MASSACHUSETTS MILITARY RESERVATION (MMR)
The Cape Cod Group has been working on a variety of issues at the Massachusetts Military Reservation since 1989, when the Cape Cod Group was founded and the MMR was added to the federal list of Superfund cleanup sites. The MMR sits at the top of the groundwater lens on the Upper Cape, which supplies drinking water for the citizens of this region. Military training at the site began in the 1940's, and toxics from these activities have polluted large portions of Cape Cod's sole source aquifer for drinking water. There are two areas of main concern within the MMR, Otis Air Force Base (AFB) in the southern half and Camp Edwards in the northern half. In addition to groundwater contamination from these sites, potential environmental and human health concerns are associated with a radar system operated by the U.S. Air Force within the MMR.
Otis Air Force Base
Numerous pollution plumes have traveled from this site into the surrounding neighborhoods, where most of the residents used to use private wells. Over time the military provided funding to area towns to provide town water to those residents whose water supply was threatened by the MMR groundwater pollution. In 1987 the Town of Falmouth had to close its Ashumet Valley water supply system because of groundwater contamination by volatile organic carbon (VOC) contaminants emanating from Otis AFB. The Superfund cleanup is being conducted by the Air Force Center for Environmental Excellence (AFCEE) under the direction of the Massachusetts Department of Environmental Protection (Ma. DEP) and the U.S. Environmental Protection Agency (EPA).
Unlike the southern portion of the MMR, the northern portion has not yet been designated as a Superfund site, despite groundwater pollution detected under the Camp in the mid-90’s. In 1987, the EPA issued a cease-fire that banned firing howitzers/mortars and required the Army National Guard (ANG) to conduct a study on the extent of groundwater contamination by explosives/propellants. This cleanup and remediation effort is governed by the Safe Drinking Water Act, and oversight of the ANG cleanup efforts at Camp Edwards is provided by the EPA. Unlike the Superfund cleanup on the southern portion of the base, for which state/federal standards exist for the maximum permissible levels of toxic contaminants in drinking water, these cleanup guidelines are lacking for the toxic contaminants associated with explosives and propellants.
Ma. DEP recently proposed a 2 parts per billion maximum contaminant level (mcl) for perchlorate (component of propellants), which is supported by the Massachusetts Chapter-Sierra Club. This standard is strongly opposed by the Department of Defense (DOD) and other polluters, who favor EPA's lax 24.5 ppb standard for perchlorate. Tungsten was recently discovered in the soil/groundwater beneath the firing ranges at Camp Edwards that utilize "green ammunition" (combination of tungsten and plastic). This metallic compound is being examined in Nevada as a possible cause of high childhood leukemia rates. Unlike the case of perchlorate (which is a widely distributed contaminant that poses a threat to iodine uptake in the thyroid glands of babies and children), the ANG has begun removal of the tungsten-contaminated soil at the firing ranges. The difference is that tungsten contamination of groundwater from military training nation-wide is limited in extent, while perchlorate contamination is widespread nationally, with large remediation costs if other states adopt the Ma. DEP 2 ppb mcl. The MMR is a test case for other Sierra Club entities on the potential environmental hazards posed to drinking water from military training practices (past and present). Given the current federal policy to emphasize training over environmental protection, it is important for the Sierra Club to insist that the military restore the water quality in our sole source aquifer.
Given the differences in the types of contaminants in the groundwater and the regulatory laws (Superfund and SDWA) overseeing the cleanup, the AFCEE cleanup of Otis AFB is much further along than the ANG’s cleanup of Camp Edwards. AFCEE works more collegially with the regulators (Ma. DEP and EPA) than does the ANG with the EPA. Both AFCEE and the ANG continue to find new areas of polluted groundwater on the MMR and offbase, so cleanup progress is two or three steps forward (removing contaminated soil at source areas and establishing pump/treatment/reinjection of clean water systems to remove contaminants from groundwater) followed by one step backward (new contamination discoveries or bureaucratic obstacles to cleanup).
In the late 1990's the Sierra Club combined with other groups (business and environmental) to form a coalition that supported the development of a master plan for the MMR that highlighted the goal of protecting the quality of our drinking water and preserving the habitat for state-listed species that occur in the grasslands and pitch pine/scrub oak barrens at the MMR, while allowing compatible military training. This plan was developed by the Community Working Group (CWG), which had a representative from the Cape Cod Group. The CWG plan was adopted by the Massachusetts Executive Office of Environmental Affairs (EOEA) and Governor Jane Swift. A state Environmental Management Commission (EMC) was established to guide activities at the MMR (replacing the military governance of this land that is leased from the commonwealth for training). The rapid response to the tungsten soil contamination was spurred on by the EMC
and the Massachusetts Army National Guard, which shows that the CWG plan has enhanced action to address community concerns. This could serve as a model for elsewhere in the country.
PAVE PAWS Radar
The Air Force (AF) operates the PAVE PAWS phased array radar on land at the MMR that they own. This radar system is designed to detect ballistic missiles fired from submarines and track objects in space. This system became operational in 1978 and the AF never followed up on its promises to examine possible adverse effects from the phased array radar system, which exposes our citizens to side lobe radiation 24 hours per day, seven days per week. Given the high cancer rates on Cape Cod, our Congressional delegation (Senators Kennedy and Kerry; Congressman Delahunt) arranged for federal funding to examine this problem, a full 20 years after the system was installed. This eventually led to the formation of the the PAVE PAWS Public Health Steering Group (PPPHSG) which has overseen studies on the radar exposure patterns on Cape Cod (Broadcast Signal Laboratory) and potential health impacts study (International Epidemiology Institute). On a separate track the National Research Council/National Academy of Sciences (NRC/NAS) received governmental funding (arranged by our Congressional delegation) to examine the PAVE PAWS radar, issuing reports in 2005 and 2006.
The Sierra Club hopes to spur a public discussion on how to convert these scientific studies into public health policy. This is a challenge since scientists and regulators don't want to take action unless a statistically significant cause/effect relationship can be established. Given the long delays between exposure to agents that can promote cancer and the incidence of the disease, meeting this level of scientific certainty is unrealistic and rarely achieved (note how long it took to connect cigarette smoking with lung cancer). Massachusetts is in the top ten states in cancer incidence and Cape Cod has elevated rates of some cancers compared to other areas in the Commonwealth. Thus the Sierra Club feels that a precautionary approach should be adopted for factors that appear to elevate cancer rates (but are not statistically significant) in developing public health policy. We applaud the Silent Spring Institute's (SSI) Cape Cod Breast Cancer and Environment Study, which has been attempting to link indoor pollution by endocrine disruptor chemicals with increased breast cancer rates. SSI's website contains practical action that citizens can take to reduce their exposure to these chemicals, while the Massachusetts Department of Public Health (Ma. DPH) awaits definitive scientific studies before taking action. We need to develop a more precautionary approach to protecting public health.