Loading...
HomeMy WebLinkAboutCOM 1210.025 2006-2008 3 There are four reports covering 1) Burning at SB 2) Scoping at all sites 3) Health Risks at SB and 4) Final Characterization. I always assumed that the purpose of the survey was to examine the quantity, distribution and type of DU weaponry used. This survey should be designed to look beyond the reports (of Davy Crockett's, DC) to see if penetrating DU weapons were used. Penetrating weapons pose a special health risk due to the high levels of airborne DU products including DU oxides. The non-soluble chemistry of inhaled DU oxides leads to very slow clearance (decades) from the body and dissemination throughout the lymphatic system. One should not extrapolate health effects between soluble DU products and DU oxides. One should not do environmental surveys focusing on health threshold criteria (especially using inappropriate soluble forms, especially looking at after-the-fact residuals left on the ground). Rather one should look at raw data to see if the areas are contaminated with DU which would implicate PAST health risks. Besides the quantity and type of contamination one should look at a representative geographical distribution to see if the contaminated areas exactly correlate (or not) with what is felt to be DC ranges. The latter should be based on criteria which is historical, remnant, topographical but NOT radiologic. In general can anyone say for sure that penetrators were not used (in addition to DC) based on these study results? Comments/Questions: Rpt #1 uses U238:U234 ratios and clearly shows that the targeted burn site was highly contaminated with DU. Why was this type of data not reported in the fourth study - especially at the reference site (Wheeler Base)? One would like to know if the "reference" site has DU. It would be impossible for DC to contaminate such a site but Penetrator smoke/dust could. Rpt #1. For air sampling the numbers are too small for statistical analysis especially when so many counts are below threshold (MDC). To increase the "sensitivity", more data points from burns are needed (there were samples form 7 hour burns compared to the usual 60 minute samples) . As above - the argument that health threshold levels are not exceeded is questionable with DU oxides. Rpt #2 had too many obstacles for reasonable interpretation. But problems with the design are evident. Why was there no far upwind reference (control) site chosen? Was the reference site truly non-contaminated wrt levels of radiation and the U238/U234 ratio? It is a poor representation of the site if one only takes soil samples based on an algorithm of first sighting piston remnants. The fourth study attempts a better systematic survey. Even with minimal data the sightings of many pistons and negative perimeter data (PTA) shows that perimeter data is not sensitive. Where there was one known high soil sample the perimeter data was not done (SB). Rpt #3 The focus is only on present and future health risks. As above the analogy is like looking for health risk of smoking by only looking at health risks of ashes. What were Comm. ~Z14.2 ur! / Ref. To Ref. Date ;1 9 2008 the PAST risks if penetrators were fired? Even if there are only DC remnants - aren't many of the DU particles now in the oxidized forms? How does one predict the future risks without knowing future activities? As stated in the report, even the PRESENT/FUTURE health risk are based on soluble DU compounds. Inhaled, non- soluble DU health risks are not known (references of the report). Rpt #4. I have not accessed the appendices. It is not clear if we are only sampling within the DC ranges (M-79) - or if a general survey is intended. If the latter, were a lot of high radiation sites detect outside of DC sites as determined by evidence excluding radiation readings (gamma readings)? The inclusion of gamma readings as a criteria of a DC site definition ("judgement" samples) would lead to a self-fulfilling prophesy that only DC sites had high readings. As above an upwind controls site would be useful. Compared to the control site with 2.5% exceeding the cutoff of 2.57 PiC/g (2 Standard deviations), 31 of the 318 judgement samples above this level is noteworthy (what is basis for statement on 6-1, last Paragraph claiming similarity of judgment and reference sites?) Of the 31 high readings are they all surface samples (in which case the denominator should be nearer to 165)? What is the algorithm distinguishing systemic vs judgment sites? What were the U238:U234 ratios of the 31? Were they associated with DC remnants? Can one calculate the total SB load of DU radiation based on judgement sampling (is it representative?)? Does this load exceed what is compatible with the DC records? Lorrin Pang, MD, MPH Retired Army Medical Corp Preventive Medicine Boards 1990 America's Best Doctors List 2006-8 Pentagon fights EPA orders to clean ha,zardous vast- . _ . The ll sites include ndsubstantial risk to public cleanup contracts. Those eight the Arizona missile plant, which one at a Na antenna 1 ealth and the environment. To "The department, at different facilities are in Massachusetts, has been on the EPA's Superfund date, the Pentagon has agreed to levels and times Virginia, Maryland, Alabama, list since 1986. The other U sites ~ station in Wahiawa o omply with only one of those ' has New Jersey, Florida and Hawaii. were put on the'EPA's list of most n©I orders, at an Air Force missile exhausted every available The Hawaii site is the Naval polluted sites in the country in BY DINA CAPPIELLO ' plant near Tucson, Ariz. avenue with EPA to resolve Telecommunication Station at the 1990s Associated Press In separate letters in May to Lualualei, which was put on the "There is not a stoppage of these issues. government's Su erfund list in WASHINGTON - The De- the White House budget office P work because we have not signed fense Department is refusing to and the justice Department, Pen- wAYNE ARNY Deputy 1994. these agreements," Davis said. comply with orders or~n tagon officials challenged the undersecretary of defense "The department, at different The Defense Department has tracts to clean up 11 hazardous EPA's authority to issue orders levels and times, has exhausted entered into contracts for 123 of waste sites, including one in under other environmental laws every available avenue with EPA the 135 Superfund sites it owns - Hawai`i, and has asked the White to force Superfund cleanups at D-Calif:, agreed yesterday with a to resolve these issues," Wayne than any other entity in the Souse and Justice Department Air Force bases in New Jersey request by Maryland's two De-. Arny, deputy undersecretary of more The contracts set for- to intervene on its behalf. and Florida and at the Army's ' mocratic' senators, Barbara defense, said in a May 14 letter to country. schedules and allow the EPA The dispute between the Pen- Fort Meade in Maryland. The Mikulski and Benjamin Cardin, White House budget officials. mal tagon and the Environmental Defense Department dismissed to hold a hearing on the Penta- The letters were first reported to assess penalties if deadlines Protection Agency has simmered the EPA's claim that soil and gon's noncompliance with the by The Washington Post. are missed. Although law favors over the last year since the EPA groundwater pollution at the EPA's orders. Tad Davis, the Army's deputy the EPA in disputes with other began issuing orders compelling three bases was dangerous At eight other Superfund sites, assistant secretary for environ- agencies over cleanups on federal the Air Force and Army to clean enough to warrant such action. the Pentagon is objecting to "ad- ment, said in an interview property, the Pentagon is asking up four properties where con- Senate Environment Commit- ditional provisions" that it says yesterday that cleanups are pr_o the justice Department and tamination poses an "imminent tee Chairwoman Barbara Boxer, the EPA added to proposed dressing at all 12 sites, including ' White House to take its side.