[CPEO-MEF] Statement on DoD's RRPI proposal

[CPEO Moderator <cpeo@cpeo.org>]

The following was submitted by Cal Baier-Anderson, Ph.D.
<cbaie001@umaryland.edu> in response to DoD's Readiness and Range
Preservation Initiative (RRPI) proposal
_____________________________________________________________

Statement of Cal Baier-Anderson, Ph.D.

University of Maryland, Program in Toxicology
Technical Advisor to Aberdeen Proving Ground Superfund Citizens
Coalition

cbaie001@umaryland.edu

May 1, 2003

I am a toxicologist with the University of Maryland, Program in
Toxicology.  The Program in Toxicology provides outreach and technical
support to communities faced with contamination issues.  Since 1999, I
have worked with the Aberdeen Proving Ground Superfund Citizens
Coalition (APGSCC), assisting them with cleanup issues at the Superfund
sites at Aberdeen Proving Ground.

Aberdeen Proving Ground, an active Army military base since 1917, has
left the city of Aberdeen’s wells tainted with perchlorate, a primary
ingredient in rocket fuel, fireworks, and munitions.  The perchlorate at
Aberdeen comes from smoke bombs and other munitions that are used in the
operating range above the well field.  While working with APGSCC, I’ve
become familiar with perchlorate’s toxicity and the scientific research
on its adverse and irreversible health effects.

Currently, the Department of Defense is pushing Congress for exemptions
from the very environmental laws that would require it to clean up the
perchlorate contamination.  In my professional judgment, DoD’s proposal
would jeopardize the health of millions of people, from Aberdeen,
Maryland, to Lake Mead, Nevada, to Rancho Cordova, California.  As a
scientist, I urge Congress to reject DoD’s proposal.  The DoD has a
legal and moral responsibility to clean up this dangerous chemical.

The city of Aberdeen, Maryland receives almost all of its drinking water
from 11 wells that draw water from a shallow aquifer that straddles
Aberdeen Proving Ground (APG).  Seven production wells are just outside
of APG property, while four wells are actually on APG property.  Within
the aquifer, a perchlorate plume of 24 parts per billion has been
detected.  Recently, perchlorate has been detected in the finished water
that is distributed to the
community.  In an effort to keep perchlorate concentrations in the
finished water as low as possible, 4 wells have been shut down.  With
this action, the city has been forced to purchase additional water from
Harford County to meet the needs of the city of 14,000 people.

The city has responded in this manner, because of perchlorate’s toxicity
and adverse health effects.  Perchlorate inhibits the transport of
iodide into the thyroid.  Iodide is necessary for the production of
thyroid hormones, which are essential for numerous biological activities
throughout our lives.  From reproduction, to the neurological
development of the fetus, to metabolism and cardiovascular health,
thyroid hormones play an important role in our health and well-being.

Consequently, there is special concern for pregnant women and for
newborn babies.  We know that thyroid hormones are essential to fetal
and new-born brain development.  The thyroids of developing babies do
not have the capacity to store thyroid hormones. Since perchlorate is a
salt, we would expect it to pass through the placenta and into the
bloodstream of the fetus.  We are also concerned for the newborn,
ingesting perchlorate either through formula made with
perchlorate-contaminated water, or through the breast milk of women
drinking perchlorate-contaminated water.

In January 2002, the US EPA issued a Draft Risk Assessment for
Perchlorate. The EPA analyzed the available laboratory animal data and
developed a sophisticated computer model to help predict the likely
distribution of perchlorate from the drinking water within the human
body.  Based on the results of their analyses, the EPA recommended a 1
ppb limit for perchlorate in the drinking water.

There are flaws in these risk assessments, but many scientists, myself
included, believe the number developed by EPA is less protective than it
ought to be.  Nevertheless, DoD is doing everything within its
considerable political power to suppress these findings.

DoD has estimated that the cost of cleaning up perchlorate to the levels
suggested by EPA could cost the military, and the manufacturers of the
chemical – such as Kerr-McGee and Lockheed Martin – some $3 billion.  In
a desperate effort to sidestep these costs, DoD and the companies have
been using “disinformation” to deter an honest debate about the science
on perchlorate.  For instance, DoD claims that the EPA risk assessment
is based on a single study.  This statement is false.  The EPA risk
assessment is in fact based on numerous laboratory studies and considers
human epidemiological studies, as well.

DoD alleges that the laboratory data is flawed, but most of the
laboratory data comes from DoD researchers.  Furthermore, the results of
the many DoD laboratory studies are upheld by the results of research by
disinterested parties.

DoD also contends that, since perchlorate has been used as a medicine,
it must be “safe” at high levels.  While it is true that perchlorate has
been used as a medicine to treat individuals with over-active thyroids
(e.g., Graves Disease) this certainly does not mean it is universally
safe to consume in our drinking water.

On the basis of these profoundly flawed interpretations of available
science, DoD has successfully threatened EPA into withholding its draft
report indefinitely.  It claims that more studies are needed before we
can reach any conclusions about perchlorate’s toxicity. This maneuver
allows DoD to argue that until the EPA establishes a regulatory
standard, DoD need not address the problem.  Meanwhile, the
contamination spreads and more people are placed at risk.  Lake Mead,
for example, continues to receive up to 500 pounds of perchlorate per
day from a Kerr-McGee plant in Henderson Nevada.  Downstream,
perchlorate levels have reached 5-9 parts per billion in the Lower
Colorado River, which is above what scientists working for EPA and the
state of California believe is safe.

In my professional judgment, there is adequate evidence to justify 1ppb
as an interim standard.  We have clear evidence of potential risk based
on animal studies, epidemiological studies, and a human exposure study
that validates the assumptions that were made in understanding the
distribution of iodine and perchlorate in the healthy human body.
Available evidence justifies taking action to prevent or reduce
exposures.

It is important to note that this debate is raging despite the fact that
we have laws in place that allegedly protect the public from harm.  The
DoD refuses to consider the potential impacts that its homeland
activities have on human health and the environment.  Unfortunately, our
current laws are not even strong enough to prevent the unacceptable
environmental risks that military “readiness” has already created.

The DoD’s proposal to further weaken key environmental laws will place
hundreds of thousands of pregnant women and their children at grave risk
of irreversible developmental damage.  As a scientist deeply concerned
about this looming public health catastrophe, I implore Congress not to
allow the military to escape its responsibilities to the millions of
citizens potentially exposed at levels far above what is safe.

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