ATSDR Public Health Assessment for George Air Force Base, CA
In the 1998 Public Health Assessment for George Air Force Base the ATSDR made the following statements:
“ATSDR did not identify any completed exposure pathways from George AFB to children at nearby schools or residential areas.” Page 27
“Soil at George AFB does not represent an apparent past public health hazard and does not represent a present or future public health hazard.” Page 28
See: Public Health Assessment for George Air Force Base, CA – ATSDR – December 1, 1998
Completed Exposure Pathways at George AFB’s Housing
“The Air Force has analytical testing data indicating elevated soil contamination levels of the pesticides Aldrin and Dieldrin in the housing area. The Air Force believes that the surface and shallow subsurface soil contamination is pervasive through the housing area, particularly under house foundations. The pesticides could present a risk to human health if soils are inhaled, ingested, or contacted by skin.”
George AFB Family Housing Quitclaim Deed
“Grantee covenants and agrees that it will not use, or allow others to use, the Property for residential purposes (including mobile or modular homes), hospitals for human care, public or private schools for persons under 18 years of age, nursery schools, or day care centers for children.”
It has been almost seven years since this deed restriction was issued, and the Air Force yet to inform military families of the potential health dangers posed by contaminated soil under and around the George AFB Housing.
The high rates of infant mortality, birth defects, cancer, autoimmune disorders, and sterility at the former George Air Force Base, CA, “EPA Superfund ID: CA2570024453,″ may have been caused in part by Dieldrin, other pesticides, lead-based paint, and asbestos-containing materials (ACM) and friable asbestos at the base housing. Other sources of environmental contamination and exposure pathways are documented here: Completed Exposure Pathways. The high rates of infant mortality, birth defects, and childhood cancers are discussed here: George AFB’s Children.
The Air Force has spent 34 years and $124,700,000.00 cleaning up the environmental contamination at the former George Air Force Base, CA. However, according to the “Deed Restrictions” the Air Force placed on the base housing in 2007, the base housing cannot be used for “residential purposes” because the buildings and soil are contaminated. The Air Force also placed “Deed Restrictions” on the use of groundwater because the upper [and lower aquifers are] contaminated with Dieldrin. Unfortunately, the Dieldrin contamination plumes are within 50 feet to a ¼ mile upstream/adjacent to the municipal wells for George AFB and Adelanto, residential wells for private homes, and the former Victor Valley Country Club.
- The Air Force was required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 120(H) to make full disclosure of known contaminants when the property is transferred.
- The Air Force failed to list all of the Pesticides used under and around the George AFB Housing.
- The Air Force chose to deceive the public and the recipient of the property by using the following vague phrase: “Dieldrin or other possible pesticide-related constituents (“Pesticides”)”
- It was common practice for the Air Force and DOD to use the following “Pesticides” chlordane, heptachlor, aldrin, dieldrin, and endrin to protect buildings’ foundations against ground termites and other pest. See: – Dieldrin contamination at military housing
- The Environmental Protection Agency banned dieldrin use in 1974, except to control termites, because of concerns about damage to the environment and potentially to humans.
- In 1987, EPA banned all use.
- There are no federal drinking water standards for dieldrin.
Organochlorine Pesticides Concentrations In Soil at George AFB Family Housing
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §120(H) Deed Restrictions
The Air Force is required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) § 120(H) to make full disclosure of known and suspected contaminants when the property is transferred. This is the only time that the Air Force presents the information in a clear, concise, and complete format that the public can easily understand. Because of these CERCLA disclosure requirements, it is crucial that the public have unfettered access to these Notices, Covenants, and Environmental Restrictions.
As of July 20, 2014 the Air Force has refused to release the “CERCLA § 120 (H) Deed Restrictions” that were requested under FOIA. However, the Lahontan Regional Water Quality Control Board has made the “Deed Restrictions” available to the public. Here
Quitclaim CERCLA § 120 (H) Deed Restrictions for George Air Force Base Housing
Groundwater use restrictions:
“(a) Groundwater use restrictions: the Grantee covenants and agrees for itself and any of its agents, representatives, contractors, or lessees that it will not construct any well on the Property or extract/pump groundwater from beneath the Property for any purpose other than monitoring.”
Source: page 4
Land use restrictions:
“(e) Grantee covenants and agrees that it will not use, or allow others to use, the Property for residential purposes (including mobile or modular homes), hospitals for human care, public or private schools for persons under 18 years of age, nursery schools, or day care centers for children.”
“1. Lead-based paint was commonly used prior to 1978 and may be located on the Property. The Grantee is advised to exercise caution during any use of the Property that may result in exposure to LBP.”
Asbestos-Containing Materials (ACM) / Friable Asbestos:
“B. The Grantee is warned that the Property may contain current and former improvements, such as buildings, facilities, equipment, and pipelines, above and below the ground that may contain ACM.” … “The Grantee covenants and agrees that in any situation where there may be human contact or exposure to potentially friable ACM (for definition see 40 C.F.R. § 61.141)”
Dieldrin / Pesticides:
C. Pesticides. The Grantee is warned of the presence of Dieldrin or other possible pesticide-related constituents (“Pesticides”) on the Property in certain portions of the soil and in the upper aquifer [and lower aquifer] of the groundwater, which may have resulted from past applications of pesticides. The Grantee is cautioned to use due care during use, occupancy, and Property development activities that may involve soils containing Pesticides. …
Page 7, paragraph 2
Source of the Deed Restrictions:
As of 20 April 2014 Air Force has refused to release any of the Deed Restriction for George Air Force Base that are required by Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
The Lahontan Regional Water Quality Control Board made this copy of the deed restriction available.
Quitclaim Deed Parcels: D-7, D-8, D-9, F-1, G-2, J-1, J-2, J-3, J-A, J-5, J-6, J-7, Central and Southeastern Portion of D-5
A term in legal conveyancing for the party granting title or encumbrance
In this case the Grantor is the United States of America, acting by and through the Secretary of the Air Force
A person or entity to whom a grant or conveyance is made
In this case the Grantee is the Southern California Logistics Airport Authority.
Asbestos vs. Friable Asbestos:
Asbestos -containing materials (ACM) ceiling tiles, floor tiles, undamaged laboratory cabinet tops, shingles, fire doors, siding shingles, etc. will not release asbestos fibers unless they are disturbed or damaged in some way.
Friable Asbestos is the bad actor and can cause Asbestosis, Lung Cancer, and Mesothelioma. The AF has not released a document on the amount in the Base Housing but the Deed Restrictions state it was there.
Drinking Water Supply Wells
The base housing and golf course are within 50 feet to a ¼ mile upstream/adjacent to the municipal wells for George AFB and Adelanto, residential wells for private homes, and the former Victor Valley Country Club.
The groundwater flows northeast under the base housing and golf course to the “Zone of Contribution” (ZOC) for the well fields for George AFB, Adelanto, and private homes, and the former Victor Valley Country Club, and therefore considered upstream of these supply wells.
Dieldrin is shown in yellow on this groundwater plume map
Page 216 (this is a 562 page PDF)
This contamination plume is 50 feet to ¼ mile upstream of the supply wells
The Lahontan Regional Water Quality Control Board hammered the AF over this issue (8 page PDF)
Dieldrin is a chlorinated hydrocarbon pesticide used from approximately 1950 to 1970. Its use beyond the limited termite control near building foundations was banned in the United States in 1974. The EPA banned all uses of Dieldrin in 1987.
Harmful Effects of Dieldrin?
- Decrease the effectiveness of our immune system
- May increase infant mortality
- Reduces reproductive success
- May cause cancer
- May cause birth defects
- Damages the kidneys
Flawed ATSDR Public Health Assessment for George AFB
The Air Force deliberately misled the Agency for Toxic Substances and Disease Registry (ATSDR) and the American people about the hazardous substances at George Air Force Base and the Completed Exposure Pathways (CEP) that these provided. The Air Force knew that the ATSDR came to a flawed conclusion in their 1 December 1998 report “Public Health Assessment for George AFB,” section “Evaluation of Potential Public Health Hazards at George Air Force Base” and Exposure Pathways at George Air Force Base.
See: Request For A New Public Health Assessment
The Air Force has known that numerous “Completed Exposure Pathways” existed at the former George AFB base housing and property since before 27 September 2007.
It has been over 7 years since the Air Force placed the “Deed Restrictions” on the housing, property, and groundwater. In all of this time the Air Force has failed to:
- Request a new ATSDR Public Health Assessment for George AFB
- Notify the former base personnel of their exposure to potentially life threatening environmental contamination at George AFB
- Notify the Department of Veterans Affairs about our Veterans potential exposure to hazardous chemicals at the former George Air Force Base so they can get medical care
- Notify CHAMPVA about our families potential exposure to hazardous chemicals at the former George Air Force Base so they can get medical care
- Notify the San Bernardino County Health Officer that people living in the surrounding community were potentially exposure to hazardous chemicals from the former George Air Force Base so they can get medical care
Because the DOD did not correct the ATSDR during the Peer Review / Public Comments period or after the report was published in 1998, the Department of Defense (DOD) lied by omission.
- FOIA Request Air Force – Deed Restrictions Water / Land Use – 15 Feb 2013
As of 27 April 2014 I have not receive the requested records.
- FOIA – AF HQ – Findings and Recommended Disposition of USAF Physical Evaluation Board – George AFB – 5 Oct 2014
- FOIA – AF HQ – Autopsy Reports & Results – George AFB – 5 Oct 2014
United States Government Accountability Office (GAO)
The DoD has a history of failing to notify the Veterans Affairs or former base personnel of their exposure to potentially life threatening environmental contamination on its military bases. See: Defense Infrastructure – “DOD Can Improve Its Response to Environmental Exposures on Military Installations” – GAO – May 2012
After reviewing this report I have to ask: “Has the DoD crossed the line from criminal negligence to criminal intent to conceal and defraud our nations Veterans?
Major Stephen Russell Henley, JA United States Army
Major Russell wrote an excellent thesis on the “Superfund Reauthorization 1994: DoD’s Opportunity To Clean Up Its Hazardous Waste Act – April 1994″ this is a 135 page PDF
This thesis examines three of the major issues facing the military in its attempts to clean up its hazardous waste legacy:
- Consistency in remedy selection and risk assessment
- Defining the appropriate state role at military hazardous waste sites
- Resolving land transfer issues under CERCLA section 120(h)
If only someone within the Air Force or DoD would have listened to Major Russell’s suggestion.