Letter from national expert calls for Fort Ord to be added to the DoD list of locations where Agent Orange was stored and used
By Pat Elder
May 8, 2024
The historic letter from Denise Trabbic-Pointer to the Armed Forces Pest Management Board posted in the Federal Register (4/6/24) states, “The new discovery of the presence and extensive use of Agent Orange at the base was devastating in its implications, in addition to everything else we already knew.”
Despite the compelling evidence described below, the DOD still insists the toxins were never used at Fort Ord. The same is true for dozens of bases across the country.
The DoD says it reviewed thousands of government documents from a variety of sources to include the National Archives and Records Administration, Air Force Historical Research Agency, United States Department of Agriculture, National Agricultural Library, and Defense Technical Information Center.
According to the Pentagon, information obtained from these documents was assessed against criteria developed jointly by VA and DoD to identify specific locations inside and outside the United States where certain herbicide agents and their chemical components were tested, used, or stored. They say Agent Orange was never used at Fort Ord.
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Vets exposed to Agent Orange at US bases
denied VA compensation - By Hannah Norman
and Patricia Kime KFF Health News
This article presents overwhelming evidence that Agent Orange was recklessly used at Fort Ord for many years, endangering thousands.
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The historical record is clear that the Army sprayed 9,000 acres with Agent Orange or similar herbicides at Fort Ord, California for more than 20 years while hundreds of thousands of soldiers trained for wars in Korea and Vietnam. The use of Agent Orange is more clearly documented at Fort Ord than anywhere on earth, with the possible exception of Okinawa and Panama where many have been exposed and sickened. The VA does not extend presumptive status to sick and dying veterans claiming Agent Orange exposure in Panama and Okinawa. The VA, however, admits it tested, disposed, or store herbicides like Agent Orange in Cambodia, Canada, India, Johnston Atoll, Korea, Laos, and Thailand. A worldwide groundswell of opposition is growing to confront the official obfuscation and demand compensation.
How could the DOD leave Fort Ord
off of the list of bases where regulatory
presumptions of exposure to Agent Orange
are established?
The Armed Forces Pest Management Board (AFPMB) has been assigned the responsibility to maintain and update this list. Little is known about this board.
To: Armed Forces Pest Management Board
From: Denise Trabbic-Pointer
e-mail: osd.pentagon.ousd-atl.mbx.afpmb-tactical-herbicides@mail.mil
RE: Request to add Fort Ord to the DoD List of locations where herbicide active ingredients were stored and used
April 6, 2024
Introduction
I am a Chemical Engineer with a BS and MS in Hazardous Materials Management, a career EHS professional and a Certified Hazardous Material Manager (CHMM) Emeritus. My education and EHS career included an emphasis on the health impacts and effects of exposure to chemicals in the workplace. I retired in January 2019 after 42 years with DuPont. The last 7 years were with a spin-off company, Axalta Coating Systems, as their Global Environmental Competency Leader. Since May 2019, I have 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.
For nearly one year now, I have read, researched, and written extensively about the historic and current contamination at Fort Ord. I’ve researched and assessed the cumulative and synergistic impacts of the numerous chemical contaminants in soil, wastes, and groundwater to human health and the environment and have heard the heart-breaking stories of deadly illnesses experienced by veterans and their families that lived and worked there. The relatively new data indicating the presence of high levels of per- and polyfluoroalkyl substances (PFAS) at the base was yet another unpleasant, but not unexpected finding. This new discovery of the presence and extensive use of Agent Orange (AO) at the base was devastating in its implications in addition to everything else we already knew.
The potential exposures to the active ingredients in AO during the time that it was used at the base cannot be overstated. The people that applied it, mixed it, and maintained the equipment used for spraying, solders training in areas where it was used, families captive in their homes downwind of where it was used or made airborne by excavation activities and prescribed burns across the base, were all exposed. And there are many more ways they could have been exposed. The insidious properties of Agent Orange after the active ingredients were past their half-lives and gone, dioxin and furans remained.
Health outcomes from exposure to AO
The VA has recognized certain cancers and other health problems as presumptive diseases associated with exposure to Agent Orange or other herbicides during military service. Veterans and their survivors may be eligible for benefits for these diseases. A list of diseases is located at this link. Five more diseases are proposed in the Department of Veterans Affairs (VA), 38 CFR Part 3, RIN 2900–AR10, Updating VA Adjudication Regulations for Disability or Death Benefit Claims Related to Exposure to Certain Herbicide Agents.
Health outcomes from exposure to dioxin/furans
The CDC assessed health hazards from Dioxins, Furans and Dioxin-Like Polychlorinated Biphenyls and links to other agency findings are located at this link.
EPA Dioxin Website. Dioxin and dioxin-like compounds (“dioxins”) are persistent, bio accumulative, toxic (PBT) chemicals characterized by EPA as probable human carcinogens. It also biomagnifies similar to PCB where animals eat impacted foliage and other animals eat them through the food chain and dioxin levels are increasingly magnified. People near dioxin-impacted environmental media (soil, water, air) can be exposed to dioxin through oral, dermal and inhalation routes. Any burn areas where chlorinated solvents and/or used oil was included will likely include dioxin in the list of soil/GW contamination.
Active movement and remediation of soil containing dioxin would likely have been cause for particulates to become airborne. This risk would have been particularly increased when the facility was performing closure activities (1995 to final closure activity).
Furans should be included whenever mentioning dioxin as they are created in essentially the same manner. There are 210 different dioxins and furans. All dioxins have the same basic chemical "skeleton," and they all have chlorine atoms as part of their make-up. Furans are similar but have a different "skeleton". Furan is listed in the Department of Health and Human Services list of carcinogens and considered as possibly carcinogenic by the International Agency for Research on Cancer (IARC).
How dioxin/furans are created (specific to chemicals and activities at Fort Ord)
Dioxins are mainly byproducts of industrial practices. They are produced through a variety of incineration processes, including improper municipal waste incineration, and burning of trash, and can be released into the air during natural processes, such as forest fires and volcanoes.
At Fort Ord, wherever waste, trash or other materials were burned are likely locations where dioxin/furans could be found. A common practice at Fort Ord was to perform prescribed burns prior to munitions cleanup. The following is from the 2019 document OE-0973, Prescribed Burn Frequently Asked Questions: Former Impact Area, from the Fort Ord Base Realignment and Closure Office.
A prescribed burn at Fort Ord
“Prescribed burns are an important part of the munitions cleanup and are also required under an agreement between the Army and the U.S. Fish and Wildlife Service as a part of the Installation-Wide Multispecies Habitat Management Plan.
The prescribed burn will make the ground surface accessible for safe munitions removal to follow.”
Because closure of Sites at Fort Ord were historically confirmed and accepted by relevant agencies, there is no recourse that we are aware of to request that areas should be resampled using today’s advanced analytical methods and knowledge of the hazards of the contaminants. But what is a legitimate request from veterans and their families is to insist that ATDSR include this information and considerations in their new review of health hazards posed to people living and working at Fort Ord during the time period they have determined and through facility cleanup activities.
Documented evidence of the storage and use of Agent Orange at Fort Ord
The following are documents and facts regarding the use of and potential exposure to Agent Orange and dioxin/furans by veterans, their families and other workers that lived and worked at Fort Ord Army base on Monterey Bay in California.
According to the VA, the two active ingredients in the Agent Orange herbicide combination were equal amounts of 2,4-dichlorophenoxyacetic acid (2,4-D) and 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), which contained traces of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). The dioxin TCDD was an unwanted byproduct of herbicide production. The following are documents and facts regarding the use of and potential exposure to Agent Orange and dioxin/furans by veterans, their families and other workers that lived and worked at Fort Ord Army base on Monterey Bay in California.
In summary, new information includes:
1. There is documented evidence that indicates the active ingredient of Agent Orange was stored and extensively used at Fort Ord.
2. There was potential exposure, not only to Agent Orange, but also to dioxin/furans across a large portion of Fort Ord.
3. Exposure to these chemicals posed serious health hazards to veterans, their families and other people living at Fort Ord historically and throughout closure activities.
4. There are gaps in historic data and information about the potential exposure to Agent Orange by veterans and their families that lived and worked at Fort Ord, primarily because RCRA and site closure documents do not always include dioxin/furans as possible analytes. There is also increased knowledge about the hazards of these chemicals and these facts need to be considered in the current ATSDR Fort Ord reevaluation as well as any new claims submitted to the VA.
Key documented proof that Agent Orange (AO) was used at Fort Ord
From the VA, Citation Nr: 1235530, Decision Date: 10/15/12, Archive Date: 10/23/12, DOCKET NO. 09-49 139, https://www.va.gov/vetapp12/files5/1235530.txt
“Notably, the Veteran has submitted a letter from the Department of the Army, dated in December 1980, noting that the Pest Control Shop at Fort Ord had monthly records dating back to January 1973 of all herbicides used on that installation, and that 2-4-5 T and 2-4 D usage was included in the records.”
·POISON OAK CONTROL WORK AT FORT ORD, CALIFORNIA Floyd L. Otter Management Agronomist U.S. Army, Fort Ord, California, Not Dated
https://ucanr.edu/repository/a/?a=164771
AO wastes stored at Fort Ord – Further documented proof
The precise building or location referred to as the “Pest Control Shop” by veterans where AO was reportedly stored could not be confirmed. However, available information suggests that wastes containing AO active ingredients, 2,4,5-T and 2,4-D, were stored at the DRMO Hazardous Waste Container Storage Unit located near what is currently the Arts Park at the former East Garrison.
The following cited documents confirm that wastes containing AO active ingredients were stored at the DMRO Hazardous Waste Container Storage Unit.
When no longer useful if its intended purpose or if accidentally released to the environment, Agent Orange is a hazardous waste. Subpart D, 40 CFR 261.31 of RCRA includes a list of hazardous wastes from non-specific sources (aka F-Codes). F027 on the list is the hazardous, waste code for the active ingredients of AO and is characterized by EPA as “Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols.” F027 is agent orange.
“Draft” Final Closure Plan for the DRMO Container Storage Unit, Appendix B is the 1995 Part A RCRA permit application and it indicates that up to 1,000 lbs/year of F027 waste might be stored in the DMRO Container Storage Unit prior to offsite disposal. The Part A permit is a regulatory document that was signed and certified by responsible Department of Defense personnel.
RCRA Closure Certification Report, DMRO Hazardous Waste Container Storage Unit, Former Fort Ord, California, December 6, 2000. Section 5.0 Summary and Conclusions of document BW-2083 (page 12) assesses that approximately 54 cubic yards of soil was removed as part of the RCRA closure of the container storage unit and was taken to the OU2 landfill “for use as the foundation layer”. Appendix E of the same document includes analytical results of chemicals from soil and sediment samples as well as equipment confirmatory rinsate samples from RCRA closure activities of the DMRO Hazardous Waste Container Storage Unit.
Components of AO, 2,4,5-T and 2,4-D, are not included in the Appendix E Chemical Data Report, likely because of their short half-lives in the environment. However, 2,4,5- and 2,4,6- trichlorophenol are on the Chemical Data Report. 2,4,5-trichlorophenol is an intermediate in the manufacture of the herbicide 2,4,5-Trichlorophenoxyacetic Acid (2,4,5-T) and as a fungicide and bactericide.
What is notable about the Appendix E Chemical Data Report is that dioxin and furans were not included in the analyses, even though they are known byproducts of Agent Orange and records indicate that waste AO was stored at the DRMO Storage Unit. “Dioxins and furans” is the abbreviated or short name for a family of toxic substances that all share a similar chemical structure and are noted for their toxic, persistent, and bioaccumulative properties. Dioxins, in their purest form, look like crystals or a colorless solid. Most dioxins and furans are not man-made or produced intentionally but are created when other chemicals or products are made. Of all of the dioxins and furans, one, 2,3,7,8-tetrachloro-p-dibenzo-dioxin (2,3,7,8 TCDD) is considered the most toxic. The fact that DoD did not include analysis for dioxin/furans under the DRMO Storage Unit is a significant gap in information that the DoD should include in their review and that ATSDR should take into consideration in their current reevaluation.
The other disturbing discovery from document BW-2083 is that the DoD followed proper closure of the DRMO Hazardous Waste Container Storage Unit by excavating soil from under the Storage Unit. However, what they did with the soil that was removed was to take it to the OU2 landfill “for use as the foundation layer”. Suffice it to say, using known impacted soil to line a landfill is not a great idea. The OU2 landfill was and continues to be the source of significant groundwater contamination at Fort Ord, including Trichloroethylene (TCE) and other chlorinated solvents as well as per- and polyfluorinated substance (PFAS). The DoD has operated a groundwater pump and treatment system since the mid-1990s, with limited success initially, to control the spread of the contaminants and with some success more recently. They continue to monitor the groundwater on a regular basis but to my knowledge, dioxin/furans have not been included in any of the analyses. This is yet another consideration for the DoD to review and the ATSDR to include in their current reevaluation of the health hazards posed to human health at Fort Ord over the years..
Taken together, the above referenced documents and related information confirms the use and storage of Agent Orange at Fort Ord and the likely exposure routes for veterans and their families that lived and worked there. For these reasons, Ford Ord must be added to the “DoD List of Locations Where Tactical Herbicides and Their Chemical Components Were Tested, Used or Stored Outside of Vietnam.”
Respectfully submitted,
Denise Trabbic-Pointer, MS, BS, CHMM Emeritus
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I will be travelling to Ireland, UK, and Germany in July and to Japan in August to meet up with environmental activists to test surface waters draining from industrial and military sites. It’s important work. It draws attention to the issue! I’m trying to arrange it so that I don’t have to take a bath. Please help! Each test kits costs $79. Please make a note that your contribution is for testing waters in Europe and Japan. - Thanks, Pat
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