To: Brian Helland, U.S. Navy Remedial Project Manager,
South Weymouth Naval Air Station(SWNAS) Base Realignment And
Closure(BRAC)
From: David Wilmot, Abington Massachusetts resident & co-founder,
research director of
AWARES (Abington, Rockland And Rockland Environmental Studies)
Re:
Public Comment for Proposed Capping Remediation of
WestGate Landfill CERCLA designated SuperFund Site.
Sir,
I wish to thank the Navy for extending the
Public Comment Period through July 6,2007 to allow myself and others the
opportunity to weigh in on this most grave error in judgement on the Navy's
proposed capping remediation of the highly contaminated WestGate Landfill
site.
Our communities surrounding SWNAS have for
decades served the Navy as hosts.
The Navy now proposes to reward us
and other downstream communities, by leaving the most toxic of the 11 designated
base SuperFund sites in place abutting Frenches Stream and adjacent wetlands, in
total disregard of our, our children's, and our future children's, health.
Just today the Boston Globe reports that
"statewide Autism rates have nearly doubled in the past five years. I have no
doubt that a stunning rate occurrence would be in the proximity of toxic waste
sites, industrial sites and current and former airport runways in Massachusetts,
and nationwide. There is a small street abutting SWNAS where six of the eight
homes on the street, at one time housed autistic children. I don't
believe in such coincidences.
How does the Navy, or any factions of our
government find it morally responsible to ignore the growing reams of evidence
linking the exploding incidences of chronic health problems to chemical
exposure?
These are truly dark times for our floundering
democracy. Those of us living in blue collar neighborhoods like mine, urban
neighborhoods, rural neighborhoods or Native American neighborhoods in proximity
to current or former military facilities, are taking on a great incidence of
environmentally-triggered diseases, in most cases, without their knowledge.
There is no "Justice for ALL" in this country. The Department of Defense has a
stranglehold on America's Public Health and Environmental Protection
initiatives. This is most especially true of Americans not fortunate enough
to live in the "best" neighborhoods.
I've grown ashamed of being under this
current Administrations rule. Could our leadership be any more short-sighted in
terms of protecting America's Best Interests? I fail to see how.
Example of Gross Short-sightedness :
Proposed Capping of the WestGate Landfill CERCLA (SuperFund
designated) Site.
Frenches Stream is a known headwaters of the
North River Watershed. This is an important watershed
resource for all of Southeastern Massachusetts. This is especially true to
water-starved towns like the one I live in.
Recent efforts to get a copy of the
Geochemical Stream Assessment have been unsuccessful, but I do know firsthand
the following:
Close Examination of Frenches Stream as
it exits the former base would prove it to be lifeless.
I fail to see how the Navy and involved
Federal and State regulators can award a "No Ecological Risk" assessment to a
Basewide Watershed Study where in Frenches Stream downstream of the WestGate
Landfill, no fauna exists to access.
As the stream enters the base
from Thompson's Pond in Abington, it is alive with the fish,frog and
macroinvertibrate creatures representative of a healthy benthic animal
community.
When leaving SWNAS downstream of the
WestGate Landfill, the stream is devoid of life, a metal-choked, orange
flocculent stained stew of military released toxins, flowing through our
communities, and
for decades, depositing contaminated sludge in the wetlands that are
contained within the Frenches Stream floodplain.
The Navy finds no necessity thus far in
doing any testing for contaminants in adjacent base property wetlands prior to
closing this landfill, or the responsible testing that should be mandated in all
adjacent wetlands outside the base fence. This is irresponsible towards
protecting the Public Health of former host communities. EPA and USGS testing
conducted during the Old Swamp River Investigation proved that migration of
airbase-released contaminants pool in adjacent wetlands. The Navy continues to
cling to the already dis-proven statement that "contamination has not migrated
off base property". Statements such as this are completely irresponsible! How
does the Navy justify this lack of responsible oversight?
The Navy finds no necessity in finding out what
became of the disposal of 30+ years of toxic coal-burning power plant coal ash
and flyash.If you ask many former sailors formerly stationed at the base how
things were disposed of they tell me "we just dumped it in the river" or "we
dumped it out in the woods" or "in the swamp". The Navy is now assuming their
only toxic legacy is in a set number(11) of denoted Superfund sites such as the
WestGate Landfill. Even on these known highly contaminated sites, we are
supposed to approve of their lowball method of cleanup.How does the Navy justify
the lack of complete examination of the property being returned to the private
sector?
Our children, and some of us somewhat older
people, play in these streams and swamps! The Navy is grossly irresponsible in
proposing this toxic landfill stay in place atop wetlands that without complete
removal has the potential of endangering so many!
How does the Navy explain this gross
oversight in BRAC process?
The Department of Defense and
controlling Federal and State regulator Leadership downplay the known need
for adaptation of precautionary principles in addressing toxin cleanup.
It's true that adverse health effects from
toxic exposures may take decades to manifest themselves in tangible diseases,
but with all the currently emerging science linking chemicals and chemical
mixtures to adverse, chronic health outcomes, it's long past time that the
United States Navy and the Federal Department of Defense(DOD) spend the money
required to DEFEND the public health of former host communities, and those
others downstream.
As it is has been with Global
Warming, our government lags behind the rest of the world in addressing the need
for toxic substance remediation. The wastes that now sit atop the SouthShore's
water supply, should be moved to a National Depository under a dry desert
state, or perhaps in the future on the Moon or Mars. The current
military-industrial complex should be looking beyond their current
financial dictates towards the future. Most financial powers in place prohibit
rededication of any part of their amassing wealth to address the serious changes
necessary to sustain life on this planet.
The Navy and DOD need to rededicate a
like portion of their massive budgets towards protecting the public health of
the Americans they are sworn to protect.
This country is in dire need of
change.This BRAC process ongoing on the former SWNAS is in dire need of change.
All across this country former military properties, through the use of
irresponsible "Covenant Deferral Requests" and "Early Transfers" are being
passed into the eager hands of waiting developers where Superfund mandated
cleanups are being entrusted to companies driven to maximize their profit
margins.
Former host communities
citizens in most cases unknowingly suffer increased health burden.
The National Health System suffers, as we
live longer, yet sicker lives.
Our National priorities are grossly
irresponsible to future Americans.
Because in most cases our people are
unaware of the risks you are saddling them with, does not mean you are without
moral responsibilities to return the former military land and waterways in a
state of health to the best of your abilities. But, truth and justice here are
continually overlooked to force political and financial agendas, in lieu of
moral responsibilities!
Is the Navy aware of the preponderance
of autoimmune, among other, diseases in our neighborhoods?
Why did the Navy insist on withholding
health information of former military personnel, when the Massachusetts
Department of Public Health(MDPH) requested information for a study to establish
incidence of autoimmune disease in proximity to SWNAS?
This irresponsible lack of
cooperation, completely invalidates the results of years of work, and
facilitates the waste of tax payers dollars.Does the Navy hide behind the
Privacy Act as reason for their noncompliance? Given the fact that the MDPH had
no interest in publishing any personal information,how is this excuse in any way
valid?
As Mr. Gore points out boldly in the
title of his latest book, our democracy is suffering a great "Assault on
Reason".Eight years of my life trying to bring one man's well intentioned Reason
to this SWNAS BRAC process is stonewalled at every turn by politics and money!
Sound Reason is disregarded as so much bothersome rubbish. This is not how
democracy is supposed to operate. I'm sure Mr. Gore would agree.
How does the Navy explain their decision to
stonewall the MDPH study?
With diseases like Multiple
Sclerosis(MS), Lou Gehrig Disease(ALS), Lupus, Autism, and
many already proven environmentally triggered Cancers exploding in
incidence across the country, in many documented cases in proximity to National
Priority Listed SuperFund sites like SWNAS, how is the Navy able to reason that
saving 30 million leaving this toxic landfill in place located in wetlands
to perpetually release buried contaminants into the groundwater and surface
wetlands, is the prudent, responsible way to remediate this situation? I would
appreciate a detailed analysis of your decision, specifically addressing how
Public Health was factored in.
I tried what I could to
involve local health boards and in Abington the Town Manager and Selectmen in
this BRAC process, to no avail. Local government is afraid of lowering the real
estate market,and it seems local health boards are unprepared to look much
beyond dumpster placement and smoking restrictions in local pubs. Why has the
Navy made no stronger effort to engage local governing boards with the
Restoration Advisory Board meetings or the BRAC process at SWNAS?
A very recent
study by the Harvard School of Public Health reports that Chronic Illnesses
in American Children have nearly quadrupled in the past three
decades.
Some of this is surely due
to more sedentary lifestyle, lack of exercise and diet choices, but those things
do little to explain the great rise in birth defects, learning disabilities
and autism.
Why have teenagers
and 20-some-things, only in recent years been diagnosed been with
Multiple Sclerosis? Their numbers are growing around here.
Why has the DOD only
recently given the Veterans Affairs Bureau the right to classify MS and ALS
disability claims as "Service Related Disability"?
It has been proven in the
laboratory that Military JP-8 Jet Fuel is extremely toxic to the immune systems
of rats. Might the use of JP-8 Jet Fuel at SWNAS help explain the high incidence
of Autoimmune and other diseases in my neighborhood? All efforts to orchestrate
a combining of existing MDPH geographically-tagged Disease Data, with the
existing Geographical Navy Database in use at SWNAS, already containing the
geochemical and hydrogeographical data collected by the Navy and
regulators. This existing data could easily be augmented with
geographical placement of streams,runways, taxiways, warm-up pads and known
spills and fuel jettison areas to provide a geographical look at former
military exercises and possible effects on public health.
There is the
possibility we stand to learn things of global importance here! And yet,
I'm fought every step of the way.
How can our sworn
protectors validate their apparent fear of the truth? Please
comment.
Given the
DOD's apparently growing knowledge of military released toxic
substances adverse effects on human health, how can the Navy justify
prioritizing financial concern over people's health?
The Navy is not the only
culprit in this moral injustice.
The Washington decision
makers atop the Federal Environmental Protection Agency(EPA) also shares in
blessing this moral injustice taking place here and now.
Not the good people
involved here on the ground level, but the decision makers in Washington who
give them their marching orders.
The EPA made the decision
that our suburban communities would be aptly served by designating cleanup
levels to adhere to "Urban" level remediation standards. I would venture
that there are few living in our communities who would consider themselves
living in a city. I would also venture to say that more well-to-do
towns situated equidistant or less from the city, say Hingham or Milton,
would have the political power and legal wherewithal to fight
this unjust "Urban" tag from being affixed.
Knowing
firsthand how heated the remedial discussions between the Navy and the
regulators , both EPA and State Department of Environmental
Protection(DEP) often got, I wonder whether this "Urban" designation affixed to
our suburban communities, was in any way the result of debate with the
Navy's position on expected cleanup levels and costs?
I would appreciate
the Navy commenting on this.
I also hold
the EPA responsible for establishing Background Levels for comparative
analysis of tainted sites vs. "naturally occurring" levels of mediums from
samples of soils, waters and sediments collected directly on the
base. Subjected to 50 years of military aviation exercises, I will never agree
that any part of the base should carry a tag of "naturally occurring". Again, I
would ask the Navy if their position on costs played a role in establishing of
"Background Levels" establishment?
I know that the DOD
insists that the "Lead Agent" in BRAC processes is an appointee from
the military. Does the "Lead Agent" carry enough power to dictate all
remediation parameters and protocol? Please illuminate the power wielded by the
appointed "Lead Agent" in a "Memorandum Of Agreement(MOA)" during a BRAC
military environmental remediation? I question whether this "Lead Agent"
designation gives a crippling disadvantage to the agencies responsible for
protecting the environment and public health.
The federal
EPA is likewise responsible for keeping the cleanup levels of individual
chemicals, metals and other toxic substances, updated to the evolving
findings of sound science. Environmental Protection is by definition a proactive
precautionary function.
The EPA
announced five years ago that the model used to calculate each
substance minimum cleanup level(MCL) was flawed, as it had been devised
using an Average 160-180 pound man as a constant in it's calculation of
chemical health risk. The EPA further stated that children would be in many
cases at least ten times as susceptible to chemical assault from standardized
model in use. Those EPA MCL's have yet to be enforced. I have to assume the
political climate and the DOD's position in it, has thus far held up the
responsible update of parameters. Is the Navy sworn to uphold MCL's as devised
by the EPA?
How can Neurotoxic
levels of Manganese, as well as other metals, for instance Hexavalent
Chromium, be allowed to flow out of SWNAS with the complete blessings of the
EPA? As one of the many folks around here suffering from a neurological
disease, I would once again ask for comment from both the Navy and EPA? If you
need to kick that question upstairs, feel free, but for once please give me a
reasonable response to my question.
Given
the inevitable "no apparent health issues" rubber stamp that the federal
Agency for Toxic Substances and Disease Registry(ATSDR) constantly bestows on
CERCLA mandated BRAC Public Health Assessments, I would be dumbfounded to
find out that this agency was not fully controlled by the DOD. Please supply
ATSDR's final assessment of the WestGate Landfill.I am assuming of course that
they had some input and final assessment prepared before the Navy decided on a
Final Proposal. Please share what if any involvement ATSDR was afforded in this
finalization.
I'd also be very interested in learning how ATSDR finds it in any way
responsible to not release the results(albeit partial,with the Navy's previously
cited lack of information release) of the MDPH MS-ALS Incidence Study they are
holding in "necessary peer review". I myself was instrumental in getting that
study off the ground here, and I resent what I can only assume is politically
mandated foot dragging, in presenting timely results, while development plans
and efforts proceed without benefit of collected data.
All
these issues bring questions to the argument of whether the DOD and it's BRAC
process, holds responsible public health remediation in a perpetual
stranglehold, away from basic human rights moral responsibilities. I would like
to ascertain in detail how the Navy used the multi-faceted
Final Remediation Derivation technique to settle on their selected method?
I need to be shown clearly that cost alone wasn't the only factor in the
derivation.
After eight plus years of intense involvement in this BRAC process at
SWNAS, I can't help feeling like this much touted "Public Process", Is a
great waste of the Public's time. Even our most reasonable well-researched
opinions and findings are perpetually ignored or disregarded.
The
WestGate Landfill given all I've learned about it, was used as a catchall for
decades of military waste disposal. Given the little regard for the environment
practiced in those decades of use, a toxic legacy should be deemed by
thinking, responsible authorities,as warranting complete removal from atop a
wetland capable of perpetually distributing leeching toxins to an unsuspecting
populace with children.
I
ask the Navy in all sincerity, to reconsider the alternative of total removal.
An already well-recognized floundering national health care system,
can ill afford greater future increases of chronic disease occurrences. It is
time for the factions of the Department of Defense to use a
greater and responsible portion of their allotted resources to Defend
the Public Health and protect what should be the inalienable rights of All
Americans.
David Wilmot
10 Arch St.
Abington, Massachusetts 02351
(781) 878-4110