The Department of Navy has neglected to discuss in their environmental impact documents ready-available data suggesting genuine and proven threats to munitions contaminants leaching into surface or groundwater on Tinian, the U.S. Environmental Protection Agency confirmed yesterday.<\/p>\n
Local agencies and government consultants have been concerned with these data omissions.<\/p>\n
They say the Navy\u2019s designations of \u201cless than significant\u201d impacts to water quality on Tinian must be changed.<\/p>\n
One omitted study\u2014an EPA study from 2012\u2014covered a wide range of munitions chemicals and propellants left in the soils of over 30 military installations and firing ranges in the U.S., including Hawaii.<\/p>\n
Another omitted study\u2014from the U.S. Geological Survey\u2014points out how Tinian\u2019s relatively porous limestone geology could be susceptible to pollution via infiltration.<\/p>\n
These studies are readily available via Google Search.<\/p>\n
Environmental Science Associates director Jim Keany told Saipan Tribune that the EPA paper also cites a number of very specific studies dealing with munitions, soil residues, and groundwater risk\u2014but that the Navy cites none of these in their analysis of effects.<\/p>\n
\u201cThe conclusions seem to be drawn to meet a vision,\u201d Keany said. ESA has been hired to review Navy impact documents.<\/p>\n
When sought for comment, the Environmental Protection Agency confirmed that that they were aware of these data omissions within the \u201cCNMI Joint Military Training\u201d draft environmental impact statement.<\/p>\n
\u201cYes, in general\u2014in that they [the Navy] didn\u2019t really evaluate the impact from MCs [munitions constituents],\u201d said public affairs officer Dean Higuchi, speaking on behalf of those in EPA working on the review of the EIS.<\/p>\n
Higuchi confirmed that EPA would address the potential mobility and leaching of MCs into Tinian and Pagan groundwater in their official comments.<\/p>\n
\u201cWe cannot say more at this time, as the comments are not final yet,\u201d Higuchi added.<\/p>\n
Comments from the Marine Corp Force Pacific were not yet available as of press time.<\/p>\n
Keany explains that the EPA report discusses their results by munitions range type\u2014from hand grenade, to small arms, and bombing ranges.<\/p>\n
For Tinian and Pagan, MARFORPAC would expend a \u201cmunitions quantities\u201d of 114,681 for field artillery, mortar, rocket, and grenade training, according to a summary of use per year provided by ESA.<\/p>\n
MARFORPAC proposes to expend 4,924,643 rounds of small arms to .50 caliber rounds per year. Maforpac also proposes to expend 176,000 total of air-delivered munitions. These include up to 1,000-lb bombs.<\/p>\n
Keany said the 2012 EPA report looked at heavy metal residues in soils and in a few cases, in groundwater.<\/p>\n
\u201cThe results show that there is a wide range of chemicals that are left in soil\u2014many of which can be mobilized by rain and travel to groundwater. This is a particular concern because\u2014as the USGS study notes\u2014the karst limestone geology of the islands is relatively porous on Pagan and Tinian,\u201d Keany explained.<\/p>\n
\u201cThe Navy also does not address destruction of duds or excess munitions that are discussed in the EPA report,\u201d he said.<\/p>\n
The EPA report states: \u201cMilitary EOD technicians use [open burn\/open detonation] ranges at active [Department of Defense] training facilities to destroy duds of various munitions that are considered acceptable to move. Sometimes chunks of high explosive or unused propellants are also destroyed at these ranges by detonation or burning.\u201d<\/p>\n
It also states: \u201cAs discussed in Clausen et al. (2007) perchlorate is rapidly dissolved, does not absorb to soil components, is largely recalcitrant, and thus it is highly mobile. The high solubility and ease of dissolution prevents persistent build-up in soil, but can potentially produce groundwater contamination.\u201d<\/p>\n
\u201cThe general concern is that there will be a great deal of munitions spent annually both on Pagan and Tinian,\u201d Keany said. \u201cFrom studies such as this EPA paper, and the ones cited in the paper, we know that a number of chemicals and heavy metals can accumulate in soil. Many can be mobilized by water. These mobilized chemicals can seep into the soils and because of the limestone geology o the islands, can easily make their way to the groundwater.\u201d The freshwater aquifer of Pagan and Tinian is a lens of freshwater that sits atop seawater.<\/p>\n
Lack of baseline data<\/strong><\/p>\n The Navy\u2019s impact documents also lack important information on the current state of Tinian\u2019s groundwater and the effects of any leftover chemicals from World War II. This information is important because it would provide a \u201cbaseline\u201d from which regulatory agencies can compare in gauging the effects of the military\u2019s spent munitions.<\/p>\n The Bureau of Environmental and Coastal Quality is concerned with this lack of data\u2014especially in regards to MCs and their byproducts.<\/p>\n \u201cThere is no baseline data with which to compare, or for [the Navy] to identify increasing contamination levels, and ultimately to react and remediate,\u201d BECQ said, in a summary of their EIS comments on water quality impacts.<\/p>\n \u201cThe [impact document] does not state whether or not they currently possess water quality data for munitions constituents, to compare to future levels, nor do they specify what MCs would be included in live and inert munitions.\u201d<\/p>\n \u201cThe [Navy] does not provide information regarding the model or method used to determine the chemical transport of MCs throughout the water bodies of the CNMI.\u201d<\/p>\n Keany said there could be already some chemical residue from World War II\u2019s extensive bombing and fighting on Tinian.<\/p>\n \u201cIt would be important to understand the current conditions to provide a full analysis of expected effects,\u201d he said. \u201cThere are thresholds for many chemicals in groundwater regarding human health and safety\u2014but there is no such analysis in this Navy EIS.\u201d<\/p>\n \u201cThere is no way to evaluate the risk to human health and safety from the document or predict the risk to groundwater water contamination. No data has been presented even on the existing conditions of the groundwater and soil.\u201d<\/p>\n Keany said the Navy needs to:<\/p>\n -Develop a sampling scheme for groundwater and soil to determine the baseline\u2014using the suggested protocols in the 2012 EPA paper.<\/p>\n -Use this EPA paper and other science documents to develop an analysis framework for predicting levels of soil contamination and risk to groundwater.<\/p>\n -Analyze the information and have it peer reviewed by reputable scientist with relevant experience and knowledge.<\/p>\n -Develop a long-term soil testing program and a protocol for cleanup of all munitions on an annual basis.<\/p>\n -Develop a supplemental environmental impact statement that includes this information and allow agency and public comment.<\/p>\n Significant impact, not any less<\/strong><\/p>\n Both Keany and BECQ disagree with the Navy\u2019s designation of \u201cless than significant impacts\u201d groundwater resources.<\/p>\n When asked if there were enough concerns to compel the Navy to raise their \u201cless-than-significant\u201d designation to \u201csignificant,\u201d Keany said, \u201cAbsolutely.\u201d<\/p>\n \u201cGenerally when analyzing such human health risks the professional approach is to err on the conservative side if there is no data. The Navy has done the opposite,\u201d he said.<\/p>\n These \u201csignificant\u201d or \u201cless than significant\u201d designations concern legal definitions, Saipan Tribune learned\u2014but what exactly is a significant impact as defined by National Environmental Policy Act and Council of Environmental Quality regulations are at issue. If something causes a significant impact\u2014it has to be mitigated, lessened or rescaled, or eliminated under some circumstances.<\/p>\n Saipan Tribune learned that local agencies and government consultants have been tying their EIS review to other federal and local laws outside of NEPA like the Endangered Species Act, Coastal Zone Management Act, Marine Mammal Protection Act, and Clean Water Act.<\/p>\n The Clean Water Act for instance would prevent proposed activities from polluting or contaminating water. And the Coastal Zone Management Act would prevent harm to coastal areas.<\/p>\n In a memorandum on the \u201cLegal Adequacy of the Draft Environmental Impact Statement\u201d for the CJMT project, Dentons\u2014the firm hired to review this document\u2014notes these failures of compliance with law.<\/p>\n \u201cThe [EIS] does not contain data and information necessary to demonstrate compliance with these requirements,\u201d Dentons said.<\/p>\n \u201cOn the contrary, the limited evidence presented in the document suggests that the CJMT would violate both federal and CNMI law,\u201d Dentons said.<\/p>\n BECQ, in their water quality comments, remind the Navy that the \u201cCNMI owns the groundwater of Tinian\u201d and if the Department of Defense would like to use it they \u201cmust apply for a permit and use it in accordance with CNMI law.\u201d<\/p>\n \u201cTinian is a sole-source aquifer system with limited fresh water availability, and the military has provided no evidence that impacts such as contamination, salt-water intrusion, or water shortage due to over-extraction\u201d from military water wells \u201cwould not impact the southern aquifer system.<\/p>\n \u201cTinian residents already struggle to use groundwater resources sustainably, and any negative impacts to these resources due to proposed activities would have significant impacts to the population and the environment,\u201d BECQ said.<\/p>\n","protected":false},"excerpt":{"rendered":" The Department of Navy has neglected to discuss in their environmental impact documents ready-available data…<\/p>\n","protected":false},"author":47,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[94],"tags":[880,26,200,2307],"class_list":["post-206481","post","type-post","status-publish","format-standard","hentry","category-headlines","tag-becq","tag-cnmi","tag-military","tag-nepa"],"_links":{"self":[{"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/posts\/206481","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/users\/47"}],"replies":[{"embeddable":true,"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/comments?post=206481"}],"version-history":[{"count":0,"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/posts\/206481\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/media?parent=206481"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/categories?post=206481"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.saipantribune.com\/index.php\/wp-json\/wp\/v2\/tags?post=206481"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}