2002 CPEO Military List Archive

From: olah@speagle.com
Date: 30 Jan 2002 21:34:39 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] CSWAB: Media Announcement
Citizens for Safe Water Around Badger is pleased to announce...

    The Legacy Project

            If we love our children, we must love the earth.

Risk-Based Cleanup of Military Toxins

As costs to operate and maintain its closing bases increase, the U.S.
military is looking for ways to minimize environmental cleanup costs,
control potential site liabilities, and expedite transfer. Currently 
72,000 of the 440,000 acres of BRAC (Base Realignment and Closure) 
property to be transferred out of the Department of Defense are in the 
"unsuitable" category due to the need to address environmental cleanup 

In some cases soil and/or groundwater on these properties may contain
residual contamination below federal cleanup standards but at levels 
higher than "pristine" levels Local Reuse Authorities and nearby 
communities may demand. In other cases, properties contain unexploded 
ordnance (UXOs).

Consultants working for the U.S. Army have advised Congress that EPA's
Brownfields initiatives are and will continue to be an important 
mechanism to reduce cleanup costs specifically in their role to "promote 
risk- based cleanups". EPA, as the primary administrator of Superfund, 
has historically mandated stringent standards for cleanup without regard 
to current or future intended use of the property. These standards often 
required cleaning up to "background" levels or levels that allowed for 
unrestricted use of the property. Such cleanups, the military 
complained, were too costly.

The majority of cleanups conducted in recent years under the EPA's
brownfield standards are "risk-based" closures that permit some
contamination to remain in place and rely on the implementation and
stewardship of land use controls. Such controls indefinitely restrict 
the use of the land and its natural resources.

Examples of land use controls include "institutional controls" such as 
deed restrictions that limit how the land is used. A deed restriction, 
for example, may eliminate farming or gardening as a potential future 
use if residual contaminants could enter the food chain or sensitive 
ecosystem. "Engineering" land use controls physically restrict access 
and include fences and landfill caps.

It's not surprising this stopgap approach to "cleanup" is cheaper for
polluters, including the military, but at what cost to future
generations?  What will be our legacy?

Why Clean isn't Clean Anymore

Current environmental regulations are aimed primarily at controlling
pollution rather than taking the preventive approach of limiting the 
use, production, or release of toxic materials in the first place. Many 
polluters use their influence to delay preventive action, arguing that 
the immediate expense of redesign to achieve pollution prevention is 
unwarranted in the face of any uncertainty about eventual harmful health 

For example, only a few years ago "clean closure" required that all
hazardous wastes were removed from a disposal or spill site. Due to 
pressure from industry and other corporate and governmental interests, 
the USEPA (U.S. Environmental Protection Agency) and state environmental 
regulators now allow some "limited quantities" of hazardous constituents 
to remain in the environment if the facility (polluter) can convince 
these agencies that the calculated level of risk to human health and the 
environment is acceptable, particularly when weighed against the 
short-term environmental cost of a true cleanup.

According to a May 16, 1998 memo from the National Director of EPA's 
Office of Solid Waste, "EPA's position is that the procedures and 
guidance generally used to develop protective, risk-based media cleanup 
standards for the RCRA (hazardous waste) corrective action and CERCLA 
(Superfund) cleanup programs are also appropriate to define the amount 
of hazardous constituents that may remain in environmental media after 
clean closure." In other words, "clean" no longer means clean and 
"safe"... it now means risk that is acceptable to government agencies 
and polluters.

Our Responsibility to the Future

The Earth and its ecosystems are the foundation of life and we have a
responsibility to protect and care for today's resources and 
opportunities for the benefit of generations to come. This means 
ensuring emissions of pollutants do not harm human health or exceed 
nature's capacity for absorbing or breaking them down. Persistent 
pollutants harmful to humans or the environment need to be eliminated as 
all living things should have access to pure water, clean air, and 
healthy food - free from environmental toxins.

The natural environment can only support human life, health, and well 
being if its own resources are healthy and if it can continue to 
assimilate wastes and support a wealth of biodiversity - our heritage of 
natural features, wild plants and animals, and their natural 
communities. Environmental pollution changes the physical, chemical, and 
biological characteristics of air, water, and land; these changes affect 
the health, survival, and activities of living things and contribute to 
the degradation and fragmentation of communities and ecosystems.

Children are in particular need of protection as their bodies are less 
able to cope with and detoxify harmful substances. Research in recent 
years has demonstrated that children and developing fetuses are 
especially vulnerable to health damage from toxic chemicals. Their 
organs and physiological processes are still developing and toxic 
chemicals can disrupt this development, causing long-term irreversible 

Children are more susceptible to the affects of pollution because the 
cells in their bodies are still developing at a rapid pace. The 
increasing burden of toxins in our environment coincides with a rise in 
childhood asthma, cancer and leukemia. Research has been ongoing since 
the '80's in an effort to understand the cause behind alarming increases 
in the rates of asthma and cancer occurring in our children.

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