George AFB’s Flawed Public Health Assessment (PHA)

January 1, 2023
logo ATSDR Public Health Assessment No Completed Exposure Pathways

ATSDR did not identify any completed exposure pathwaysThe Air Force deliberately misled the Agency for Toxic Substances and Disease Registry (ATSDR), Congress, and the American people about the toxic substances present at George AFB, CA. They failed to disclose the Completed Exposure Pathways (CEPs) and potential health threats to base personnel, their family members, civilian employees, and the surrounding community.

The ATSDR relied on the Air Force to supply the relevant documents and information for the Health Assessment for George AFB. Because the Air Force failed to provide all of the appropriate records and information to the ATSDR, it came to a flawed conclusion. This is because the ATSDR did not fully understand the nature and extent of the contamination, locations of the Installation Restoration Program (IRP) sites, hydrology (direction of the groundwater flow, (northeast), and the location of the water supply wells for George AFB, Adelanto, private homes, and the former Victor Valley Country Club.

The Air Force was aware that the ATSDR’s December 1, 1998 report, “Public Health Assessment for George AFB,” reached a flawed conclusion. Despite this knowledge, the Air Force failed to correct the ATSDR during the Peer Review and Public Comments period and neglected to notify it after new information about the emerging contaminants of concern became available. This was a clear breach of trust and a deliberate act of deception.

I urgently request that the Agency for Toxic Substances and Disease Registry (ATSDR) conduct a new Public Health Assessment for the former George Air Force Base, CA, “EPA Superfund ID: CA2570024453.” This is a crucial step towards ensuring the health and safety of all those affected by the Air Force’s actions, which have significantly impacted their well-being.

From the ATSDR’s Public Health Assessment for George AFB, dated December 1, 1998, Pages 28 – 29:

On the basis of available data, ATSDR concludes that exposure to contaminants in groundwater and soil at George AFB does not pose an apparent public health hazard.
Page 27

“On-site and off-site groundwater do not represent a past, present, or future public health hazard. …
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

Radiological contamination does not represent an apparent past public health hazard and does not represent a present or future public health hazard. …
Page 28

… ATSDR concludes that the George AFB site should be assigned to the No Apparent Public Health Hazard category.”
Page 29

1998-12-01 ATSDR - Public Health Assessment (PHA) for George AFB.pdf

CONCLUSIONS - ATSDR's Public Health Assessment for George AFB

Public Health Assessment for George AFB – CONCLUSIONS

On the basis of available data, ATSDR concludes that exposure to contaminants in groundwater and soil at George AFB does not pose an apparent public health hazard.

On-site and off-site groundwater do not represent a past, present, or future public health hazard. On-site groundwater has never been used as a source for drinking water at George AFB and no supply wells are expected to be installed there in the foreseeable future. Groundwater contamination from the OU 1 plume has migrated off site towards the Mojave River, but has not affected any municipal or private drinking water wells. Two supply wells in the path of the plume, at the VVWRA, have never been used to supply drinking water. The installed pump-and-treat system at OU 1 is expected to prevent contaminants from migrating to the Mojave River and regular groundwater sampling will continue to monitor the movement of the plume over time.

Soil at George AFB does not represent an apparent past public health hazard and does not represent a present or future public health hazard. Soil contamination has been detected above ATSDR health-based comparison values in very few areas of George AFB. Access to most areas of contamination is limited and the contaminant levels detected would not pose a health hazard to either children or adults from short-term exposure. Due to the low levels of contamination, exposure to contaminated soil through future industrial reuse of the base is not expected to pose a public health hazard to adults working at the base.

Radiological contamination does not represent an apparent past public health hazard and does not represent a present or future public health hazard. A small amount of radioactive material was discovered and removed from a portion of the SEDA. Radiation surveys and exploratory soil excavation indicate that this area and the two munitions storage areas were not used for disposal of significant quantities of radioactive waste. Although people using the SEDA for recreation in the past may have been exposed to small amounts of low-level radioactive material, such exposures would have been infrequent and of short duration and would not be expected to pose a health hazard. The SEDA has recently been fenced and its landfill cover has been rehabilitated. The George AFB property located south of Air Base Road, which includes the SEDA, has been transferred to the Federal Bureau of Prisons and will be the site of a prison that is currently under construction; the SEDA will remain fenced and will be within the fenceline of the prison. On the basis of information available on groundwater and surface soil contamination at George AFB, the previous and ongoing remediation efforts, and the past, present, and planned future uses of this land and these facilities, ATSDR concludes that the George AFB site should be assigned to the No Apparent Public Health Hazard category.  Pages 27 – 29

References - ATSDR's Public Health Assessment for George AFB

Public Health Assessment for George AFB – References 

CEDAR. 1997. Military Base Closures Announced in December 1988 – BRAC 1: George Air Force Base. Listed on the California Economic Diversification and Revitalization (CEDAR) Website. August 1997.

City of Adelanto. 1998. Personal communication with Jack Stonesifer, Water Superintendent. City of Adelanto. January 15, 1998.

Earthtech. 1993. Basewide Environmental Baseline Survey, George Air Force Base, California. Prepared by Earth Technologies for George Air Force Base, California. December 1993.

IT. 1992. Remedial Investigation Operable Unit 2 JP-4 Spill, George Air Force Base, California. Prepared by International Technology Corporation for George Air Force Base, California. October 1992.

IT. 1995. Report of Southeast Disposal Area Background Radiation Survey, George Air Force Base, California. Prepared by International Technology Corporation for U.S. Air Force, George Air Force Base, California. August 1995.

IT. 1996. Draft Natural Attenuation Monitoring Treatability Study Report, George Air Force Base, California. Prepared by International Technology Corporation for Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas. March 1996.

James Montgomery. 1992. Final Remedial Investigation Operable Unit 1, George Air Force Base, California. Prepared by James Montgomery, Consulting Engineers for U.S. Army Corps of Engineers Sacramento District, California. August 1992.

Montgomery Watson. 1994. Final Record of Decision Operable Unit 1, George Air Force Base, California. Prepared by Montgomery Watson for U.S. Army Corps of Engineers Sacramento District, California. March 1994.

Montgomery Watson. 1996. Final Operable Unit 3 Remedial Investigation, George Air Force Base, California. Prepared by Montgomery Watson for Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas. April 1996.

Montgomery Watson. 1997a. Final Basewide Ground-water Monitoring Report, February 1997 Event, George Air Force Base, California. Prepared by Montgomery Watson for Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas. June 1997.

Montgomery Watson. 1997b. Draft Remedial Action Report (Post Construction) OU 1 Ground-water Extraction Treatment System, George Air Force Base, California. Prepared by Montgomery Watson for Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas. June 1997.

Montgomery Watson. 1997c. Draft Operable Unit 3 Record of Decision, George Air Force Base, California. Prepared by Montgomery Watson for Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas. April 1997.

U.S. Air Force. 1991. Final Draft Community Relations Plan for the Installation Restoration Program at George Air Force Base, California. July 1991.

U.S. Air Force. 1994. Draft George Air Force Base Installation Restoration Program Newsletter. October 1994.

U.S. Air Force. 1997a. Personal communication with Bob Sommer, Base Environmental Coordinator. George Air Force Base, California. June 26, 1997.

U.S. Air Force. 1997b. Personal communication with Bob Sommer, Base Environmental Coordinator. George Air Force Base, California. August 5, 1997.

U.S. Air Force. 1997c. Final Draft Community Relations Plan for the Installation Restoration Program at George Air Force Base, California. October 1997.

U.S. Air Force. 1997d. Draft George Air Force Base Installation Restoration Program Newsletter. April 1997.

U.S. Air Force. 1998a. Personal communication with Bob Sommer, Base Environmental Coordinator. George Air Force Base, California. January 14, 1998.

U.S. Air Force. 1998b. Personal communication with Bob Sommer, Base Environmental Coordinator, George Air Force Base, California. April 2, 1998.

U.S. Air Force. 1998c. Personal communication with Bob Sommer, Base Environmental Coordinator, George Air Force Base, California. April 9, 1998.

U.S. Air Force. 1998d. Comments on the George AFB Draft Public Health assessment by Charles Weir, U.S. Air Force ATSDR Liaison Officer. June 24, 1998.

VVWRA. 1998. Personal communication with Bruce Corria, Health and Safety Officer. Victor Valley Wastewater Reclamation Authority. April 9, 1998.

Public Comments - ATSDR's Public Health Assessment for George AFB

APPENDIX D: Public Comments on the Public Health Assessment

The George AFB public health assessment was available for public review and comment from September 11, 1998 through October 11, 1998. The public comment period was announced in a press release dated September 4, 1998. Copies of the public health assessment were made available for review at the Adelanto and Victorville branches of the San Bernardino County Public Library and at the George AFB Library. The public health assessment was also sent to state and federal agencies and interested members of the general public.

A total of two agencies supplied written comments. The specific comments that were received either identified new information or suggested additions or corrections to the text to improve the clarity, completeness, or accuracy of a sentence or a paragraph. A summary of the comments and ATSDR’s response is given below:

1. Comment: The JP-4 free product estimate has recently been revised from 350,000 – 400,000 to 750,000 – 800,000 gallons.

Response: The text was updated on pages 1, 7, and 18.

2. Comment: EPA does not agree that the OU-2 plume shows little or no migration. George AFB has agreed to put in additional monitoring wells to better define the plume.

Response: The text was updated to reflect these new developments. Unless data are developed that indicates the OU-2 plume is potentially endangering nearby drinking water wells, the public health evaluation of the OU-2 plume is not changed by this information.

3. Comment: The EPA is not satisfied that the OU-1 pump and treat system is not fully meeting the objective for that system for TCE removal in the upper aquifer and hydraulic control in the lower aquifer. George AFB is taking steps to optimize the operation of the pump and treat system and additional data may be needed.

Response: The text was revised to reflect these activities. Given that the character and migration of the OU-1 plume is monitored and there are no potential points of human exposure to the contaminants of this plume in close proximity, continued monitoring and regulatory oversight and controls will preclude a future potential pathway of human exposure to site contaminants at levels that may result in harmful health effects.

4. Comment: The EPA disagrees, on several grounds, that the JP-4 plume can be successfully cleaned-up natural attenuation within 50 years. EPA has requested that George AFB perform a soil vapor extraction pilot project to evaluate active source removal.

Response: The text has been modified to reflect these changes. As stated in response to Comment 2 above, the present information does not warrant a change in the public health evaluation of this plume and its public health implications.

5. Comment: Both the EPA and George Air Force Base supplied additional information and/or clarification regarding the pesticide rinsate pit (Site OT-62). Both agencies confirmed that when the site was investigated, the pit was found to be free of cracks or seams and that records indicated that rinsate water had been placed directly in the lined pit for evaporation. In 1992, all residual pit wastes were drummed and shipped to the Defense Reutilization and Marketing Office for proper disposal. Since no contamination or residue existed, the pit was determined to be a No Further Action site. The pit was then filled in and paved over with asphalt paving.

Response: Given the additional information and clarification, ATSDR has withdrawn its recommendation for sampling and further evaluation of Site OT-62. The text has been modified and corrected to reflect this additional information.

Source

Source:

George AFB’s Completed Exposure Pathways (CEP)
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logo ATSDR Public Health Assessment No Completed Exposure Pathways

George AFB’s Flawed Public Health Assessment (PHA)

Posted: January 1, 2023
The Air Force deliberately misled the Agency for Toxic Substances and Disease Registry (ATSDR), Congress, and the American people about the toxic substances present at George AFB, CA. They failed to disclose the Completed Exposure Pathways (CEPs) and potential health threats to base personnel, their family members, civilian employees, and the surrounding community. The ATSDR relied on the Air Force to supply the [Read More…]
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Posted: April 19, 2014
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George AFB’s Lead Based Paint Contamination

Posted: December 21, 2015
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Request a New Public Health Assessment for George AFB

Please get in touch with Sven E. Rodenbeck and ask that the ATSDR conduct a New Public Health Assessment for George AFB.

Sven E. Rodenbeck, Sc.D., P.E., BCEE
Acting Western Branch Petition Coordinator
Rear Admiral (retired), USPHS
ATSDR/DCHI – Mailstop F59
1600 Clifton Road, NE
Atlanta, GA 30333
Office: (770) 488-3660
Cell: (404) 729-5041
FAX: (770) 488-1543

Definitions

Lying by omission:

Definition:  “A lie of omission also known as a continuing misrepresentation, a lie by omission occurs when an important fact is left out in order to foster a misconception. Lying by omission includes failures to correct pre-existing misconceptions”

Completed exposure pathway:

A pathway of exposure is considered completed when all five elements are present. A completed pathway connects the source of the material to people.

  1. Source
  2. Media
  3. Exposure point
  4. Exposure route
  5. People

Will exposure from a completed pathway affect my health?

Whether or not a person experiences health effects from exposure to materials in the environment depends on a combination of several site-specific factors, including:

  • Kind of material released;
  • Amount of material available at the exposure point;
  • The physical and chemical form of the material;
  • Environmental conditions;
  • Length of exposure time.

Source: EPA

I am not a doctor, Veterans Service Officer (VSO), or attorney; therefore, I cannot provide medical or legal advice.

If you, a friend, or a loved one have been injured or have passed away due to exposure to contamination at a DOD Superfund Site, please follow the steps outlined on the "Get Help" page.

The views and opinions expressed on this website belong solely to the authors and do not necessarily reflect the official policy or position of any agency of the U.S. government.

Fair Use Notice   |   Release to one is release to all 

4 Comments

  1. Is this something for us to participate in, or is this something you did or doing now?

    Reply

    • If you or a loved one was injured or died from a toxic exposure at GAFB, please write a letter requesting a NEW Public Health Assessment for GAFB.

      Look for a chemical/toxin with a completed exposure pathways (CEPs) that would have caused the illness include 1 or 2 pages of medical records and/or a Death Certificate.

      Include a section from the old Public Health Assessment for GAFB that applies
      George AFB’s Public Health Assessment (PHA)

      Send the request to:
      Sven E. Rodenbeck, Sc.D., P.E., BCEE
      Rear Admiral (retired), USPHS
      ATSDR/DCHI – Mailstop F59
      1600 Clifton Road, NE
      Atlanta, GA 30333
      Office Telephone: (770) 488-3660
      Cell Telephone: (404) 729-5041
      FAX: (770) 488-1543
      Email: [email protected]

      cc: Libby Vianu
      Regional Representative
      ATSDR Region IX
      75 Hawthorne Street
      Suite 100, HHS-100
      San Francisco, CA 94105
      Office Phone (415) 947-4319
      Cell Phone (415) 203-2238
      Email: [email protected]

      AND your Congressional Representative and Senators
      Find Your Representative
      Find Your Senators

      Reply

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