[CPEO-MEF] Rocky Mountain Arsenal offpost groundwater

[Lenny Siegel <lsiegel@cpeo.org>]

Presentation delivered by John Yelenick <yelenick@earthlink.net> to the 
Rocky Mountain Arsenal Citizen Advisory Board (CAB), formerly the 
Medical Monitoring Advisory Group (MMAG) on October 19, 2004. Dedicated 
to the late Roland Russell – MMAG Co-Chairperson and Co-Author of the 
MMAG Minority Report:

Members of this Committee:

Pursuant to page one of the Rocky Mountain Arsenal Offpost Record of 
Decision, groundwater contributes approximately 75 percent of the total 
carcinogenic risk to the RMA offpost population.  However, during August 
of 1988, medical monitoring of the public for exposures related to 
groundwater contamination was politically negated.  Instead MMAG 
emphasis was placed upon exposure prevention related to onpost soil 
remediation and air monitoring.

Since the December 1995 formation of the MMAG, the groundwater offpost 
community has experienced a statistically significant elevation in 
lymphoma’s, brain, lung and pancreatic cancers.  We are currently 
witnessing genetic abnormalities in the RMA groundwater impacted South 
Platte sucker fish – abnormalities which are the first of their kind 
discovered in Colorado and perhaps the nation. DIMP exposure results in 
liver and kidney damage. However, only one week ago, a conclusion by the 
federal Research Advisory Committee on Gulf War Veterans Illnesses 
confirmed a "probable link" between neurological damage and to 
acetylcholinesterase inhibitors – of which DIMP contaminated 
groundwater, in combination with fluoride or chloroform, could 
reasonably generate comparable affects.

Obscuring offpost groundwater medical monitoring was justified by the 
regulators who emphasized the planned construction of an alternate water 
supply for citizens located in the offpost groundwater contamination 
pathway – a federally recognized Environmental Justice community without 
neighborhood medical clinics.  It is the alternate water supply quality 
and delivery, a project that is to be completed by the end of October 
2004, that I now will address.

Despite written indemnification's to the contrary, the US Army/Shell Oil 
Company installation designee, South Adams Water and Sanitation District 
in unison with and under the purported supervision of Commerce City 
construction inspectors, did allow for the improper installation of 
distribution pipelines relative to the final finished grade elevations. 
 Construction so improper, that during July 2004, a buried fire hydrant 
had its top hex bolt, sheared-off by a weed-mowing contractor. 
Extensive pre-construction improvements, including asphalt paving and 
private driveways that were removed from private property/and public 
right-of-ways without their warranted replacement. Regulators have 
subsequently directed that the onus of repairs and replacement be placed 
on adjacent property owners.

Despite current USEPA-CERCLA statutory rights of access to potentially 
contaminated property, State and local regulators have imposed or are 
attempting to impose additional non-compensated surface and sub-surface 
easements across private property as a condition precedent to private 
development under the RMA-ROD, Institutional Controls - for new domestic 
wells.  As an example, an Adams County 2003 building permitted, 
fully-framed residence, having petitioned regulators for an alternate 
water supply because of DIMP contamination at or exceeding 8ppb, -sits 
idle - awaiting water connection assurances from the US Army/Shell Oil 
Company.  Surprisingly, County and City regulators are currently 
attempting to impose residential development upon Industrially zoned 
lands - yes, zoned Industrial for decades, also impacted by RMA 
groundwater contamination and operating pursuant to a State sanctioned 
"Voluntary Clean Up Plan".

 Let me not omit the current delivery of questionable SACWSD 
"alternate" water quality, which compared to the previously utilized 
aquifer water quality, is deteriorating private metal water lines and 
metal plumbing fixtures.

 In conclusion, during February 1998, Chemical Weapons Treaty 
Organization- Director General: Jose Bustani, himself confirmed, that 
DIMP is covered by the provisions of the Chemical Weapons Convention 
(CWC).  The CWC prohibits the release of DIMP into the environment. 
However, in February 2004 the US Department of State, responding to an 
inquiry made by US Colorado Senator Allard disclosed that the Colorado 
Department of Public Health and the Environment may waive international 
CWC requirements in lieu of domestic legal standards (concerning DIMP). 
I was, and am currently - appalled. No other United States ‘state’ has 
ever over-ruled the protections afforded people under the Chemical 
Weapons Convention.  I urge the MMAG to meet its purported mandate to 
prevent exposure, identify health concerns, and inform the community by 
re-engaging issues related to the RMA-ROD offpost groundwater 
contamination pathway and the purported Institutional Control 
protections which lie dormant or unabated.

Blessings,
John Yelenick, Community Co-Chairperson 1996-1998: RMA US Army's 
Restoration Advisory Board

--
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
http://www.cpeo.org


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