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The Environmental Protection Agency issued a proposed standard to limit perchlorate in drinking water that will gravely threaten public health. The agency’s plan comes after a decade of delay and a lawsuit by NRDC compelling it to set a standard. Perchlorate, a toxic chemical that is a component of rocket fuel [and explosives], has been detected in the drinking water systems that serve up to 16.6 millions Americans. Even at low levels, it can present serious health risks to children and pregnant women. The following is a statement by Erik Olson, senior director for Health and Food at the Natural Resources Defense Council:
"... Millions of Americans will be at risk of exposure to dangerous levels of this toxic chemical in their drinking water. Fetuses and infants are especially vulnerable to harm from perchlorate. EPA has more than tripled the amount of perchlorate it now recommends allowing in water. Scientists recommend a limit that is 10 to more than 50 times lower than what the agency is proposing ...”
EPA is proposing a standard of 56 parts per billion [ppb] — more than 3 times its own previous limit of 15 ppb. State standards based on scientists’ recommendations set the limit dramatically lower — 2 ppb (Massachusetts) and 6 ppb (California). Perchlorate impairs hormone production critical to brain development. It has been widely used by the military and defense industries ... It is highly soluble in water, and can move quickly into ground and surface water when it contaminates soil. The EPA has revised drinking water standards since the 1996 amendments to the Safe Drinking Water Act, but this is the first new standard the agency is putting forward for an unregulated contaminant in more than 23 years.
Anne Hawke
NRDC
May 23, 2019
Agency Abandons Peer-Review
Process at Behest of Big Water
EPA’s scientists developed a sophisticated model that considers the impact of perchlorate on the development of the fetal brain in the first trimester when the fetus is particularly vulnerable to the chemical’s disruption of the proper function of the maternal thyroid gland ... In April, a consulting firm published a study critiquing EPA’s model. The authors acknowledged the model as a valuable research tool but did not think it is sufficient to use in regulatory decision-making due to uncertainties. Therefore, the authors concluded that EPA should discard the peer-reviewed model and rely on a 14-year old calculation of a “safe dose” that does not consider the latest scientific evidence and has even greater uncertainties ... In 2016, EPA developed a Biologically-Based Dose Response Model (BBDR) that focused on the third trimester and breast-fed infants. A peer review panel, convened by the agency, provided positive feedback but challenged the agency to focus on the first trimester when the fetus is most vulnerable to hypothyroxinemia.
In 2017, EPA rose to the challenge and refined the BBDR model for the first trimester after conducting a rigorous review of the science. It also drew on five distinct children studies showing a quantitative relationship between perchlorate exposure, low [levels of a thyroid hormone known as "free T4" or] fT4 and harm to the developing brain ... In March 2018, the panel gave what amounts to high praise coming from independent scientists convened to be critical of the agency’s work ... The American Water Works Association, a 501c(3) technical and education organization representing drinking water professionals and utilities that would be affected by the rule, funded a consulting firm, Ramboll, to evaluate EPA’s model.
The authors of the report ... proposed ignoring new, compelling evidence that perchlorate exposure during pregnancy harms the developing brain. Instead, they called for EPA to use an RfD [reference dose] developed in 2005 that was estimated using a study of healthy non-pregnant adults ... The authors’ conclusion is at direct odds with those made by EPA’s independent peer-review panel through a multi-year transparent public process, which acknowledged the uncertainties but deemed them adequately addressed by the agency’s model. The recommendations appear to be an unrealistic demand for perfection. EPA’s model represents the “best-available, peer reviewed science,” which the Safe Drinking Water Act requires EPA to base its decisions upon ... Therefore, based on our calculations, the RfD should be 0.03 µg/kg-bw/day – about 20 times more protective than the current reference dose.
Brian Barone (Agency Rep - DC Dept. of Energy & Environment ) provided an update on the Dispute Resolution between USACE, DOEE, and Environmental Protection Agency. DOEE and EPA do not want to rely solely on Land Use Controls (LUCs) as a remedy for the Spring Valley Groundwater issue. The Dispute Resolution process has paused at Tier 2 while USACE and the Partners discuss potentially conducting additional groundwater data collection. USACE agreed to move forward with a new round of sampling as a data gap study to identify any areas that may require more information for an assessment of remedial options at the site. The Groundwater data is now several years old at this point, therefore any decision made on remediation approaches would be based on old data. DOEE wants to see new data ...
The Comprehensive Environmental Response, Compensation & Liability Act (CERCLA) site directives state that LUCs should not be the first and only way to remedy a problem. Other remediation options should be implemented, and there are several different technologies available. That's why DOEE wants to sample to determine current levels and utilize additional geochemical parameters to help decide on the best remedy ... The plan needs to include a remediation that is known to be effective. The worst thing to do is spend a lot of money and not conduct the research up-front and have zero result. At this point, DOEE believes that Institutional LUCs are not enough ...
Allen Hengst (audience member): Let's say they conduct the additional testing and perchlorate is over EPA's forthcoming new standard, which might very well be lower than 15 parts per billion ... The Army doesn't want to clean it up. They don't care what the level is, they don't think it needs to be cleaned up. So, you're headed for Tier 1 and then the lawsuit, I guess. Because USACE is never going to give in on this. It's not up to them. It's up to the Department of Defense and they have perchlorate sites all over the country that they don't want to clean up ... Right now the hazardous locations are based on 15 parts per billion. If the standard goes down to 10 or 5 or 2 — or like California where it's 1 part per billion — you're going to have a lot more wells that need to be tested ...
Barone: If the first round of sampling is completed and a new standard comes out, another round of sampling can be conducted. Barone does not believe anyone wants to get to the point where the Partners say, "this is all taken care of," and then a new standard comes out and testing must be resumed ...
Hengst: EPA is coming out with a new standard and your 15 parts per billion is going to be ancient history.
Greg Beumel (RAB Co-Chair): If it's ancient history, we have two people sitting in the room right now who will then direct us to the new standard, okay? ... The Army Corps cannot conduct a year’s worth of quarterly tests until they start them.
Spring Valley FUDS
RAB Meeting Minutes
March 12, 2019 (pgs. 3 - 5)
Ensuring the community remains informed about the past military use of the area encompassed by the Spring Valley Formerly Used Defense Site [FUDS] is part of the overall Site-Wide recommendations developed to reduce risks to members of the community. That means that in addition to the cleanup activities, like removal of contaminated soils and investigations to find and remove potential buried munitions, the U.S. Army Corps of Engineers will also promote munition education and awareness in order to further reduce risks in the event a munition item is encountered. This will be through letters and brochures sent to all residents and institutions within the boundary of the Spring Valley FUDS once a year. They will include information about the 3Rs (Recognize, Retreat & Report) of explosives safety.
The Corps'pondent
December 2018 (pg. 1)
USACE Baltimore will engage with the community and conduct a continuing education program indefinitely ... Mailings will be sent to the community once a year in the spring with information about the boundaries of the FUDS, the potential possibility that a munition could be encountered, and instruction on what to do if a munition is found. The Department of Defense 3Rs explosive safety brochure has been customized for the Spring Valley site to include site-specific background information and photos of munitions found in Spring Valley from the WWI era ... The draft mailing documents have been reviewed by DOEE and EPA; no comments were submitted by the regulators. [Project Mgr. Dan] Noble invited the RAB to review the two draft mailing documents and submit comments by the next RAB meeting in early March.
USACE expects to address any comments and send out the first mailing at the end of March ... USACE must then inform and remind the public that the residual risk of finding munitions is an ongoing possibility in the area and what to do if a munition is found ... Noble explained that over the years there have been instances of what is termed "Amnesty Rounds," munitions that people have found, picked up, moved, and left in an obvious place for someone to find, instead of contacting 911. Sometimes the munitions have been anonymously brought directly to USACE. Munitions have been left at the USACE gate at the Federal Property; one was left out on the sidewalk on Nebraska Avenue alongside the AU Campus. Finding a munition can happen anywhere.
Spring Valley FUDS
RAB Meeting Minutes
January 8, 2019 (pgs. 9 -11)
Todd Beckwith [USACE Baltimore] said potential unacceptable risk for future receptors would occur if groundwater is used as a drinking water source in the future within Exposure Unit 2 — the area next to [American University’s] Kreeger Hall and adjacent to the Glenbrook Road disposal areas. The main contaminants of concern are perchlorate and arsenic ... Steve Hirsh [EPA Region III] and Kathy Davis [EPA geologist] explained that EPA would have been okay with anything other than “No Action” or “Land Use Controls" ... EPA would prefer to see the groundwater cleaned up, so the groundwater could be used as a potential drinking water source in the future ... Based on the Groundwater Feasibility Study, the Army Corps selected LUC/LTM [Land Use Control/Long Term Monitoring] as the preferred alternative. The preferred alternative is identified in the current Groundwater Proposed Plan (PP) ... Physical construction of treatment systems would be very challenging in this residential/campus neighborhood. American University has gone on record that AU is opposed to the installation of treatment systems on AU property …
Thomas Smith [community member]: Can you explain why AU would not want the installation of treatment systems? Is it because it is too big, or what? It takes up too much space, or what is the issue?
Beckwith explained that AU stated that AU did not have the space and had other plans for AU property ...
Mary Bresnahan [community member]: Yes, that is what I thought. If it is coming from their property, they should be willing to help out ... They do not want to take any responsibility at all? That is what it sounds like …
Mary Douglas [community member]: Is there any provision for adjusting this remedy if EPA lowers the perchlorate standards?
Beckwith explained that contingency would be a factor USACE would have to consider. He asked Steve Hirsh to share the status of establishing the maximum contaminant level (MCL) for perchlorate. Hirsh explained that EPA is under a court order to establish an MCL for perchlorate. He had no information on what the perchlorate MCL might be; the level might be below or above 15 ppb ...
Allen Hengst [audience member]: The problem is that under the court order which Steve just mentioned, EPA is supposed to come out with the new standard by December 2019. That is when you are still going to be in the area, that is when you are still going to be working with groundwater … [The MCL] is probably going to go down, it is not going to go up … In Massachusetts it is 2 ppb and in California it is 1 ppb. [In Spring Valley] you are talking about 15 ppb.
Beckwith: After receipt of the draft final Groundwater PP, DOEE [DC Dept. of Energy & Environment] submitted a formal request for dispute resolution under the Department of Defense (DoD)/District Memorandum of Agreement (DDMOA), … which includes provisions for a three-tier dispute resolution process: Tier 1 — Baltimore District Commander, Deputy Director DOEE; Tier 2 — Headquarters-USACE Environmental Division Chief, Director DOEE; and Tier 3 — Deputy Assistant Secretary of the Army for Environment, Safety & Occupational Health, DC Mayor. The Tier 1 meeting [was] held on November 5: USACE/DOEE reiterated their positions on this issue; DOEE offered an alternative to collect more data for current conditions or proceed to Tier 2 ...
John Wheeler [community member]: What happens if there is no resolution in Tier 3?
Beckwith explained that no resolution in Tier 3 is a possibility. DOEE is prepared to take legal action and may file a lawsuit.
Spring Valley FUDS
RAB Meeting Minutes
November 13, 2018 (pg. 14 - 22)
Soldiers test gas masks at AUES “man-test” lab (NARA)
Entering the [World War I] fray two years after Germany sparked the chemical arms race with a surprise chlorine gas attack in Flanders, Belgium, the United States Army had neither gas masks nor protective gear, and no capacity for producing or deploying chemical weapons ... To correct those deficiencies, the War Department set up a laboratory, initially under the civilian Bureau of Mines, called the American University Experiment Station. It began modestly with one building and fewer than 100 researchers. By the war’s end, almost 2,000 soldiers, scientists and civilians worked at the campus, which soldiers called “Mustard Hill” for the blister agent sulfur mustard.
Test trenches were filled in & land sold to developers (NARA)
The army leased nearby farmland for proving grounds, part of which the soldiers named “Death Valley” ... When the war ended, the scientists revealed they had developed a new weapon called lewisite, an arsenic-based blister agent ... Over the decades, developers turned surrounding land into an affluent residential neighborhood, transforming “Death Valley” into Spring Valley, in the northern section of the District of Columbia. The WWI legacy was largely forgotten until 1993, when developers dug up a cache of mortars, triggering a state of emergency, evacuations and a lengthy cleanup. In all, 141 munitions were found at that site ...
Hundreds of munitions have been hauled away, most of them from a handful of burial pits. Arsenic has been the most widespread chemical contaminant — the army has carted off thousands of tons of tainted soil and replaced it with clean topsoil. Sulfur mustard, lewisite and other chemical warfare compounds — as well as traces of the constituent chemicals that remain after the warfare agents break down over time — have also been detected and removed. Concerns about the health effects of chemical contamination among Spring Valley’s roughly 25,000 residents have long lingered over the cleanup, especially after a lengthy neighborhood newspaper investigation reported unusual illnesses and health problems among residents.
Theo Emery
New York Times
November 11, 2018
The Army Corps of Engineers told the Restoration Advisory Board, which is composed largely of Spring Valley residents, it drafted a feasibility study for cleaning dangerous ground water. The World War I era poison gas experimental station polluted the water in Spring Valley and parts of American University's campus. Dan Noble, who heads the Corps' Spring Valley project, plans to present a detailed cleanup plan at the board's next meeting in November ... Twenty-six Spring Valley property owners are requesting their lots to be surveyed for dangerous chemicals and munitions as early as possible ... The Corps plans to obtain rights-of-entry from owners of the remaining 65 residential properties it plans to survey ... Noble warned residents and members of the public not to touch anything that could be an old munition. Today, 100 years after they were made, they are far more unpredictable if handled than they were a century ago ...
Noble mentioned the Corps cannot force homeowners to give permission to check out their properties. However, if there are grounds to believe something is dangerous, the Corps can ask the Environmental Protection Agency for permission ... Later this fall, the Corps intends to mail a brochure describing its plans and the history of the project to approximately 1,500 property owners and affected institutions such as American University and Sibley Hospital. American University will be in charge of distributing the brochures to its students and employees.
This fall, the Corps hopes to begin contaminated soil removal and restoration at the Spaulding-Captain Rankin Area [4710 Woodway Lane], adjacent to the southern end of American University. It also tentatively plans to remove any dangerous soil underneath the foundations of the university's former Public Safety Building, which was recently taken down ... Peter deFur, who announced he is retiring as a technical advisor to the cleanup project after 16 years with the board, said there was a "disposal area" for waste materials during World War I at one end of the former building.
Davis Kennedy
The Current
September 26, 2018 (pg. 1)
The Army Corps of Engineers has begun efforts to find and clean up potential explosive and chemical hazards on 91 privately owned Spring Valley properties that might be affected by contamination from World War I-era munitions activity ... The Spring Valley cleanup encompasses about 660 acres that were used by the federal government for research and testing of chemical agents, equipment and munitions. The project began in 1993, when a contractor unearthed buried ordnance. The Corps is currently focusing on those 91 private properties and 13 lots owned by the federal and District governments ...
Mary Bresnahan, a [Restoration Advisory Board] member and Long & Foster realtor, said some real estate agents simply refuse to deal with Spring Valley properties within the area of concern. When a realtor does show a property there, Bresnahan said there is a standard warning sheet that must be given to prospective buyers. Some buyers, she added, often get a property for considerably less than it would be worth in a nearby area. "I was shocked at a property, that was worth about $1.5 million that sold for $200,000 less," she said. In recent months, work crews have excavated arsenic contaminated saprolite from the lot at 4825 Glenbrook Road. That lot, owned by American University, was the site of last summer's worker exposure.
The remainder of the work at the site is governed by a plan requiring protective gear and air monitoring. Work will be performed only when the temperature is under 75 degrees and there will be no hand digging ... [Project manager Brenda] Barber said the Corps has excavated soil samples from 12 boreholes through the concrete slab under the foundation of American University's recently demolished Public Safety Building and nothing dangerous was found in the 79 samples. Once the gas utility line is rerouted, the concrete basement slab will be removed. The Corps hopes to remove any contaminated soil and backfill the area in December.
Davis Kennedy
Northwest Current
August 7, 2018
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