One has to be careful when
speaking of the Devil. In recent responses to the Statement
of Basis documents of management alternatives for 4 of 16
toxic sites here, I cautioned against the possibility of a hurricane-generated
storm liberating contaminants from their existing "stable"
places and spreading them far and wide. Hurricane Georges
has now inundated many of these sites, including an old waste
dump off Old Boca Chica Road, an abandoned "civilian disposal
area" there, and probably other sites inside base property,
such as the ddt Mixing Area.
Many of these sites had interim remedial cleanups. Their worst contaminants were excavated and removed. But all three sites mentioned remain contaminated with pesticides, metals or other pollutants to the degree that they fail to meet exposure guidelines for industrial or residential use or protective guidelines for wildlife—troubling given the sites' proximity to the sanctuary Replenishment Zones, the Great White Heron National Wildlife Refuge and to marine waters in general. For most sites, the Navy has chosen Alternative 2, "Limited Action", as its preferred strategy. Instead of additional physical cleanups proposed in Alternatives 3 and 4, the sites would be monitored at yearly intervals for contaminant migration and access would be restricted. If migration was detected, further action would be taken. Alternative 2 leaves remaining pollutants on site and is the most economical. While restricting human access may be as simple as a fence and a patrol; osprey, eagle, heron, kingfisher, marsh rabbit, mice, lizards, downstream fish, shellfish, crustaceans, mangroves, buttonwood etc. aren't deterred and their exposure to residual toxins continues. Still, the risk assessments conclude that impacts to wildlife have generally been within a tolerable range and should continue to be so. But a closer look at the scope of the risk assessments and the testing protocols reveals a perfunctory document that neglects several important measures of ecological health. Insufficient studies exist to accurately model and predict the fate of wildlife chronically exposed to low levels of intoxicants over extended periods of time. Standard testing determines acute, short-term toxicity; acute and chronic exposure are not equivalent standards. Chronically exposed animal (and human) populations may not die, but can be affected over the long term by a litany of reproductive, endocrine and nervous system disorders.
The class of pesticides most frequently uncovered at the naskw sites are organochlorines, including ddt and its breakdown products ddd and dde, aldrin, dieldrin and others. dde became infamous as a cause of thinned eggshells in Brown Pelicans and raptor species. ddt was banned in the us in 1972 and many of its classmates soon followed after the 1960's death of more than 90 species of birds. These and other "persistent organic pollutants" break down slowly, linger the environment and accumulate in the tissues of exposed individuals. Repeated environmental exposure to pesticides and chlorinated compounds such as pcbs—formerly used in electrical insulating fluids and consequently, a frequently cited Boca Chica contaminant—has been linked in multiple studies to the disruption of the endocrine and reproductive systems of birds and of mammals, including man. A decade ago the quantity of pcb contaminated fish from the Great Lakes eaten by expectant mothers directly correlated to lower birth weights and smaller infant head size. The study was duplicated in North Carolina with the same results.
Even the minor presence of these compounds can represent a significant threat to the offspring of chronically exposed adults.
To supplement the LD/LC50 test data, biological samples of fish, crabs, shellfish etc. were tested for known on site contaminants. Sampling was inconsistent and results were inconclusive, but the testing measured contaminants from whole samples. Pesticides and other persistent toxins tend to be lipophilic, that is, they accumulate and are soluble primarily in fatty tissues, the yolks of eggs and the rich milk of nursing females. Testing the whole sample dilutes the measurable concentration of toxins, making them less detectable. No eggs or egg shells were tested during the Boca Chica assessment and samples were not sexed, nor correlated with breeding seasons to include variables that occur during reproductive cycles, when females lose much of their chemical burden as the toxins are carried out of the mother's body into the fat of eggs or milk.
Instead of ecologically specific testing parameters designed to uncover existing problems, the parameters simply comply with current epa regulations satifying federal law but not the natural law of the land and its creatures. Along with other factors not calculated in the documents, the conclusion that the naskw sites pose a tolerable risk becomes even murkier. The risk assessments assume that most contaminants will remain biologically unavailable because they have been bound up in soil and sediments. Hurricane Georges' pounding wind and storm surge demonstrate the fallacy of that assumption, liberating soils, sediments, trees and buildings. No food chain modeling was done for species present on Boca Chica Key to qualify the levels at which persistent toxins might be bioaccumulating. Once ingested, toxins build up in fatty tissues instead of being flushed out. The longer a mouse might live near a toxic site, the more polluted it can become. When a predator such as a hawk eats the mouse, it ingests the entire body burden of pollutants built up in the prey. The hawk eats many mice. The higher up the food chain an animal sits, the greater the magnification.
Finally, the documents don't take into account new risk factors such as the phenomena of multiple chemical interactions. Scientists have discovered that moderately toxic chemical compounds can become thousands of times more toxic when combined with other moderately toxic chemicals. The effect is exponential, not additive. Calculating "safe" exposures evaluates each chemical individually, not in combination, thereby radically underestimating risk. The probability of multiple chemical interactions occurring at most of the mixed waste sites would seem to be a forgone conclusion. This new research area has raised alarm in the scientific community and the epa now considers it so urgent that a dedicated scientific task force is being established (in something akin to record time) to test combinations of 500 priority compounds. Until risk of an unknown magnitude has been identified, decision makers should err on the side of caution. This isn't happening at some naskw sites and it's precisely the problem with choosing the "Limited Action" alternative. Whatever wastes Georges liberated from the Boca Chica sites will never be cleaned up. Their new distribution throughout our environment represent the ecological costs of this option that we now bear.
Alternative 3 would remove and treat remaining contaminants to meet industrial exposure standards. Alternative 4 would insure compliance with conservative standards protective of human health and the environment. These alternatives vary from site to site, but the concerns are the same: Do we choose to monitor the problem sites, clean them up most of the way, or clean them up to the best of our ability? What degree of our own health and what percentage of future wildlife populations are we willing to risk in order to save money? The cleanup budget allotted naval sites is restrictive given the magnitude of the problem, and naskw decision makers have been making good faith efforts to get to the worst sites first and spend their budget accordingly. But our military is not impoverished: the military budget for 1999 is $271 billion. The us is the only superpower in the world. We are still spending vast amounts of money that could be reallocated to fight a real threat: hazardous waste sites on military installations. The value of healthy wildlife and clean water and land can't be overestimated. It's a battle we can't afford to lose. Faced with a growing body of scientific data, conscientious people everywhere ask: Who has the authority to risk future generations?
ACTION ALERT! Please help your wild and human neighbors
one more time. Write to Phillip Williams, Environmental Branch,
U.S. Naval Air Station Key West, PO Box 9000, Key West FL 33040-9001
with a copy to Martha Berry, Remedial Project Manager, usepa,
61 Forsyth St., SW, Atlanta GA 30303-3104. Call Mr. Williams directly
at (305) 293-2061 to have copies of the documents mailed to you.
The comment period ends Dec. 18th. In addition, a rab public
meeting concerning the proposed plans will be held at 7:00
pm, Monday Nov. 16th at the Holiday Inn Beachside in Key West.
Come out and voice your concerns. I'll be there listening.