2000 CPEO Military List Archive

From: CPEO Moderator <cpeo@cpeo.org>
Date: Tue, 6 Jun 2000 16:03:14 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] Cutler PCB Cleanup
[This was posted to the list by Ron Huber, <coastwatch@acadia.net>]

For updated information on this issue, contact Steve Crawford at 
(207)853-0982 or by email at <phaedrus@telplus.net>

By Ron Huber

Downeasters report progress in their efforts to block a US Navy's plan 
to use high pressure water jets to  blast PCB -laden paint from dozens 
of its radio towers in the  NAVCOMTELSTA communications  complex 
overlooking the intertidal clamflats and fishing grounds of the Cutler 
Coast of downeast Maine.

The Maine Department of Environmental Protection (MDEP) has agreed to 
reconsider its earlier tentative approval of the Navy's  water-jet paint 
removal method, which was halted in the late '90s after soil  analysis 
revealed a PCB contamination level of  25,000 - 50,000 ppb in soils near 
one of the  towers, The towers are emplaced as close as 50 yards from 
the shore.

The towers are surrounded by mudflats  that are routinely dug  by 
clammers,  who have documented the presence of paint chips on the 
mudflats. and wetlands used both  by migratory birds and as feeding 
areas for residen redtail hawks, eagles, other birds, foxes, 
short-tailed shrews, other mammals, and countless insects of which all  
become food for each other over time.

The Cutler base also hosts one of the Navy's six  "Ecological Reserve 
Areas " around the USA. The Navy defines an  Ecological Reserve Area 
(ERA) as "a physical or biological unit in which current natural 
conditions are maintained insofar as possible."    One cannot imagine 
PCB deposition as consistent with maintaining "natural conditions"

 Cutler Naval Station website: www.norfolk.navy.mil/cutler/index.htm

Oddly, Maine DEP's  permit reviewers have chosen to disregard their own 
regulations that  allow for ZERO  per cent discharge of PCB's into the 
environment during cleanups and had given a tentative initially gave the 
Navy permission to use this technique.   Maine DEP also is ignoring its 
regulations requiring a state permit to carry out any process that 
creates "point source  contamination".      

Maine  DEP is asserting  that no permit is required,as the Navy has 
promised to return the habitat to the pre-cleaning state after paint 
removal was finished.   The Navy has not informed Maine DEP or area 
residents how wetlands and intertidal flats on and around the base, 
which will receive a rain of PCB laden water during the operation, would 
be cleaned and the habitat restored.

Federal environmental laws also requires 100% containment of PCB 
contaminated products during clean-ups. Yet the US EPA too approves of 
the Navy's claim that "only" 15% of the paint chips atomized by Dod 
water jets would end up in the ecosystem. 

 US EPA's Northeast Region supports proceeding with the water jet paint 
removal,  without testing, asserting that removing the  paint  as fast 
as possible will end the danger of the chronic leakage of PCs into this 
rugged area's natural coastal environment.   

But area residents are opposed to this quick fix. They say state and 
federal regulators are giving too little thought to how much 
environmental damage the PCB releases would have.  

Marine ecology consultant Stephen E. Crawford of Eastport-based 
International Marine Resources, a leading opponent of the water-blast 
method,  wrote"I can think of no better mechanism of introducing PCB's 
into the environment around Cutler than to reduce the paint chip 
particle size to 2.5 - 30 microns and jet blast it at 35,000 psi into a 
mist from towers that are up to 980 ft tall."

Crawford agrees that dealing with the flaking paint is necessary, but 
asserts that  the critical factor is to maximize the amount of PCB's 
captured and prevented from escaping into the environment. 

"The paint particles should be kept as large as possible" Crawford wrote 
in a recent letter, " so that they can be easily collected: this means 

Has the Navy sampled the areas for PCB's? No.  They conducted a 
"theoretical statistical study" and determined that wind direction and 
other factors indicated that no contamination would occur. 

Asked if there was any plan to sample clams, mussels, etc, again the 
Navy's answer was no. 

Re-startup of the paint removal project, initially slated for May 1st, 
has been delayed until Maine DEP carries out baseline monitoring of the 
present level of PCBs in the mussels and clams presently residing in the 
area's intertidal zone.
But Maine DEP cannot conduct the survey until July at the earliest, and 
Navy officials are in a rush to get the job started.   The DEP has 
partially caved to the federal government and supports having an 
independent entity monitor the paint removal;  if too much escapes, the 
project would be halted. 

The military claims that hand scraping is too costly and may cause 
damage to the towers' galvanized coating, though it was noted  that when 
the towers were re-painted in 1966-67, they were hand-scraped without 
harm to the towers.

While a hand scraping effort while add time to the repainting project, 
Crawford noted, "my position is that this method will be the safest for 
the environment.  The PCB's are very tightly bonded in the paint chip, 
with a half life of 50 years.  Techniques are available to collect most 
of the paint chips: these have been developed by contractors removing 
lead-based paints from bridges."

NOTE: An 'environmental defense fund" to defray the cost of keeping PCBs 
out of the flats has been set up. Send your support to the Quoddy Spill 
Prevention Group, Inc, c/o Steve Crawford, 130 Water Street, Eastport, 
Maine 04631

 "Any financial help you can provide, from $5 to whatever will make a 
difference."  Steve says.  Please make your check out to Quoddy Spill 
Prevention Group; indicate in the memo section of the check that the 
donation is for the Cutler Tower Project.   

For updated information on this issue, contact Steve Crawford  at 
(207)853-0982 or by email at <phaedrus@telplus.net>

Ronald Huber,   Executive Director
Task Force Atlantis
418 Main Street
Rockland Maine 04841 USA
(207)594-5717  email coastwatch@acadia.net
URL: Inshore: http://www.penbay.org
URL: Offshore:  http://www.atlantisforce.org 
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