Summary of correspondence between Julie Peters Akey and ATSDR officials regarding Akey’s petition request concerning contamination at Fort Ord, CA
Part 2 of a 5-part series
By Pat Elder
October 8, 2023
On August 14, 2022, Julie Peters Akey petitioned the Agency for Toxic Substances and Disease Registry, (ATSDR) to conduct a new Public Health Assessment and Health Consultation to reevaluate past exposures to contaminated drinking water for members of the military and their dependents 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 extraordinary number of people diagnosed with various cancers and diseases.
The ATSDR is also evaluating a similar petition request, submitted by the Honorable Katie Porter, (D-CA – 45) Representative Porter requested that ATSDR conduct a new health assessment of contaminated drinking water at Fort Ord to determine if the drinking water could have caused harmful health effects.
Akey informed the ATSDR that she filed the petition on behalf of 1,200 people in her Cancer and Illnesses from Fort Ord Facebook group. The number of diseased residents has now swelled past 1,250 souls.
Akey received notification in April, 2023 that ATSDR had assembled a site team to address the petition requests from her and from Reps. Katie Porter and Rep. Jimmy Panetta, (D-CA-19). ATSDR informed Akey it would re-evaluate “potential health risks” from drinking water exposures that occurred between 1985-1994.
The ATSDR promised Akey that it would share the findings of its re-evaluation of past drinking water data with the public in a written report on their website (https://www.atsdr.cdc.gov/).
Akey informed the agency in April 2023 that she was concerned about the end date of ATSDR’s review that terminates in 1994 since "active operations at the fort ended in 1994". Julie Akey was active-duty Army living on Fort Ord in 1996 and 1997, a period after the time of the agency’s review.
Akey informed the Agency that she had water reports showing exceptionally high levels of contaminants, especially trichloroethylene, TCE, during the time she was there. Julie was housed at Fort Ord while she was studying Arabic at the Defense Language Institute, (DLI) in Monterey. There are a large number of people who are sick from that time frame. Julie has two cancers and was just diagnosed with a potentially fatal and extremely rare auto-immune disease. These diseases are likely associated with the contaminants she consumed.
Akey asked the ATSDR to expand the years in question since active duty troops and their dependents were still living on Ord.
In May the ATSDR responded that they intended to analyze the sampling data from the same time frame included in the 1996 Fort Ord public health assessment. This would leave out the time that Akey was there.
The Fort Ord drinking water system drew water from groundwater aquifers. Groundwater contamination levels have been higher in some areas (closer to the plume) and lower in others (further from the plume). To estimate drinking water exposures most accurately for our analysis, we are using data collected from drinking water wells. We are not analyzing data from groundwater monitoring wells since those wells were not used for drinking water.
The ATSDR asked Julie to provide the agency with the drinking water reports she cited so that they could compare them with what they are evaluating for Fort Ord.
Julie responded by sending various water testing reports from 1996-1997 when she lived on Fort Ord. (see the links below).
After Julie 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, Akey’s group insists the ATSDR expands the years of its re-evaluation of Fort Ord.
Specifically, Akey asked the agency to consider this data:
· TCE levels of 230 in Table 5, p. 4, from "Tables" of "Water Testing Reports Dec 96-Sep 97". This is 46 times greater than the Acceptable Concentration Level, (ACL). There are many extremely high TCE levels in this report.
· 1,1,1-TCA (also known to cause multiple myeloma) levels of 18.8 in Table 5, p. 6, from "Tables...". This is 9 times greater than ACL
· PCE (also known to cause multiple myeloma) levels of 32 in Table 5, p. 14, from "Tables...". This is 6 times greater than ACL
· TCE levels of 26 ug/l in Table 3, p.1, from "April 1996 Monthly Operations Data Summary Report"
· cis-1,2-DEC/dichloroethene (which also causes multiple myeloma) levels of 12 ug/l in Table 3, p .1, from "April 1996 Monthly Operations Data Summary Report."
· TCE levels of 18 ug/l in Table 3, p. 1, from "December 1996 Monthly Operations Data Summary Report"
· Methyl Chloride/DCM (which also causes multiple myeloma) levels of .8 ug/l in Table 3, p. 1, from "December 1996 Monthly Operations Data Summary Report."
Tables, water testing reports Dec 96-Sep 97.pdf
Julie also sent the ATSDR the report on PFAS: Technical Summary Report — Perfluorooctanoic Acid and Perfluorooctane Sulfonate Basewide Review of Historical Activities and Groundwater Monitoring at Operable Unit 2
Former Fort Ord, California, February 27, 2020
https://docs.fortordcleanup.com/ar_pdfs/AR-OU2-722A/OU2-722A.pdf
She requested the agency add an evaluation of documented PFAS contamination to their current reevaluation. Although it was not included in the ATSDR’s initial evaluation, the Department of Defense and the federal government have recognized the dangers of PFAS since the 1970’s. Since then, science has proven the danger of PFAS, while California classifies two PFAS compounds – PFOS and PFOA – to be human carcinogens. Julie asked the ATSDR to look at well MW-OU2-23-180 with PFOA measuring 113 parts per trillion and PFOS at 447 ppt.
The EPA's interim Lifetime Health Advisory is .004 ppt for PFOA and .02 ppt for PFOS. The PFOA levels in this report are 28,250 times higher than the EPA threshold while the PFOS levels are 22,350 above the EPA advisory.
Julie Akey’s work has had a profound influence worldwide.
Julie cited these high levels while requesting that PFAS be included in the reevaluation. There are, however, much higher levels of PFAS in the groundwater.
The Army Helicopter Defueling Area was not far from where Julie lived. The groundwater at 99.5 feet below the surface contained 19,000 ppt of PFOS,1,340 ppt of PFOA, and 47,555 ppt of total PFAS. Those tests were conducted on 11/30/22.
19,000 ppt of PFOS is 950,000 times over the EPA's Interim Lifetime Health Advisory of .02 ppt and the PFOA concentrations are 335,000 times over the EPA's threshold of .004 ppt.
See Table 7. Site 40A ‐ Site MW 40A-01-A https://docs.fortordcleanup.com/ar_pdfs/AR-BW-2942//BW-2942.pdf
The ATSDR reviewed what Julie sent them and they replied that the data tables Julie shared are from monitoring wells (MW’s) used to keep track of the cleanup progress. The ATSDR argues that these wells were not used to provide water to residents at Fort Ord. They stated that these monitoring wells were installed near the landfills. They say the monitoring wells are not used for drinking water purposes.
The ATSDR replied that the method approved for treating the contaminated groundwater included the use of extraction wells. These wells drew the contaminants from the plume into the treatment process. The contaminated groundwater was then treated in a two-stage process. First, it was pumped through granulated activated carbon (GAC) to remove contaminants. Then it was treated through ultra-violet oxidation equipment to remove any remaining contaminants. Treated water was then injected back into the aquifer (groundwater).
According to ATSDR, groundwater treatment is still going on in 2023.
Julie asked the ATSDR to review the contaminant levels that were elevated above the Aquifer Cleanup Levels (ACLs) in the tables of water testing reports from Dec 96-Sep 97. Julie inquired about the TCE, TCA, and PCE measurements.
The ATSDR reviewed the tables and determined that the sample measurements for these three contaminants came from monitoring wells in the 180-foot aquifer. These measurements were not from drinking water wells. The ATSDR argues that these measurements were not from drinking water wells so they do not reflect what residents of Fort Ord were drinking.
Julie asked for the ATSDR to respond to following levels found in groundwater:
TCE at 26 µg/L,
cis-1,2-DCE at 12 µg/L, and,
another TCE concentration of 18 µg/L.
The ATSDR responded that these results came from the groundwater treatment system, and more specifically from samples taken from groundwater prior to it going into the GAC treatment units. So again, since these measurements were not from drinking water samples; they do not reflect the drinking water quality at that time.
Julie also asked about methylene chloride at levels of .8 ug/l in Table 3, p. 1, from "December 1996 Monthly Operations Data Summary Report.”
The ATSDR responded that the measured level of .8 ug/l was from a sample collected in two regular trip blank (Lab-FLD-Lab) samples. “Trip blanks” are samples prepared in the laboratory and “used to document contamination attributable to shipping and field handling procedures (i.e., diffusion of volatile organics through the septum during shipping and storage).” See a definition of trip blanks here:
The ATSDR explained that it is possible that the blanks were contaminated in the lab when prepared. Additional discussion of the methylene chloride results appears on p. 3 of the PDF December 1996 Monthly Operations Data Summary Report.
The ATSDR says a key point about the methylene chloride measurements is that they came from the groundwater treatment system, and not from a drinking water system.
ATSDR response to Julie on PFAS
A model of PFOS, one of more than 15,000 PFAS compounds.
Regarding PFAS contamination, The ATSDR says it is aware of ongoing PFAS investigations at Fort Ord. Unfortunately. They say local drinking water providers did not sample for PFAS prior to 2014, so, no data is available to evaluate whether people were exposed to PFAS in drinking water in the 1980s and 1990s. They state that a lack of PFAS sampling in drinking water is an issue in many drinking water systems across the US, not just in the California central coast region. They directed Julie to the Marina Coast Water District which publishes information on PFAS contamination and sampling in their annual Consumer Confidence Report.
ATSDR will re-evaluate potential health risks related to drinking water exposures that occurred between 1985-1994. They say they will re-analyze drinking water data from 1985-1994. They’re received drinking water data for this period from the U.S. Army and the Marina Coast Water District.
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