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Government Findings on El Toro Wells Not UnexpectedRobert J. O'Dowd for Salem-News.com
Marine veterans and dependents asked for assistance from ATSDR. Government agency cites lack of information and sampling data, despite evidence of TCE in base wells and El Toro engineering drawing showing wells part of the water distribution system after the award of an early municipal water services contract.
(SOMERDALE, N.J.) - This is the first report in addressing the possible contamination of former MCAS El Toro’s base wells. Future stories will address possible contamination from dermal contact and inhalation and ATSDR’s response.
In April 2008, a group of former El Toro Marines and dependents asked the Agency for Toxic Substances Disease Registry (ATSDR) to evaluate their exposure to trichloroethylene (TCE) and other contaminants found in the soil and groundwater at Marine Corps Air Station, El Toro, California.
In 1985, the Orange County Water District found trichloroethylene (TCE) and perchloroethylene (PCE) in shallow irrigation wells down gradient of the base. In 1990, MCAS El Toro was placed on EPA’s National Priorities List (NPL) primarily because of a plume of toxic waste (primarily TCE) spreading off base several miles threatening the local water supply.
Over the past few months, Salem-News.com has run a number of news stories on the TCE contamination at El Toro. I’ve written a few myself; the bulk of the work done by Tim King, another El Toro Marine veteran and editor of Salem-News.com.
In the 2007, I was shocked to learn that the Hangar 296, over 200,000 sq. ft. in area and a hangar I worked in and slept on duty watch for nearly two years in the 1960s, was “ground zero” for a trichloroethylene (TCE) plume, spreading its ugly path into the principal aquifer at Orange County and threatening the community’s water supply.
My contacts with Tim King and other Marine veterans were an incentive to continue to write a blog (mwsg37.com/) to help to spread the word of El Toro’s Superfund status to other Marine veterans and dependents.
I was part of the group in 2007 that asked ATSDR to evaluate the risk of exposure of contaminants to Marines and dependents at El Toro.
Under the Department of Health and Human Resources, the ATSDR was created by the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), more commonly known as Superfund. ATSDR is required by law to conduct a public health assessment at each site proposed or listed on EPA’s National Priorities List.
The Defense Department (a major Superfund site owner with 133 EPA Superfund sites) funds the agency’s public health assessments at DOD sites.
Dr. Thomas Sinks, Deputy Director, ATSDR Congressional in testimony in June 2007 before the House of Representative’s Committee on Energy and Commerce, Subcommittee on Oversight and Investigations confirmed that: “Under the 1986 Superfund Amendments and Reauthorization Act, HHS and the Department of Defense (DOD) are required to enter into a memorandum of understanding (MOU) regarding the manner in which ATSDR will carry out its responsibilities at DOD sites, and to establish a manner to transfer funds from DOD to ATSDR to fund these activities. Under the MOU, ATSDR sends an Annual Plan of Work to DOD each year, identifying planned work and funding needed for that work for the coming year.” (see: energycommerce.house.gov/cmte_mtgs/110-oi-hrg.061207.Sinks-Testimony.pd)
While not quite like the proverbial “roster in the hen house,” the funding arrangement raises serious questions of independence. In effect, DOD—a major polluter—funds the activities of ATSDR—the regulator—at DOD Superfund sites.
There is no information on any budgetary disputes between DOD and ATSDR, but it does give DOD usual control over an agency established to review its activities.
Could this funding arrangement influence ATSDR’s public health assessments? Obviously, if DOD funds only a portion of ATSDR’s estimated manpower requirements, then it has to influence the agency’s work.
The Base Wells and TCE
In 1990, MCAS El Toro was placed on the National Priority List (aka Superfund), the DOD BRAC list in 1993; and officially closed in 1999 with much of the land sold by the Navy at a public auction in 2005 for $650 million.
TCE is the primary contaminant in El Toro’s soil and groundwater and the reason for El Toro’s placement on the EPA Superfund and subsequent closure and sale.
TCE was used as a degreaser on aircraft on the base for decades before safe environmental practices were implemented. EPA reported that Site 24 (MWSG-37’s 200 acres) was the source of the TCE toxic plume. The Navy spent millions of dollars in the clean-up work over several years—including soil vapor extraction (SVE). The clean-up continues today and will not be completed for years.
Based on the levels of contamination of the soil and groundwater, there’s no question of the high volume usage of TCE at El Toro. El Toro kept no usage records, but the Navy and EPA estimated 8,000 pounds of TCE under the base. The City of Irvine’s consultant estimated 700,000 pounds. The Navy disputes the higher estimate. However, there is no dispute that the TCE plume cut a path through the base wells in the most industrialized portion of the base, MWSG-37 or EPA Site 24.
Both the Navy (responsible for the clean-up) and EPA expressed no concern over the base wells, which drew water from the uncontaminated principal under the base. However, a number of Marine veterans and dependents, some suffering from serious illnesses linked to TCE exposure, asked ATSDR to follow-up on its 1993 Public Health Assessment.
The 1993 PHA was indeterminate because of the lack of on-station date. The group’s expectation was that over the past 15 years there should be sufficient data for ATSDR to evaluate the risk of exposure to TCE.
Exposure to TCE and other contaminants can occur through ingestion (drinking water). Even though the base wells drew water from the uncontaminated aquifer, contaminants can enter a well through the well screen and corroded well casings. Accordingly, the location of the well screen intervals and the integrity of well casings can affect the quality of water.
Our review of well destruction reports showed 50 feet of one screen interval (Well #4) in the contaminated aquifer. The well screen construction drawings for all of the base wells are missing. Only a physical inspection of each well prior to destruction could confirm the location of well screens and the condition of well casings.
The information on well screen for Well #4 was reported to ATSDR and the Navy. No response was received from either one and ATSDR continued to ignore this fact in its recent evaluations.
In their report of January 2nd 2009, ATSDR stated they worked with EPA, and the Navy Base Realignment and Closure Program Management Office West (BRAC PMO) to obtain “information describing the source of water for the base’s drinking water needs and the available sampling data describing the contaminant concentrations measured in the groundwater beneath the industrial area used by the Marine Wing Service Group 37, the base drinking water wells in the air inside hangars 296 and 297, and in the soil and gases beneath the industrial area.” (see: atsdr.blogspot.com/)
Many Marines and dependents stationed at El Toro were concerned about the drinking water and asked ATSDR in 2008 whether the drinking water was impacted by groundwater contaminants like TCE.
For me and many others, the concern was never the quality of municipal water but the risk of exposure to TCE and other contaminants from the base wells.
Base wells were the sole source of water from 1943 until about 1951 when the Navy awarded a municipal water services contract to the Metropolitan Water District (MWD). As a result of a property annexation, a follow-on contract with the Irvine Ranch Water District was awarded in 1969. There is evidence to support that some of the original base wells continued to provide water up to the award of the IRWD contract.
The Navy has not provided any explanation for the purchase of municipal water and the eventual abandonment of the base wells. It’s not clear whether ATSDR requested this information from the Navy, but there’s no indication that this important question was asked by them.
Water is a scarce and expensive commodity in Southern California; a decision to purchase municipal for El Toro was a major one.
Why did the Navy purchase municipal water when there was no shortage of water in the principal aquifer under the base? Government procurement regulations required that the purchase of municipal water be supported by a technical analysis. The Naval Facilities Engineering Command (NAVFAC) was the contracting office for the purchase. The justification is contained in the official contract file. Requests to the Navy for copies of the justification were denied because the contract files were missing.
ATSDR did not address the reasons for the municipal water purchases in their report.
Were the base wells contaminated with TCE? Anyone on the base when well water was used would naturally be concerned about this possibility. The well destruction report for Well #4 showed the well casing extremely corroded, 50 feet of the well screen interval in the contaminated shallow aquifer, TCE found in the well, and failure of the well after the casing was scrubbed for video taping by the Navy’s consulting engineer. The report did not address any of these issues.
ATSDR noted that: “It is unfortunate that we can not conclusively determine whether the on-base wells were used to support the base’s water needs after 1951. However it is important to note that the historical documents indicate the 18-inch water main that was available to meet all of the base’s water needs in 1969, was built and operational in 1951. Additionally, the July 1969 contract noted that should the municipal water provider be unable to serve El Toro, they would assist the Government in providing water to El Toro from groundwater wells located at the Marine Corps Air Facility, Santa Ana. This suggests that the wells located at El Toro were not considered viable water supply resources in 1969.”
An El Toro Master Water Supply drawing after the early MWD contract was awarded from December 1951 showed water supply from the 18-inch water main and five of the original six base wells as part of the water distribution system. One logical conclusion is that the MWD contract was intended to “soften hardened water” from the base wells and supplement the lost of one of the original six wells (Well #3). Another El Toro engineering drawing from 1954 showed these base wells operating as part of the water distribution system.
What was ATSDR’s response? ATSDR reported that: “the available information is not sufficient to determine if the on-base drinking water wells were used after 1951 to provide a portion of the base water supply. Additionally, the available information is not sufficient to determine if the wells were impacted by the groundwater contaminant plume present in the industrial area. As a result it is not possible to determine if base-related contaminants were present in the on-base drinking water system prior to 1969.” (see: atsdr.blogspot.com)
Our assumption is if wells are shown on government engineering drawings as part of a water distribution system, then that should be enough support for anyone, including ATSDR. It’s also obvious that the Navy did not provide copies of the well destruction reports to ATSDR or they were ignored by them. For example, the well destruction report for Well #4 documented the well casing failure and well screen placement in the contaminated shallow aquifer.
There are thousands of pounds of TCE in the groundwater, engineering documentation supporting base wells in use after the award of the MWD contract, one well definitely contaminated with TCE and others constructed at the same time more than likely contaminated but ATSDR finds the “information not sufficient. At this point, you wonder what it would take to convince ATSDR that the base wells were in fact impacted by the TCE plume.
It’s unlikely that the Navy (the polluter) is going to just hand over incriminating documentation. Yet, that is exactly what ATSDR ask for. The Navy would be open to tort suits from civilian employees and dependents (but from not veterans) for evidence of exposure to contaminants. Absence a subpoena, it’s doubtful that evidence to support a potential litigant’s tort suit would be willingly handed other to anyone.
Salts in Aquifer and Corrosion
As indicated to ATSDR by Marine veterans and documented by the Navy and EPA, the shallow aquifer under the base has elevated levels of total dissolved solids (“salts”). El Toro monitored the levels of total suspended solids and nitrates (high levels in the shallow aquifer) in the drinking water from the base wells. None of the laboratory test data from the wells was available from the Navy and given the time periods involved may have been destroyed. There were no tests for TCE/PCE available until the 1980s. But, high levels of TSS and nitrates would have set off alarms and service disruptions from equipment failure supporting the need for major well reconstruction or purchase of municipal water.
You don’t have to be an engineer to know that salts are corrosive to metals. The well destruction reports for the base wells support extensive corrosion of base wells. The Navy purchased “softened water” from MWD. The government’s supporting justification for the MWD contract is not available. The Navy had to maintain file until several years after final payment of the contract. However, it’s not a quantum leap of faith to suggest that salts greater than 1,000 ug/L can corrode metal casings and pumps. In fact, the Navy’s consulting engineers reported extensive corrosion of base wells before their destruction. Corrosion would have unknowingly allowed some level of contaminants into the well water.
Homestead Wells Not Addressed
ATSDR's letter does not mention the Homestead Wells #1 and #2. Sometime after 1954, El Toro constructed two other wells--Homestead Wells #1 and #2. These two wells were located in the Northeast quadrant of the base. These wells were not part of the original six base wells constructed in WW II. We know that because these two wells were not shown on any El Toro engineering drawings before 1954.
We don't know when the Homestead wells were constructed, but it had to be after 1954. So, if El Toro is constructing wells after the initial 1951 MWD contract, it's obvious that the MWD contract was not intended to meet all of the base's water requirements. Both Homestead wells were sealed in 2006. Even though the well construction drawings are missing, the Navy did ask their consulting engineer to physically inspect these wells to locate the screen intervals. The consulting engineer reported extensive corrosion in the well casings.
ATSDR seems to be relying on the absence of sampling data as the basis for their findings. Nice, if you have it, but in the past, there’s no sampling data available. What is evident is the volume of TCE in the groundwater, the location of 6 of the 8 base wells in the direct path of the TCE plume, the abandonment of base wells without any explanation, the high risk of galvanic corrosion from the TDS levels in the aquifer (>1,000 ug/L), well destruction reports documenting corrosion and well casing failure in several base wells, the failure of the Navy to justify the purchase of municipal water, and the use of high volume of TCE indoors in hangars on base by personnel without protective clothing.
I find it hard to believe that ATSDR can use “lack of sampling data” under these circumstances to justify their conclusions. If they’re looking for a nice neat package totally documenting environmental contamination, it’s unlikely to exist outside of some make believe fantasy world.
Here is a complete list of the articles that have been generated on the contamination of the former Marine Base at El Toro and at Camp Lejeune, North Carolina:
Follow this link to our stories about the Marine Corps and TCE
Articles for January 14, 2009 | Articles for January 15, 2009 | Articles for January 16, 2009
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