the water contamination.
• The DOD directive is to block the release of records requested through FOIA.
  • The methods used by the DOD to block the release of records include: citing unjustified exemptions, For Official Use Only (FOUO), unnecessary redaction, excessive processing fees, denial of Public Interest Fee Waivers and News Media Fee Waivers. These have been used without adequate legal justifications for such withholdings.
  • These methods have been used to block the release of records about the environmental contamination and the potential exposure to hazardous materials of base personnel, military family members, and civilian employees at George AFB, MCB Camp Lejeune, Hill AFB, and dozens of other DOD Superfund Sites and BRAC installations.
  • MCB Camp Lejeune – “FOIA exemptions have been cited to justify redactions of key documents in the Agency for Toxic Substances (ATSDR) public health assessment (PHA) for MCB Camp Lejeune.” Senate Judiciary Committee Chairman Patrick Leahy
  • Hill AFB, UT – When the local community requested under FOIA “the amount of arsenic known/projected to be left without treatment on off-base private properties,” the Air Force ruled that it would not release the information to the public.  It admitted having this data, but argued that any release might “confuse” the public.
• The DOD directive is to ignore federal, state, and local environmental laws if necessary.
  • McClellan AFB, CA – The Air Force is burying radioactive waste on the site that the Air Force is supposedly cleaning up, bypassing state environmental regulations because the site is on federal land that the Air Force plans to transfer to the local community. At McClellan, Mayer said that the objections will not stand in the military’s way. “They have their right to their opinion, and we have ours,” Mayer said. “We’ll continue to go forward with our plans.” Steve Mayer, BEC for McClellan AFB, CA

The DOD’s Conflict of Interest

The DOD and its components have an inherent conflict of interest because:

• At the former George Air Force Base (AFB), the Army, NORAD, Air National Guard (ANG), and the Air Force, were the “polluters” and “responsible parties.”
• The DOD/Air Force (AF) receives and controls the funding for the environmental assessment and remediation at its installations.
  • The AF has received about $125,000,000.00 for the IRP at George AFB, and the majority of the money has been spent on thousands of reports with the intent of crushing the federal, state, and local regulators; the RAB, and the public, by “papering them to death.” The litigation strategy of “papering” is commonly used by large legal firms against a small, understaffed, and underfunded law firm with the intent to overwhelm and depilate the resources of the smaller firm. This “papering” should be considered fraud because the money was earmarked for remediation of the contamination, not for “papering” the opposition.
• The DOD/AF is the custodian of records, and determines what records should be released to the federal, state, local regulators, and the public.
  • “23.1 … If the Party that is the subject of the request (the originating Party) [the Department of Defense and the Air Force] has the record or document, that Party shall provide access to or a copy of the record or document; provided, however, that no access to or copies of records or documents need be provided if they are subject to claims of attorney-client privilege, attorney work product, deliberative process, enforcement confidentiality, or properly classified for national security under law or executive order.” – George Air Force Base (George AFB) Federal Facility Agreement – 21 September 1990
  • The DOD/AF decided what records were provided to the Agency for Toxic Substances for the public health assessment (PHA) for George AFB
    • Since 1986, ATSDR has been required by law to conduct a public health assessment at each of the sites on the EPA National Priorities List. The aim of these evaluations is to find out if people were or are being exposed to hazardous substances and, if so, whether that exposure is harmful and should be stopped or reduced. Furthermore, before the Department of Veterans Affairs (DVA) will provide medical care and/or compensation for toxic injury, the ATSDR needs to establish a Completed Exposure Pathway (CEP) and a causal link to the contaminants that were released at the base. The mechanism that the ATSDR uses is the Public Health Assessment (PHA).
  • The DOD/AF controls the records search and interviews to determine what and where hazardous chemicals and toxic substances were used and/or disposed of.
    • The Air Force knew about the George AFB’s Atmospheric Nuclear Weapons Testing Decontamination & Decommissioning Centers. These Radioactive Decontamination and Decommissioning (D&D) centers generated an enormous amount of highly radioactive waste, including decommissioned clothing, equipment, and aircrafts.
      • By withholding the records from the contractor, CH2M Hill, who conducted the IRP Phase I Record Search, the Air Force effectively purged the evidence of radiological contamination from the IRP. This removal of the records about the radiological contamination also affected the outcome of the ATSDR’s PHA for George AFB. The ATSDR cannot assess a completed exposure pathway that it is not made aware of.
    • The DOD/AF controls the site investigation, determining what sites should be evaluated.
      • See: 4
    • The DOD/AF controls the site testing, determining what hazardous chemicals and toxic substances will be tested for, and the location from where samples will be taken.
      • See: 4
    • The DOD/AF controls what sites it considers contaminated, and the nature and extent of contamination.
      • From 1965 to 1 December 1981 (16 years), the Air Force dumped 5,578,400 gallons of industrial waste containing known carcinogens into the sewer, which emptied into the sewage treatment plant (STP), and the STP discharged directly into the STP’s percolation ponds. However, the Air Force determined that the unlined percolation ponds, the soil, and the groundwater were NOT contaminated based on one (1) sample. The Air Force failed to explain why only one sample point was used, and what happened to the 5,578,400 gallons of industrial waste that were indirectly dumped into the unlined ponds.  Source: IRP Phase I Record Search, Table D-1 “Master List of Industrial Operations,” CH2M Hill, January 1982
    • The DOD/AF controls the remediation of the contamination, how, when, if, and level that the contamination will be remediated (cleaned)
      • See: 7
      • This policy sparked a disagreement between the CA Department of Public Health and Steve Mayer, BEC for McClellan AFB, over McClellan’s radioactive waste dump.
    • The DOD/AF controls what is considered to be hazardous waste.
      • This policy sparked a disagreement between the DOD and the US EPA on whether applied pesticides require cleanup at Kansas Army Ammunition Plant (KSAAP).
        “It is the EPA’s decision that the pesticides are no longer protected under ‘intended use’ when the structures are demolished or are to be demolished. Because of this, the chemical’s ‘intended use’ is no longer applicable, and the pesticides become ‘solid waste’ and subject to RCRA Section 1004(27).”
    • The DOD/AF determines when the site is suitable for transfer.
      • For example, the organochlorine pesticides (“OCPs”) contaminated parcels of lands at: George AFB Family Housing, Naval Air Station Alameda (NAS) Family Housing, McClellan AFB Family Housing, and Kansas Army Ammunition Plant (KSAAP).
    • The DOD/AF controls what information is to be included in the CERCLA 120(h) deed restriction.
      • This policy has resulted in a lawsuit against the Navy for failing to notify the property’s purchaser that chlordane and other organochlorine pesticides (“OCPs”) were present on the property at Naval Air Station Alameda (NAS), CA
        • “American International Specialty Lines Insurance Company a general liability insurer, seeks to recover the costs incurred in removing certain hazardous substances–chlordane and other organochlorine pesticides (“OCPs”) – from a portion of a former naval installation. Plaintiff alleges that the United States Department of the Navy (“Navy”) failed to notify the property’s purchaser that chlordane and other OCPs were present on the property and that the Navy failed to remediate the chlordane and other OCPs in breach of two contracts between the parties. Plaintiff further alleges that defendant failed to indemnify plaintiff for its remediation costs pursuant to section 330 of the National Defense Authorization Act for Fiscal Year 1993, Pub. L. No. 102-484, 106 Stat. 2315, 2371-73 (1992) (codified as amended at 10 U.S.C. § 2687 note (2000)).”
      • The DOD controls what DOD grants are provided, and the amount that is given to develop reuse plans for closed and realigned military bases through the Office of Economic Adjustment, DOD.
        • These grants have the appearance of “greasing the wheels” of the local politicians to ignore the environmental and public health concerns.
      • According to community members from dozens of DOD Superfund Sites, it is common practice for the BRAC Environmental Coordinators (BECs), when challenged, to verbally threaten and abuse the federal, state, and local regulators who are trying to protect the public by enforcing relevant environmental laws. Some BECs have gone as far as demanding that the “conscious regulator” be replaced with a more “DOD friendly regulator” or “reuse friendly regulator.” If this has not worked, some of the BECs have chosen to ignore federal, state, and local environmental laws, and continue to go forward with the DOD plans despite the objections of the federal, state, and local regulators.

A Request for a New Public Health Assessment for George Air Force Base

Federal, state, and local environmental regulators, we desperately need you to require that the DOD comply with all applicable federal, state, and local environmental laws, and with the spirit of FOIA and Title 42 of the United States Code, as it applies to the handling of documents relating to the George AFB environmental contamination.  Additionally, the DOD needs to demonstrate prudent environmental stewardship on its lands by cleaning up and restoring them before releasing them to the public.

We are the men and women of the U.S. Military
We enlisted/were commissioned in the military to protect our country in its time of need, agreed to sacrifice our body or lay down our life if necessary to protect the country we loved. We did NOT agree to be needlessly poisoned by the very country we swore to protect, and we certainly did NOT agree to the poisoning of our spouses and children.

While the DOD knew of the nature and extent of the contamination at its bases, and the health risks that we were to be exposed to, the DOD never warned us about the contamination. We and our families (including pregnant and nursing mothers, and young children) were forced to work and/or live on one or more of the 148 installations that were to become designated DOD Superfund Sites.  These DOD Superfund Sites are some of the most contaminated parcels of land in the U.S. and the world.

Considering that we had repeated and prolonged exposure to high levels of numerous toxins, it is unreasonable to think that we and our families were not adversely affected. Unfortunately, the average length of time that we were stationed at a base was 4 to 6 years. Because of this, we lived with our families at one contaminated base after another, and the levels of toxins kept building in our systems, often with fatal results, especially for our children.

We desperately need the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a new Public Health Assessment for George Air Force Base so that we can get medical care for friends and families, and help bring closure for those who lost their loved ones.

Consequence of the DOD decision

Hundreds, possibly thousands, of people, including children, are sick, dying, or dead, after exposure to the extremely toxic contamination at George AFB.  By concealing the nature and extent of the contamination and its Completed Exposure Pathways, the Air Force has defrauded Air Force military personnel, their families, and veterans, of their pension and medical care.

• Doctors cannot treat the toxic exposures of base personnel and family members without knowing that there was a toxic exposure.
• Military personnel are being defrauded of their Medical Discharge, Military Pension, and medical care (TRICARE).
• Military personnels’ family members are being defrauded of their medical care (TRICARE).
• Veterans are being defrauded of their Social Security Disability, VA Service Connected Pension, and VA medical care.
• Veterans’ family members are being defrauded of their VA medical care (CHAMPVA).
• Parents were never given the choice of whether or not to have children because these parents were not provided information about their toxic exposure and the possible effect that it may have on their pregnancy and unborn children.
• The two schools on George AFB remained open for 10 years after the base was closed, potentially unnecessarily exposing the children and staff to environmental contamination.

George AFB’s Atmospheric Nuclear Weapons Testing Decontamination Centers

When the Air Force suppressed information, withheld documents, and denied the existence of the George AFB’s Atmospheric Nuclear Weapons Testing Decontamination & Decommissioning Centers, the Air Force lied:

• To the public, Agency for Toxic Substances and Disease Registry (ATSDR), Department of Veterans Affairs (DVA), Restoration Advisory Board (RAB), Congress; local, state, and federal regulators;
• To FOIA requestors;
• On the CERCLA 120(h) deed restrictions;
• To the recipients of the properties at George AFB.

These Radioactive Decontamination and Decommissioning (D&D) centers generated an enormous amount of highly radioactive waste, including decommissioned clothing, equipment, aircraft, radiologically contaminated soil and water.

When the Air Force personnel, civilian employees, contractors, and subcontractors conspired to conceal the true nature and extent of the contamination and the completed exposure pathways that existed at George AFB, they potentially:

• Endangered the public;
• Defrauded the injured Air Force personnel and family members of medical care and compensation for injuries caused by their exposure to hazardous substances and/or materials;
• Defrauded recipients of the George AFB land parcels and/or their insurance companies;
• Unnecessarily exposed the construction workers who demolished the old buildings to hazardous substances and/or materials;
• Caused the demolition contractors to dispose of hazardous substances and/or materials improperly;
• Unnecessarily exposed the construction workers who built the new buildings to hazardous substances and/or materials;
• Unnecessarily exposed the occupants of the new buildings built on the contaminated property to hazardous substances and/or materials.

There are approximately a dozen documents published by the US Government, including the Air Force, Atomic Energy Commission (AEC), and Defense Nuclear Agency (DNA), which mention the Atmospheric Nuclear Weapons Test Decontamination Centers, for aircraft, crews, and equipment, at George AFB. However, the Air Force Civil Engineer Center (AFCEC) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Administrative Record for George AFB contains NO mention of an assessment or remediation of the radioactive waste that these decontamination centers would have caused.

Defense Nuclear Agency (DNA)

DNA 6005F PLUMBBOB SERIES 1957
U.S. Atmospheric Nuclear Weapons Tests, Nuclear Test Personnel Review.
Project 53.9 (Photographic Reconnaissance Training)
This project was established to provide an opportunity for Air National Guard tactical crews to observe an atomic detonation in the near vicinity of a burst and make a damage assessment photo run over the target. Air National Guard units from 14 states participated during PLUMBBOB (see footnote page 162). These units (two RF-84F aircraft for each shot) participated on a rotational basis, staging out of George Air Force Base, California. Prior to the detonation, the aircraft flew from George AFB to a holding point where they orbited in a race-track-shaped pattern at 31,000 feet from Beatty to Lathrop Wells. About 10 minutes after the detonation, the aircraft were cleared to make a photo-reconnaissance run over ground zero at an altitude of approximately 10,000 feet.” – Page 185

– http://www.dtra.mil/Portals/61/Documents/NTPR/2-Hist_Rpt_Atm/1957_DNA_6005F.pdf

DNA 6007F – SHOTS WHEELER TO MORGAN
The Final Eight Tests of The PLUMBBOB Series,
6 September – 7 October 1957

8.2.4 Department of Defense Operational Training Project
The PLUMBBOB operational summary (27) indicates that the Air Force sponsored one operational training project at Shot CHARLESTON. Project 53.9, Photographic Reconnaissance Training, was fielded by the Tactical Air Command to indoctrinate Air National Guard Tactical Reconnaissance Units from George AFB, California, in conducting photographic missions over a nuclear target. Air National Guard Units participated in the project on a rotational basis. At Shot CHARLESTON, one T-33 with two crewmen aboard passed over ground zero ten minutes after the detonation at an altitude of 10,000 feet to photograph the nuclear target (8; 27).” – Page 27

– http://www.dtra.mil/Portals/61/Documents/NTPR/2-Hist_Rpt_Atm/1957_DNA_6007F.pdf

DNA 6008F – Shots BOLTZMANN TO WILSON
The First Four Shots of the PLMBOB Series 28
MAY-18 JUNE 1957 U.S. Atmospheric Nuclear Weapons Tests, Nuclear Test Personnel

Project 53.9, Photographic Reconnaissance Training, was intended to train Air National Guard Tactical Reconnaissance units in photographic missions over a nuclear target. Two RF-84F aircraft with one pilot each departed from George AFB, California, and flew to the NTS, where they orbited above Lathrop Wells at 31,000 feet until the shot was fired. Upon clearance from the Air Operations Center, they began the photographic mission, flying toward ground zero. They crossed the shot area approximately 15 minutes after the detonation at an altitude of 10,000 feet. At about 0525 hours, upon completion of the run, they left the area to return to base (2; 24).” – Pages 33 and 34

Project 53.9, Photographic Reconnaissance Training, was to indoctrinate Air National Guard Tactical Reconnaissance Units in conducting photographic missions over a nuclear target. Two RF-84F aircraft with one pilot each departed from George Air Force Base (AFB), California, and flew to the NTS, where they orbited above Lathrop Wells at 31,000 feet until the shot was fired. Upon clearance from the Air Operations Center, they began a photographic mission flying toward ground zero. The aircraft crossed the shot area approximately 15 minutes after the detonation at an altitude of 10,000 feet. Upon completion of the run, they returned to George AFB (3; 24).” – Page 57

Project 53.9, Photographic Reconnaissance Training, was conducted to indoctrinate Air National Guard Tactical Reconnaissance units in photographic missions over a nuclear target. Two RF-84F aircraft departed from George AFB, California, and flew to the NTS, where they orbited above Lathrop Wells at 31,000 feet until the shot was fired. Upon clearance from the Air Operations Center, they began a photographic mission flying toward ground zero. They crossed the shot area approximately 15 minutes after the detonation at an altitude of 10,000 feet. Upon completion of the run, they returned to George AFB (4; 24).” – Page 76

Project 53.9, Photographic Reconnaissance Training, was intended to indoctrinate Air National Guard Tactical Reconnaissance Units in conducting photographic missions over a nuclear target. Two RF-84F aircraft with one pilot each departed from George AFB, California, and flew to the NTS, where they orbited above Lathrop Wells at 31,000 feet until the shot was fired. Upon clearance from the Air Operations Center, they began a photographic mission toward ground zero. They crossed the shot area approximately 15 minutes after the detonation at an altitude of 10,000 feet. Upon completion of the run, they returned to base for decontamination procedures (5; 24).” – Pages 105 and 106

– http://www.dtra.mil/Portals/61/Documents/NTPR/2-Hist_Rpt_Atm/1957-DNA-6008F.pdf

DNA 6010F Shots WASP to HORNET
The first Five TEAPOT Tests 18 FEB – 12 MARCH 1955
U.S. Atmospheric Nuclear Weapons Tests, Nuclear Test Personnel Review.
http://www.dtra.mil/Portals/61/Documents/NTPR/2-Hist_Rpt_Atm/1955_DNA_6010F.pdf

DNA 6013F SHOTS ESS TROUGH MET and SHOT ZUCCHINI
The FINAL TEAPOT TESTS 23
March 1955 — 15 May 1955 U.S. Atmospheric Nuclear Weapons Tests, Nuclear Test Personnel Review.
http://www.dtra.mil/Portals/61/Documents/NTPR/2-Hist_Rpt_Atm/1955_DNA_6013F.pdf

Source accessed on 13 Oct 2015: U.S. Atmospheric Nuclear Test History Reports

United States Air Force Historical Research Agency (AFHRA)

History of the 479 Fighter Bomber Wing (FBW)
1 December 1952 – 30 June 1953, George Air Force Base California
Supporting Documents Include Photographs Of Aircraft Decontamination Center At George Air Force Base CA.
Air Force History Index

History of the 479th Fighter Bomber Wing, 1 December 1952 – 30 June 1953, George AFB, CA – (PDF 32.1 MB)
Photographs Of Decontamination Centers start at page 282

Defense Technical Information Center (DTIC)

Operation UPSHOT-KNOTHOLE
Nevada Proving Grounds, March-June 1953, Project 6.11. Indoctrination Of Tactical Air Command Air Crews In The Delivery And Effects Of Atomic Weapons
… were retracted, normal fighter formation was resumed, and all aircraft proceeded directly to George AFB for decontamination, interrogation, and …
www.dtic.mil/dtic/tr/fulltext/u2/a951616.pdf – 268k – 1953-12-01

Shot PRISCILLA
A Test of the PLUMBBOB Series, 24 June 1957.
… Upon clearance from the Air Operations Center, they began a photographic mission toward ground zero. They crossed the shot area approximately 15 minutes after the detonation at an altitude of 10,000 feet. Upon completion of the run, they returned to George AFB …
www.dtic.mil/dtic/tr/fulltext/u2/a105674.pdf – 618k – 1981-02-27

Shots DIABLO to FRANKLIN PRIME
The Mid-Series Tests of the PLUMBBOB Series, 15 July – 30 August 1957.
… 10,000 feet. Upon completion of the run, the aircraft returned to George AFB for decontamination (1; 3). 37 Page 43. 2.2 …
www.dtic.mil/dtic/tr/fulltext/u2/a118683.pdf – 1090k – 1981-09-29

ATSDR’s Public Health Assessment (PHA) for George AFB – Radiological Contamiantion

Since 1986, ATSDR has been required by law to conduct a public health assessment at each of the sites on the EPA National Priorities List. The aim of these evaluations is to find out if people were or are being exposed to hazardous substances and, if so, whether that exposure is harmful and should be stopped or reduced. Furthermore, before the Department of Veterans Affairs (DVA) will provide medical care and/or compensation for toxic injury, the ATSDR needs to establish a Completed Exposure Pathway (CEP) and a causal link to the contaminants that were released at the base. The mechanism that the ATSDR uses is the Public Health Assessment (PHA). See: ATSDR – Camp Lejeune, North Carolina.

To complete the Public Health Assessment (PHA), the ATSDR relied on the Air Force to provide the relevant information and records. The Air Force failed to notify the ATSDR of the existence of:

• George AFB’s Atmospheric Nuclear Weapons Testing Decontamination Centers for aircraft, crews, and equipment
• The large quantity of highly radioactive waste the decontamination centers would generate
• Where this quantity of highly radioactive waste was disposed of including the decommissioned and radioactive aircraft, equipment, and clothing
• The potential exposure pathways that this radioactive waste would create

The Air Force failed to provide any information or records about the Atmospheric Nuclear Weapons Testing Decontamination Centers or the location of its radioactive waste. See:  http://www.atsdr.cdc.gov/HAC/pha/PHA.asp?docid=24&pg=3#REFERENCES

Chlordane and other organochlorine pesticides (“OCPs”)

The high number of reported miscarriages, stillbirths, infant mortalities, preterm births, low birth weights, childhood cancers, and infertility in women and girls who lived in the George Base Family Housing may be partly due to the persistent, cumulative nature, and synergistic interaction of organochlorine pesticides

Organochlorine pesticides (OCPs) have created environmental, safety, and legal issues for the DOD. Chlordane and other organochlorine pesticides (“OCPs”) were used as pesticides, herbicides, insecticides, termiticides, and rodenticides at virtually every military installation in the U.S. In years past, organochlorine pesticides were so widely used to protect DOD structures and infrastructures that they should be presumed present in ALL structures and infrastructures built prior to the late 1980’s when the use of organochlorine pesticides was banned by the DOD.

As soon as the DOD suspected that it had a problem with these extremely toxic pesticides, the DOD had a moral and legal obligation to test all of its tenantable/habitable structures at its bases. If any building tested positive for unsafe levels of toxins, the DOD should have declared the building unsafe, condemned the building, relocated the occupants to safe housing/schools/offices, remediated the contamination or demolished the contaminated building, and notify the former tenants and building occupants about their possible exposures. 

As early as 1970 the Air Force knew that some of its Base Family Housing units were contaminated, and the occupants exposed, to a large quantity of chlordane. The Air Force knew that due to the method used to apply the insecticide, the building design flaw, and the potential Completed Exposure Pathway that existed at a large percentage of its tenantable/habitual structures, exposure of the occupants was possible.  Furthermore, the Air Force knew that there was NO safe level of Chlordane contamination for young children on the surfaces of floors, personal possessions, or Chlordane aerosol and/or vapors. However, the Air Force chose to do nothing to protect the occupants of the George AFB Family Housing units.

1970 – Chlordane Contamination of Government Quarters and Personal Property Webb AFB

1970 – The Air Force knew that some of the Webb Air Force Base Family Housing units were contaminated, and the occupants exposed, to a large quantity of chlordane. The Air Force knew that due to the method used to apply the insecticide, the building design flaw, and the potential Completed Exposure Pathway that existed at a large percentage of its tenantable/habitual structures, exposure of the occupants was possible.

Furthermore, the Air Force knew that there was NO safe level of Chlordane contamination for young children on the surfaces of floors, personal possessions, or Chlordane aerosol and/or vapors.

A substantial quantity of 2% Chlordane insecticide (emulsifiable solution) was introduced into the heating ducts of two Capehart type housing units at Webb AFB, Texas on 12 March 1970. The insecticide was being used as a subslab termite control agent in accordance with AFM 85-7(8-16), when it was accidentally introduced into the heating ducts formed within the concrete slab. Several hours after the treatments the heating systems were thermostatically activated and distributed the pesticide as an aerosol and vapors throughout the housing units during the night. Page i

On 12 April 1970 a 2% water-chlordane insecticide solution was accidentally introduced into the heating ducts of two Capehart type housing units at Webb AFB TX. These heating ducts consisted of cardboard lined conduits within the concrete slab. Subsequent activation of the heating systems resulted in extensive human exposure and gross pesticide contamination of government housing and personal possessions.
Page 1

… and virtually undetectable floor residues are necessary if children are to inhabit the quarters.
Page 4

The presence of children in the family requires residue levels of 7.0 ug/ft2 on walls and ceilings and undetectable floor residues.
Page 6

All clothing and furniture should be decontaminated. Stuffed furniture, which will contain higher volumes of pesticides, should be reupholstered or replaced. All clothing should be dry cleaned twice and the dry cleaning solvent properly disposed of in a sanitary landfill. Children’s toys which can be dry cleaned should be where the cash or sentimental value warrants it, others should be replaced.
Page 8

– Chlordane Contamination of Government Quarters and Personal Property Webb AFB TX
USAF Environmental Health Laboratory (AFLC) – 12 March 1970 (PDF – 2.5 MB)

1982 – An Assessment of the Health Risks of Seven Pesticides Used for Termite Control

1978-79 – “… the Air Force in 1978 asked the National Research Council’s Committee on Toxicology, in the Board on Toxicology and Environmental Health Hazards, Commission on Life Sciences, to review the toxicity data on chlordane and to suggest an airborne concentration that could be used as a guideline in deciding whether the housing should be vacated.” …  “The Committee on Toxicology (NRC, 1979) concluded that it “could not determine a level of exposure to chlordane below which there would be no biologic effect under conditions of prolonged exposure of families in military housing.”
Page 1

1982 – “Given the available data and the fact that under conditions of prolonged exposure of families in military housing there may be persons, such as [developing fetuses and] young children, who in general are more susceptible to environmental insults, the Committee concluded that it could not determine a level of exposure to any of the termiticides below which there would be no biologic effects.”
Page 46 

– An Assessment of the Health Risks of Seven Pesticides Used for Termite Control
The National Academy of Sciences and the Office of Naval Research – Aug 1982 – (PDF – 3.82 MB)

1981-82 – News Articles – Pesticide Contamination – Military Housing

1981 – “The Army Times and Its companion newspapers reported in today’s editions that thousands of families may have been ex-posed to pesticides while living in military housing. Pentagon spokesman Bill Caldwell said the Defense Department is ‘studying the matter to determine whether or not we should commence a large scale inspection and monitoring program for military housing units’.”

– Pesticide May Pollute Military Base Housing
The Palm Beach Post – April 27, 1981

1982 – “A pesticide used to kill termites [chlordane] has leaked into the ventilation systems of more than 1,500 houses at United States Air Force bases across the country, according to studies made public recently by the Air Force. The pesticide, chlordane, was found to have entered heating and air-conditioning ducts in dwellings built on concrete slabs, allowing it to circulate in the air freely.”

– Chlordane Problem in Houses on Slabs
The New York Times – September 30, 1982

2004 – Guidance for Addressing Chlordane Contamination at DOD Sites

1988. What is Chlordane?
      Chlordane was a registered use pesticide applied from around 1948 until 1988. Its primary use was for termite control, but other known uses include application to prevent nesting of fire ants around power transformers; as a herbicide to control weeds in turf; and to control insects on lawns, gardens, and food crops (such as corn). So there are potentially many areas on DoD property, including family housing units, where chlordane may be found as a result of lawful application.
1989. How Was Chlordane Used?
      High concentrations of chlordane may be found around military housing as a result of lawful application for termite control. To control termites, the chlordane was initially applied to soil prior to construction beneath building foundations. Then it was PWTB 200-1-31 DoD’s pest management practice to routinely reapply chlordane every three to five years thereafter by methods such as treating the perimeter of the foundation by spraying with a rod inserted into the soil, by applying via a small trench dug along the foundation, or by injecting the chlordane through holes drilled in flooring at the periphery of walls. Thus relatively high concentrations of chlordane may have accumulated in these areas over time.

– Guidance for Addressing Chlordane Contamination at Department Of Defense Sites
U. S. Army Corps of Engineers – 30 September (2004 PDF 0.09 MB)

George AFB Family Housing – Pesticides Levels

In 2002, aldrin, chlordane, DDT, dieldrin, endrin, heptachlor, and lindane were detected in the surface soil at the George AFB Family Housing. On 1 October 2007, the levels of these persistent organochlorine pesticides and their breakdown products was so high that the Air Force banned the property and housing for residential use.

• 1998 – In the Public Health Assessment for George Air Force Base the ATSDR made the following statements:
  • “ATSDR did not identify any completed exposure pathways from George AFB to children at nearby schools or residential areas.” Page 27
  • “Soil at George AFB does not represent an apparent past public health hazard and does not represent a present or future public health hazard.” Page 28
    ATSDR-PHA-HC-George Air Force Base

• 2002 – The Air Force knew that the surface soil under and around the George AFB Family Housing was contaminated with hazardous levels of organochlorine pesticides
  • aldrin at 16, 700 μg/kg – 576 x PRG – Sample Depth (ft. bgs): 0.3-0.8
  • dieldrin at 15,000 μg/kg – 500 x PRG – Sample Depth (ft. bgs): 0.3-0.8
  • chlordane at 24,100 μg/kg – 15 x PRG – Sample Depth (ft. bgs): 0.5-1
    μg/kg: concentrations of chemicals in soil measured in units of the mass of chemical (micrograms, μg) per mass of soil (kilogram, kg)
    PRG: residential preliminary remediation goal
    ft. bgs: feet below ground surface

• 2005 – “Within the housing area of Former George Air Force Base the pesticides Aldrin and Dieldrin were used to control termites. In 2002 the soil in this area was tested for Organochloride Pesticides and in several locations elevated levels of Aldrin and Dieldrin were detected. In 2005 the Air Force advised the City [of Victorville] that these levels of pesticides may present a danger to human health if soils are inhaled, ingested, or contacted by skin.”
  SCLA SOIL TESTING Project CC12-041
• On 1 October 2007, the Air Force placed the following conditional use clause in the George AFB Family Housing quitclaim deed: “Grantee covenants and agrees that it will not use, or allow others to use, the Property for residential purposes (including mobile or modular homes), hospitals for human care, public or private schools for persons under 18 years of age, nursery schools, or day care centers for children.”
• As of 23 May 2015, the Air Force has failed to notify the former base personnel, their families, civilian employees, and the surrounding community of their exposure to potentially life-threatening environmental contamination at George AFB’s Family Housing.

George AFB Family Housing – CERCLA §120(h) Deed Restrictions – Pesticide Contamination

The Army and Air Force used the organochlorine pesticides to protect buildings (pre-1986) against ground termites and other pests at George AFB including the Base Schools, Family Housing, Barracks, and Dorms.

• The DOD and the Air Force failed to test for these organochlorine pesticides except at the Base Family Housing Units.
• The DOD and the Air Force failed to disclose the widespread use of these organochlorine pesticides in the CERCLA §120(h) Deed Restrictions as required by law except for at the Base Family Housing Units.
• The DOD and the Air Force failed to test the soils at the former George AFB Elementary School and George Junior High (Middle) School for dieldrin.
• The DOD and the Air Force failed to disclose that dangerous levels of aldrin and chlordane were present at the Base Family Housing Units in the CERCLA §120(h) Deed Restrictions as required by law.
• The DOD and the Air Force failed to disclose the widespread use of these organochlorine pesticides to the ATSDR for its 1998 Public Health Assessment for George AFB. When the ATSDR concluded that there were no completed exposure pathways, the DOD and the Air Force did not correct the ATSDR during the  Peer Review / Public Comments period or after the Public Health Assessment for George AFB was published in 1998.

The Air Force Misled the ATSDR about the Chlordane and Other Organochlorine Pesticides Contamination at George AFB

ATSDR Flawed Public Health Assessment for George Air Force Base, CA

In the 1998 Public Health Assessment for George Air Force Base the ATSDR made the following statements:

“ATSDR did not identify any completed exposure pathways from George AFB to children at nearby schools or residential areas.” Page 27

“Soil at George AFB does not represent an apparent past public health hazard and does not represent a present or future public health hazard.” Page 28

See: Public Health Assessment for George Air Force Base, CA – ATSDR – December 1, 1998

The Air Force deliberately misled the Agency for Toxic Substances and Disease Registry (ATSDR) about the extremely high levels of organochlorine pesticide contamination at the George Air Force Base Family Housing.

The ATSDR relied on the Air Force to supply ATSDR with the relevant documents and information for the Health Assessment for George AFB).  Because the Air Force did NOT supply the relevant documents and information to the ATSDR, the ATSDR did not fully understand the nature and extent of the contamination at the Base Family Housing. The Air Force knew that the ATSDR came to a flawed conclusion in their 1 December 1998 report “Public Health Assessment for George AFB,” section “Evaluation of Potential Public Health Hazards at George Air Force Base” and Exposure Pathways at George Air Force Base.

Because the Air Force did not correct the ATSDR during the Peer Review / Public Comments period or after the report was published in 1998, the Air Force lied by omission.

George AFB’s Burn Pits and Incinerators

The Department of Defense (DOD) and Air Force failed to notify the Agency for Toxic Substances and Disease Registry (ATSDR) of this potential exposure pathway for the Public Health Assessment of George AFB.

George Air Force Base had over a dozen of open-air burn pits and two old style incinerators (without an air scrubber to remove toxic chemicals).  The known carcinogens and respiratory sensitizers that were released into the atmosphere by the burn pits and incinerators present both acute and chronic health hazards to civilians, and military personnel and their family members.

A list of possible contaminants includes: acetaldehyde, acrolein, arsenic, benzene, carbon dioxide, carbon monoxide, dichlorofluoromethane, dioxins, ethylbenzene, formaldehyde, hydrogen cyanide, hydrogen chloride, hydrogen fluoride, various heavy metals (lead, cadmium, and mercury), nitrogen dioxide, phosgene, sulfuric acid, sulfur dioxide, toluene, trichloroethane, trichloropropane, and xylene.  See: Burn Pit Health Hazards Memo

George AFB’s Open-air Burn Pits

On 20 December 2015, a search of the George Air Force Base Administrative Record produced a list of 180 documents that contain the term “burn pit”.

Old Incinerator Building

There are four references to an old incinerator building in the administrative record.

“… Herbicides and other pesticides were stored in the old incinerator building near the sewage treatment plant until 1968…” AND  “… Pesticides were originally stored in the old incinerator building until 1968…”

– Phase I, Records Search Report, Vol I of  II
CH2M Hill – Jan 82
AR/IR File Number: 3

– RI/FS, Draft Work Plan Addendum, OU-3
James M Montgomery, Inc. – Jan 92
AR/IR File Number: 525

– Draft Final Work Plan Addendum, Vol I of II, OU-3
James M Montgomery, Inc. – Apr 92
AR/IR File Number: 572

– RI/FS, Final Work Plan Addendum, Vol I of II, OU-3
James M Montgomery, Inc. – Jun 92
AR/IR File Number: 613
Source accessed on: 14 July 2012

Hospital Incinerator

“The hospital incinerator was active from 1963 to 1992; however, in 1989 the incinerator was inoperative and sharps were burned at the fire training area (IRP Site FT-i 9). In the past, hospital wastes were disposed of and burned at a waste burn pit at the fire training area. This area has been designated IRP Site FT-i9 and is currently undergoing an Rl/FS .” (see Section 3.3.2)

– Basewide Environmental Baseline Survey (EBS)
HQAFBDA/SP – Dec 93
AR/IR File Number: 817
Source accessed on: 14 July 201

Frank Vera
www.GeorgeAFB.Info
www.BaseFamilyHousing.Info

cc: [email protected]; [email protected]; [email protected];  [email protected]