In June 2023, Denise Trabbic-Pointer, a volunteer with the Sierra Club, reviewed site information and documents for Julie Akey.
Chemical engineer Trabbic-Pointer found that there was a significant lack of data in the 1996 ATSDR report on which to base their final determination that toxic chemicals in the soil and in the aquifers below Fort Ord were not likely to pose a past, present, or future threat to those living there. Her report follows:
Part 3 of a 5-part series
Fort Ord is poisoned.
In California, Monterey County's Fort Ord Army Base was a pollution hotspot, with a burn pit and groundwater contaminated with toxic solvents and other chemicals. Former base residents are questioning whether exposure to these chemicals could be the cause of illness for thousands of Ford Ord veterans and their families. Julie Akey, a former resident of Fort Ord, collected the names and diagnoses for more than a twelve hundred people, including 138 diagnosed with multiple myeloma like her, a deadly blood cancer.
EPA has identified more than 40 potential chemical hazards on the base, including soils and groundwater. People who lived at Fort Ord were likely exposed to levels of TCE – trichloroethylene through inhalation, dermal contact and ingestion of contaminated drinking water while living on base and base housing. EPA has determined that the chemical can cause kidney cancer, liver cancer and blood cancers like non-Hodgkin lymphoma and multiple myeloma. TCE exposure has also been determined to contribute to autoimmune disease and to developmental cardiac toxicity.[1]
The Agency for Toxic Substances and Disease Registry (ATSDR), a branch of the Centers for Disease Control investigated the site in 1996 and concluded that there was “no apparent public health hazard”. However an investigation by the Associated Press in 2022 highlighted hundreds of sickened veterans and their exposure to toxic solvents, munitions and other chemical hazards.
ATSDR has recently announced that it will reevaluate the impact of contaminated drinking water from the mid-1980s when data on contaminated drinking water were first identified, to mid-1990s, when the base closed.
In August 2022, Akey petitioned ATSDR to conduct a new Public Health Assessment and Health Consultation to reevaluate past exposures to contaminated drinking water for members of the military stationed at Fort Ord, California. The petition requested a new assessment because of the availability of new scientific data since the 1996 ATSDR assessment and because of the number of people diagnosed with various cancers and diseases.
In a May 2023 email to ATSDR, Akey wrote: “Although the base was "closed" by 1996, there were still some things in operations, and it was the housing for all of us stationed at the Defense Language Institute in Monterey who had dependents. After I lived on Fort Ord, the base continued to be redeveloped and repurposed, so although officially it was “closed", it was used for many things, including a new university. Because of this, we feel it is important to expand the years of your re-evaluation of Fort Ord, since there have been people living and working on it continuously since "closure.” Akey had lived in Fort Ord housing during 1996 and 1997.
Following Akey’s petition, the ATSDR received a petition from the Honorable Katie Porter. Representative Porter requested that ATSDR conduct a new health assessment of contaminated drinking water at Fort Ord, California, to determine if the drinking water could have caused harmful health effects. Representative Porter requested that ATSDR reevaluate the health risks considering new science and data and to reissue an updated health assessment.
In February 2023, ATSDR made the determination to reevaluate potential health risks from drinking water exposures that occurred between 1985-1994 at Fort Ord, California.
Denise Trabbic-Pointer
In June 2023, Denise Trabbic-Pointer, a volunteer with the Sierra Club, reviewed site information and documents for Akey. Ms. Trabbic-Pointer is a chemical engineer with a BS and MS in Hazardous Materials Management and a career EHS professional. She retired in January 2019 after 42 years with DuPont and a spin-off company, Axalta Coating Systems. Since May 2019, she has been the Sierra Club – Michigan Chapter, Toxics & Remediation Specialist, working nationally as a technical resource for communities impacted by releases of toxics to air, water and/or soil.
[1] Joseph Griffin, Ph.D., Toxicol., NIOSH, Sci., 57: 345-352, 2000
Ms. Trabbic-Pointer reviewed the ATSDR findings and Fort Ord records and found that there was a significant lack of data in the 1996 ATSDR report on which to base their final determination that toxic chemicals in the soil and in the aquifers below Fort Ord were not likely to pose a past, present, or future threat to those living there.
The following is a summary of considerations that have been proposed to ATSDR in an email from Ms. Akey, based on Trabbic-Pointer’s findings.
1. A historic review of volatilization to indoor air from chlorinated chemicals of concern has not been performed and must be completed in order to fully assess Fort Ord occupant exposures. Historic levels of chemicals of concern in groundwater can be used in this assessment. The review should include buildings where people stationed at Fort Ord would spend a significant amount of time while stationed there over a specified length of time.
2. Cumulative exposures to chlorinated chemicals have not been assessed. Cumulative exposures should include inhalation from volatilization to indoor air, ingestion of drinking water, and dermal contact with drinking water, showering, etc.
3. Historic impacts of per- and polyfluoroalkyl substances (PFAS) have also recently been found in groundwater and drinking water at the base. There is emerging information indicating that there could be synergistic effects of exposure to PFAS and other chemicals, including some of the listed chemicals at Fort Ord, namely trichloroethylene (TCE), tetrachloroethylene (PCE), and carbon tetrachloride. This potential should be included in the ATSDR reevaluation effort. We understand that there is no actual groundwater or drinking water PFAS data available prior to 2014 but there is current information in groundwater indicating very high levels of PFAS and ATSDR should be able to review and consider whether impacted aquifers were used where people could have been historically exposed. PFAS compounds may have degraded to other PFAS compounds over time but levels of total PFAS are likely the same or higher now as in the 90s. The following is a list of resources that includes a discussion of the synergistic effects of PFAS.
List of Resources
● Early life exposure to per- and polyfluoroalkyl substances (PFAS) and latent health outcomes: A review including the placenta as a target tissue and possible driver of peri- and postnatal effects Bevin E. Blake et al… 2020, Toxicology. 2020 Oct; 443: 152565.
● High-content analysis shows synergistic effects of low perfluorooctanoic acid (PFOS) and perfluorooctane sulfonic acid (PFOA) mixture concentrations on human breast epithelial cell carcinogenesis, Paula Pierozan, et al…2023, https://doi.org/10.1016/j.envint.2023.107746
● Combined effects and toxicological interactions of perfluoroalkyl and polyfluoroalkyl substances mixtures in human liver cells (HepG2), Atinuke F. OjoAtinuke F. Ojo et al, 2020, https://doi.org/10.1016/j.envpol.2020.114182
● PFAS Toxicology – What is Driving the Variation in Drinking Water Standards, Christy A. Barlow. GZA Whitepaper
● Strategies for grouping per- and polyfluoroalkyl substances (PFAS) to protect human and environmental health, Ian T. Cousins et al…, 2020, Environ Sci Process Impacts. 2020 Jul 1; 22(7): 1444–1460
The ATSDR reevaluation should consider both the synergistic effects and immune impacts of PFAS on people that lived and worked at Fort Ord.
4. Review of documents indicate that the operating unit 2 (OU2) extraction well and pump and treat system was not operating properly upon startup in October 1995 through at least October 1997, during the time when Akey lived on base. OU2 area contamination and Site 10 PFAS contamination had reached the Upper 180-foot aquifer and there are indications that PFAS has reached Well 29 of the drinking water system wells.
Therefore, the decision by ATSDR to only reevaluate potential health risks from drinking water exposures that occurred between 1985-1994 at Fort Ord, California, ignores the many hundreds of people that continued to live on base through 1995, 1996 and much or all of 1997. Drinking water data for 1995 through 1997 should be obtained and included in the ATSDR reevaluation effort.
5. Precursors to PFHxA, which have been found in at least one of the drinking water wells that services Fort Ord, have not been assessed. In particular, 6:2 FTS and 8:2 FTS must be included in all PFAS analysis at Fort ORD because these compounds will degrade to PFHxA. 8:2 FTS can also degrade to PFOA and is known to be present in AFFF during this time period (1970 – 2016). The truncated list of PFAS analytes used in the Fort Ord investigation leads to a false sense of security that all potential PFAS compounds have been assessed. EPA Method 533 includes these precursors and is recommended for all drinking water analyses. OU2 groundwater and soil should also be assessed using EPA Method 1633 because of the nearby landfill.
6. Groundwater in the Site 10, Burn Pit area should be tested as recommended in the Preliminary Assessment Narrative Report and EPA Method 1633 should be used to analyze the groundwater in order to properly assess all potential PFAS and PFAS precursor compounds.
7. From 1995 through 1997, the Fort ORD Soil Treatment Area (FOSTA) site treated soil from areas of the site that were highly impacted by numerous hazardous chemicals, some known and some unknown, like PFAS. The FOSTA site was very near residential homes and potential impacts to people living in the homes have not been assessed.
The documents that were reviewed only indicate that bioremediation was used in the Corrective Action Management Units (CAMU), but not specifically what the process that was (i.e., bioventing, biosparging, bioaugmentation) used or whether there was a potential of emissions to air resulting from the treatment process. A review of the types of treatment performed in this area, characterization of the wastes that were treated, and the potential for airborne particulate and/or emissions to air that may have reached people living near it during this time period, must be reviewed and evaluated during the ATSDR current reevaluation of overall exposures.
The following are problems identified during our review of available data and information that led to the recommendations listed above. Supporting information and links to documents are included to further support our arguments.
1. There is a lack of data available about contaminants in drinking water on base and at base housing during the period 1994 through 2017. After 2017, water quality reports are available from the Marina Coast Water District. Contaminated ground water suggests a concern for human exposure.
2. The ATSDR plan to reevaluate hazards at Fort Ord appears to be only for drinking water exposure and will likely not provide information about all routes of exposure experienced by those working and living on the base in the years that Ms. Akey was there and beyond. In order to understand a person’s total exposure, all routes of exposure must be assessed (i.e., vapor inhalation, ingestion and dermal absorption)
For example, only one assessment of volatilization of the chemicals of concern to indoor air was performed in 2004 and only in a residential area in the vicinity of Lexington Court and Ready Court, Fort Ord. This means that the potential for people living and working at Fort Ord to be exposed to harmful chemicals via inhalation has not been fully assessed.
3. There is an obvious lack of information about historic per- and polyfluoroalkyl substances (PFAS) levels in ambient air, soil, surface water, groundwater, and drinking water in and around Fort Ord. Exposure to PFAS can be the cause for many of the illnesses observed in people that have worked and lived at Fort Ord.
In addition to cancer, many autoimmune disorders are alleged by people that lived and worked at Fort Ord. According to the CDC/ATSDR “What are the health effects of PFAS?” website:
“CDC/ATSDR understands that many of the communities we are engaged with are concerned about how PFAS exposure may affect their risk of COVID-19 infection. We agree that this is an important question.
CDC/ATSDR recognizes that exposure to high levels of PFAS may impact the immune system. A National Toxicology Program review found that exposure to perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) is an immune hazard to humans based on a high level of evidence that PFOA and PFOS suppressed the antibody response from animals and a moderate level of evidence from studies in humans (NTP, 2016). More research is needed to understand how PFAS exposure may affect illness from COVID-19.”
4. Available documents indicate that the installation of extraction wells and startup of the Fort Ord operating unit 2 (OU2) pump and treat system was expedited in order to meet an October 1995 planned startup. Further, a January 1997 OU2-492 Plume Delineation Draft Report found that the installed treatment system was insufficient to resolve the extent of the plume and that “the plume in the upper 180-foot aquifer is considerably larger along the southern edge than in early 1995.” This appears to indicate that the initial treatment system actually expanded the contamination plume. The following documents support the premise that the pump and treat system was not effective upon startup and that it could have been because the design and installation was rushed.
a) January 1997 OU2-492 Plume Delineation Draft Report
b) There was an apparent abbreviated build and startup of the UO2 extraction system. See OU2-418. August 1995
c) OU2-499 November 1995 – it appears that the CalEPA DTCS did not agree with the expedited plan and asked that it be extended and that a more foresighted plan be devised. The conclusion was that the expedited plan was not protective enough.
d) BW-2769 August 1997 – IT Corporation (IT) prepared this Contractor Quality Control Plan (CQCP) on behalf of the U. S. Department of the Army (Army) to address the construction of the expanded treatment facilities at the Operable Unit 2 (OU2) groundwater remedy at the former Fort Ord, located near Monterey, California.
e) As late as October 1997, OU2-559 Draft Final OU2 Plume Delineation Investigation Work Plan Addendum indicates that there are still issues with the OU2 extraction and GW treatment system.
In addition to the above, there is more recent information available that indicates that the Fort Ord operating unit 2 (OU2) pump and treat system may continue to be inadequate for removal of TCE, particularly from the 180-foot aquifer. A 2002 report, “A spatial and temporal analysis of trichloroethylene contamination in the aquifers under the former Fort Ord landfill” by Kristy J. Meyer from California State University, Monterey Bay, came to the following conclusions.
“Increases in trichloroethylene (TCE) concentration outside of the source area are more relevant than those found inside the area. My initial hypothesis that areas of high concentration are located near the landfill cells was not supported by the data. It is expected TCE will continue to be found in high concentrations under the landfill for many years to come because of the complex nature of TCE contamination and the hydrogeography of the aquifers. The data supported my hypothesis regarding adequate plume contamination in the 180-foot aquifer. More data would be needed to confirm my hypothesis in both the A- and 180-foot restricted aquifers. I feel I met my project goals of compiling relevant information on the site and trichloroethylene as well as providing an easy-to-interpret representation of how the TCE plume has changed over time in the A-, 180-foot, and 180-foot restricted aquifers. In addition, I think it is important to continue this project using available well data prior to 1997 and data available from sampling events after Spring 2001.
I believe the data and the scientific literature reviewed supported my final hypothesis that the current remediation strategy is appropriate for the OU2 site. However, I feel it will be necessary in the future to re-evaluate the feasibility of the Army’s goal to reduce TCE concentrations below EPA drinking water standards. At that time, I suggest developing a cost/benefit analysis that includes a risk analysis for using natural attenuation in combination with pumping or bioremediation to reduce TCE contaminant levels to their lowest possible levels.”
5. Site 10, the former Burn Pit, is very near where Ms. Akey lived when stationed at Fort Ord from 1996 – 1997. The “Preliminary Assessment Narrative Report, Per- and Polyfluoroalkyl Substances”, Site 10 - Groundwater Conclusions states the following.
“The release of PFAS from Site 10 to the Upper 180-Foot Aquifer is suspected because of reported historical use of AFFF for training and demonstration purposes at the site for at least two decades. Due to relatively high hydraulic conductivity, the potential for migration of PFAS in groundwater is high and there are downgradient water supply wells. Therefore, additional groundwater investigation is recommended.”
6. One PFAS chemical, PFHxA, has been found in Well 29, which is one of the wells that serves drinking water to the Marina Coast Water District. PFHxA is a degradation product of precursors like 6:2 FTS and 8:2 FTS, which are common precursors found in 2nd generation and modern firefighting foams. PFHxA is also commonly found in landfill leachate and one of the contamination sources at Fort Ord OU2 is a former landfill. The Fort Ord PFAS investigations only analyzed the Method 537.1 list of PFAS compounds that notably does not include long- or short-chain fluorotelomer sulfonates (FTS). This further supports the recommendation that Method 533 must be used to assess Fort Ord past and current drinking water for the presence of all potential PFAS compounds.
7. From 1995 through 1997, the Fort Ord Soil Treatment Area (FOSTA) site was used as a Corrective Action Management Units (CAMU) to bioremediate soil containing petroleum hydrocarbons excavated from Interim Action sites at Fort Ord, including Sites 10 and 10A and Site 21. The FOSTA Area was very near where Akey lived when stationed at Fort Ord from 1996 – 1997.
Prior to designating the FOSTA as a CAMU, approximately 6,000 cubic yards of soil was treated at the FOSTA and transported and placed at the OU2 Fort Ord Landfills (e.g., soil from Sites 8, 10, 20, 34, and 40). Another approximate 2,000 cubic yards of soil from interim action (IA) sites stockpiled for bioremediation at the FOSTA were transported to the OU2 Fort Ord Landfills. The FOSTA was shut down in April 1997.
Julie Akey
Julie Akey arrived at Fort Ord in 1996 at age 25. She says she drank the water and ate the vegetables she watered with the base’s water supply. At age 46, she was diagnosed with multiple myeloma, a blood disease where cancerous plasma cells accumulate in the bone marrow. Trichloroethylene, (TCE) is held as a likely suspect because it is linked to multiple myeloma. TCE is mentioned a dozen times in the AP report. PFAS is also linked to multiple myeloma, but it is never addressed.
There is an urgent need for a structured study of the data and the people that worked and lived at Fort Ord and the number of illnesses that have been diagnosed. Julie has collected data on > 1250 people and receives more reports of illnesses from others nearly every week. The following is a snapshot of Akey’s findings relating to the cancers and autoimmune disease reported by people that were formerly stationed at Fort Ord. The numbers of blood cancers are notable.
According to information collected by Akey, 417 people who have lived at Fort Ord have been diagnosed with an Autoimmune Disease
Some of the people diagnosed with an autoimmune disorder also have cancer. The following are the incidents of diagnosed autoimmune disorders at Fort Ord.
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Financial support from the Downs Law Group makes it possible for us to challenge federal agencies like we are doing here with the ATSDR.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS and other contaminants.
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If you spent time in the military and you think you may be sick as a result of your service, think about joining this group to learn from others with similar issues. Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination?
Join the Veterans & Civilians Clean Water Alliance Facebook group. (2.5 K members and growing rapidly.)