DOD RELEASES FIRST TOXICS RELEASE INVENTORY (TRI) REPORT

For the first time, the Department of Defense has submitted a nationwide report on its toxic releases. As required by a 1993 Executive Order, the DOD has submitted detailed data, by installation, to the Environmental Protection Agency and the states in which those installations are located. The nationwide report, covering calendar year 1994, summarizes releases at 131 Defense installations -- including contractor-operated facilities, many of which had previously complied with the TRI -- that met the threshold reporting requirements. More detailed information should be available in June.

The combined release of TRI chemicals by reporting DOD installations totaled 11.46 million pounds in 1994. DOD points out: "By comparison, private industry releases for the TRI reporting year 1993, the most current available, were 2.8 billion pounds. Thus, DoD represents a small portion of those total TRI releases, approximately .41%." DOD suggests that this is because it is a downstream user of chemicals, not a manufacturer.

The totals, by type of release, were as follows. Note that the weights apply to the toxic constituents, not the total waste.

Total reported releases of three chemicals -- all solvents -- exceeded one million pounds each: dichloromethane (methylene chloride), methyl ethyl ketone (MEK), and 1,1,1, trichloroethane (TCA or methyl chloroform). The fourth on the list, ethylene glycol, is primarily used as an airplane de-icer. The top ten chemicals, listed below, accounted for 68% of the reported releases in 1994.

DOD says it has "made enormous progress" in reducing its use and release of ozone-depleting substances: "In just five years, the Department decreased its use of halon from 10,325,000 pounds in 1990 to 231,000 pounds in 1995; and its use of CFCs [chlorofluorocarbons] from 14,588,000 pounds in 1990 to 313,000 in 1995." It neglects to mention that TCA, third on its list, is also an ozone-depleting substance.

Ten installations, all off which are industrial activities, accounted for 52% of the reported releases. Two, Lockheed-Martin and Vought Aircraft, are contractor-operated. Two others, Kelly and McClellan Air Force Bases, were just approved for closure, although the government is looking for ways to continue at least some of their operations under private ownership.

Given the experience with private companies' TRI reporting, it will probably be a few years before all DOD installations get their numbers right (or at least as accurate as they will ever be). Unlike the private sector, the Defense Department is required to report releases from non-manufacturing installations, so it exempted numerous activities, such as the field maintenance of motor vehicles, from its total. It remains to be seen whether such exemptions mask substantial additional releases.

In any case, DOD is already using the data to make plans to reduce its releases: "In a pilot initiative the Department is calling Toxics Reduction Investment and Management, DoD intends to first identify and quantify the industrial and maintenance processes that produced the releases, then identify the military specification, standard, procedure, and other technical document that requires the process to use the TRI chemical. This analysis, although it cannot be used as the sole basis for prioritization, will provide valuable assistance to the Department in developing its pollution prevention investment strategy, managing environmental technology efforts, and prioritizing the revision of standardized documents."

FY97 DERA SERVICE BREAK-OUTS

The Clinton administration has released more details on its proposed Fiscal Year 1997 military cleanup budget. It has proposed four line items covering what formerly was known as the consolidated Defense Environmental Restoration Account (DERA).

Formerly used defense sites (FUDS) have been moved from the Army budget to Defense-wide. This year (FY96), the Defense-wide total is $57,000,000, covering Defense Agencies (such as the Defense Logistics Agency) as well as the operation of the Environmental Security office's cleanup branch. So the total proposed for FUDS in FY 1997 is somewhere around $200,000,000.

This total is about $80 million below the FY96 appropriated DERA level of $1,411 million and far below the President's FY96 request of $1,622 million. Though increases in the Base Realignment and Closure (BRAC) environmental account compensate numerically for the drop in the Environmental Restoration account, BRAC money is supposed to help put cleanup at closing bases on the fast track. At the proposed DERA level, cleanups at many active bases will be significantly slowed.

DOD IS DEVO

In its proposed FY97 budget and an accompanying report, the Defense Department has formally proposed to devolve the Defense Environmental Restoration Account (DERA) into four separate accounts. Devolvement has been in the works for about a year, but it was decided internally at the Pentagon without outside consultation. The report to Congress is designed to justify the decision.

Officials within the military cleanup programs see devolvement as a matter of internal accounting. After several years of DERA, the armed services' restoration programs are consistent, and they all provide substantial opportunities for public participation. The Base Realignment and Closure accounts, they point out, are already separate.

However, outside advocates of military cleanup are concerned that devolvement will make it easier for each of the armed services to raid their environmental accounts to support other projects. They cite the DOD devolvement report: "Including environmental restoration in program and budget reviews by the Components' [armed services and defense-wide] financial managers will allow restoration requirements to compete with other mission requirements. . ."

In fact, it's hard to predict whether devolvement will strengthen or weaken military cleanup programs. Conceivably, activities within some components will fare better while others find money tighter. More than anything else, it depends upon whether the communities affected by cleanup and their elected representatives make it clear that the sustained funding of environmental restoration is both an obligation and a necessity.

CONTAMINANT MASS

The State of California (Department of Toxic Substance Control, Office of Military Facilities) has published a paper describing the preliminary results of its innovative Contaminant Inventory Project. Instead of relying upon the poorly defined "number of sites" within facilities with particular forms of contamination, Peter Wood and David Wang have used existing data to estimate the contaminant mass, by type, of soil contamination at 13 closing military bases in northern California.

At eight Navy installations in the San Francisco Bay Area, they found that TPH (total petroleum hydrocarbons) contamination accounted for 54% of the total mass of contamination, much more than their share of contaminated sites (22 of 135). Inorganics, principally iron, lead, copper, zinc, and antimony, accounted for 29% of the contaminant mass, even though they were found at 68 sites. Iron made up 22% of the inorganic contaminant mass (that is, 22% of 29%), even though found at only one site, while arsenic represented only .57% of the mass, even though it was listed at 13 sites.

Three Bay Area Army sites, including Fort Ord, showed inorganics at 51% (led by lead at 46% of the 51%) of contaminant mass and TPH at 21%. Explosives were counted at .0002%, but that obviously doesn't include the unexploded ordnance and other explosive wastes at the Fort Ord impact range. A fourth Army base -- the Sacramento Army (Signal) Depot -- showed inorganics at 68% and solvents at 25% of contaminant mass. Lead represented 97% of the inorganics.

Mather Air Force Base, the only Air Force facility analyzed, showed TPH at 90% of the contaminant mass. Gasoline accounted for nearly 6% more.

The data compiled by this project, as well as further analysis of other facilities, provide a tool to "prioritize resource allocation, evaluate cleanup progress, and help focus cleanup technology research and development efforts that maximize risk reduction."

This methodology appears to be a relatively inexpensive new tool for analyzing cleanup requirements and accomplishments, but as the report acknowledges, the authors have not yet come up with a systematic way to integrate risk and risk reduction data.

TOOELE COUNTY COMMUNITY HEALTH SURVEY

In a remarkable community-based health study, more than 40 volunteers from the town of Grantsville, in Tooele County, Utah have uncovered what appears to be alarmingly high rates of serious illness. In the study, sponsored by the community-based West Desert Healthy Environment Alliance (West Desert HEAL), the volunteers directly contacted households representing about half the residents of Grantsville, a military-dependent city of about 5,000 people, in January and February of this year (1996).

Participants made no pretension about this being a scientific study; they don't claim to have the answers. Rather, they say, "Ours was a modest and humble effort by citizens to catalyze those with power, authority, expertise, and resources to take action on our behalf. Our survey and this report can identify problems and set targets and directions for further action."

The HEAL survey volunteers identified 201 cancers in half the town -- that is, 650 households -- nearly as many as the 237 identified in all of Grantsville by the official cancer registry. Only the 29 skin cancers found by HEAL were deliberately ignored by the state registry. Other cancers included 23 breast, 16 prostate, and 12 colon. Notably, 182 of the 201 cancers were found among native or long-time residents.

HEAL also found 181 serious respiratory illnesses, including asthma, emphysema, and "serious" or "chronic" sinusitis, but excluding bronchitis, allergies, colds, and pneumonia. The researchers also uncovered 29 serious birth defects, but they felt that many residents may have withheld such information. HEAL also tabulated a number of other health problems, such as 12 cases of multiple sclerosis and 8 lupus cases.

Grantsville is home to the Tooele Army Depot, site of past as well as planned chemical munitions incineration, and the location of extensive open burning and open detonation of conventional munitions. It is also near the Dugway Proving Ground, where the military conducted open air nerve agent tests until 1968, when the chemicals drifted downwind and killed thousands of sheep in Skull Valley, on Goshute Indian lands. One survey respondent gave birth to seriously deformed twins several months after the sheep kill.

HEAL does not claim that hazardous releases from these facilities necessarily caused the high rates of illness. However, its survey raises questions that the Army, regulatory agencies, and health officials should be prepared to explore and answer to the community's satisfaction.

The authors of the study conclude: "the conventional wisdom that too many people in our community are suffering poor health is true.... No once can convince us this is the way it was or is supposed to be. Something is wrong. It is important to find out what and why. We want action."

The Barron Park Association Foundation (BPAF), formed by a neighborhood group to manage the EPA Technical Assistance Grant at a private cleanup site in Palo Alto, California, issued its Final Project Report in December, 1995. The 40-page report, available from the Foundation at 3589 Laguna Ave., Suite #1, Palo Alto, CA 94306, illustrates one way in which all parties to a cleanup can benefit from empowered public participation. The site, 1501 Page Mill Road, is operated by the Hewlett-Packard Corporation on land leased from Stanford University.

Like most of the areas near Stanford and its world-model research park, Barron Park is home to a highly educated, affluent, empower, predominantly white population.

BPAF believes that regular working group meetings were key to the effectiveness of its participation: "A major advance in the process occurred when BPAF, H-P [Hewlett-Packard], and the RWQCB [Regional Water Quality Control Board, the lead regulatory agency] agreed to hold monthly meetings at H-P headquarters to review and discuss events and activities in a timely fashion." When the workload lightened, they moved to less frequent meetings. BPAF's technical consultants attended as necessary.

BPAF took the lead in producing three fact sheets on the cleanup, all of which were distributed to 10,000 households as an insert in the local weekly newspaper. It also helped the responsible parties obtain city approval for their plans.

The report observes: "It was very interesting to discover that everyone was willing to work together collaboratively, since the normal assumption is that industry and community are at odds when discussing environmental impacts and especially contamination cleanup."

The report neglects to mention one significant fact: the Foundation only spent about $31,000 of its $42,000 grant. It returned the rest to EPA.

CALIFORNIA DSMOA

On March 13, James Strock, California's Secretary for Environmental Protection, sent a letter to Pentagon Environmental Security chief Sherri Wasserman Goodman summarizing the benefits of the embattled Defense State Memorandum of Agreement (DSMOA) program. Strock noted that California is currently overseeing the cleanup of 32 Base Realignment and Closure bases, 82 active bases, 36 formerly owned or used defense sites, and seven voluntary base closures.

Strock has designated Cal-EPA's Department of Toxic Substances Control as the lead agency for cleanup oversight, and "it is coordinating the activities of over 20 state and local boards and departments with independent legal authority over cleanup activities conducted at California military installations." He pointed out: "Without the coordination afforded by the DSMOA grant, this system would revert to what existed several years ago with each independent department, air district or other agency having to rely on its own authority to oversee work and recover costs through fees and cost recovery or enforcement.

In an accompanying fact sheet, dated March 6, 1996, Cal-EPA asserts that the Defense Department has saved an estimated $450 million in cleanup related costs in California as a result of the DSMOA program, a "cost avoidance versus DSMOA grant expenditure ratio of 8 to 1."