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Health Dept. - Ft. Detrick Environmental Contamination Concerns

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1. Where was sampling performed near Carroll Creek and what were the results?

See MDE letter posted under the October 3, 2011 meeting heading found on the main Cancer Investigation webpage on the Health Department's site (www.FrederickCountyMD.gov/CancerInvestigation).

2. What is [Ft. Detrick] Area B and what materials were disposed there?

[From EPA & MDE August 2010] Area B is roughly 399 acres, and includes 8 landfill/trenched areas that have been identified to date. Area B was established as a proving ground in the Army’s Biological Warfare program. Later, Area B was used as a disposal area for chemical, biological, and radiological (CBR) material and until 1970 for biological experimentation.

Area B has been the primary location of waste management activities for Fort Detrick and is the location of an active municipal landfill, animal farm, former skeet range, former explosives storage area, and former waste disposal/test areas associated with former research activities.

In the late 1940s, the Special Operations Group of Fort Detrick installed a test grid in Area B to test both live and simulant biological warfare (BW) materials. A list of the live agent materials used in Area B is not available, but it is known that simulant materials used included Bacillus globigii, Serratia marcescens, and Escherichia coli. Test animals were buried in trenches or pits located in Area B after autoclave sterilization. Many types of munitions were tested on the test grid in Area B.

Anthrax was buried in Area B. In addition, radiological tracer materials were reportedly buried at three locations in Area B, including radioactive carbon, sulfur, and phosphorous. Two cylinders marked “Phosgene” were also reportedly buried in Area B. Phosgene is considered a lethal chemical agent.

In 1970 and 1971, after the United States outlawed biological research for offensive operations, a decontamination program was initiated for Fort Detrick. Decontamination procedures for residual biological/chemical research materials included autoclave steam sterilization and incineration. Incineration ash was tilled into soil in the northwestern corner of Area B (Pit 13). Research buildings and equipment were also decontaminated, and an extensive wipe sampling program was completed after decontamination. In addition, sewage drainage lines were cut and capped, and drainage systems were filled with hypochlorite solution.

In 1977, severe soil erosion exposed buried scrap materials and created several deep cavities in Area B. The areas were subsequently covered with soil.

In June 2004, a removal action was completed at Area B-11, an Area B chemical disposal area. Activities completed included the removal of contaminated soil, chemical containers, compressed gas cylinders, and laboratory waste. The discovery of live pathogens in medical wastes at Area B-11 caused suspension of all intrusive work at the disposal area. The southwestern portion of Area B contains three known chemical waste disposal pits (Pits 1, 3, and 4), one suspected chemical waste disposal pit (Pit 2), and one ash disposal pit. Area B-11, also known as Pit 11, is reported to have received various types of waste chemicals from Fort Detrick, the National Bureau of Standards, and the Walter Reed Army Medical Center from 1955 to 1970.

Reportedly, eight 55-gallon drums of TCE were disposed of in Pit 1. Wastes disposed of in the pits included metals, wood, general waste from laboratory modifications and building demolition, refuse from housing and animal farm operations, acids and chemicals, incinerated medical waste, waste herbicides and insecticides, phosgene, and animals potentially contaminated by anthrax. Area B-11 is underlain by solution-weathered limestone of the Frederick Formation, a karst formation aquifer. Solution features such as voids were identified in Area B-11 during the installation of monitoring wells. The voids are 10 to 87 feet long and were encountered with the greatest concentration in the first 100 feet of drilling. Drilling in Area B-11 revealed that bedrock is located at 32 to 33 feet below ground surface (bgs). The nature of karst conditions in Area B-11 increases the probability of releases to ground water from wastes disposed of in Area B-11. Wastes may have been disposed of directly into karst solution cavities (voids). All of these disposal activities could have resulted in ground water contamination.

The EPA has requested that the Army undertake an Archives Search Report to identify all materials used, tested, and disposed of at Area B over time. Such historical information will aid in determining what potentially could exist at Area B.

3. What contaminants are under investigation [as of August 12, 2010]?

[From MDE August 2010] The known contaminants in groundwater beneath Area B include tetrachloroethene (PCE) and trichloroethene (TCE). However, under EPA’s supervision the Army is conducting a new remedial investigation of the groundwater beneath Area B, which includes the taking of environmental samples which will be collected and analyzed for their chemical content (type and concentration). Other pollutant could be identified during the course of this new investigation. The most significant pollutants associated with the Fort Detrick incinerators include the following: hydrogen chloride, particulate matter, carbon monoxide, dioxins and furans, sulfur dioxide, nitrogen oxides, lead, cadmium, and mercury. There are many other known toxic air pollutants that are discharged from incinerators in trace quantities.

4. What are TCE and PCE?

PCE is also known as tetrachloroethylene, a manufactured chemical that is widely used for dry cleaning of fabrics and for metal-degreasing. It is also used to make other chemicals and is used in some consumer products. Other names for tetrachloroethylene include perchloroethylene, PCE, and tetrachloroethene. It is a nonflammable liquid at room temperature. It evaporates easily into the air and has a sharp, sweet odor. Most people can smell tetrachloroethylene when it is present in the air at a level of 1 part tetrachloroethylene per million parts of air (1 ppm) or more, although some can smell it at even lower levels.

The EPA maximum contaminant level for the amount of tetrachloroethylene that can be in drinking water is 0.005 milligrams tetrachloroethylene per liter of water (0.005 mg/L). The Occupational Safety and Health Administration (OSHA) has set a limit of 100 ppm for an 8-hour workday over a 40-hour workweek. The National Institute for Occupational Safety and Health (NIOSH) recommends that tetrachloroethylene be handled as a potential carcinogen and recommends that levels in workplace air should be as low as possible. [Source: ATSDR ToxFAQs accessed 12/29/10, http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=264&tid=48 ]

TCE is Trichloroethylene (TCE), a nonflammable, colorless liquid with a somewhat sweet odor and a sweet, burning taste. It is used mainly as a solvent to remove grease from metal parts, but it is also an ingredient in adhesives, paint removers, typewriter correction fluids, and spot removers. Trichloroethylene is not thought to occur naturally in the environment. However, it has been found in underground water sources and many surface waters as a result of the manufacture, use, and disposal of the chemical.

Some studies with mice and rats have suggested that high levels of trichloroethylene may cause liver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels of trichloroethylene in drinking water or in workplace air have found evidence of increased cancer. Although, there are some concerns about the studies of people who were exposed to trichloroethylene, some of the effects found in people were similar to effects in animals. In its 9th Report on Carcinogens, the National Toxicology Program (NTP) determined that trichloroethylene is "reasonably anticipated to be a human carcinogen." The International Agency for Research on Cancer (IARC) has determined that trichloroethylene is "probably carcinogenic to humans."

The EPA has set a maximum contaminant level for trichloroethylene in drinking water at 0.005 milligrams per liter (0.005 mg/L) or 5 parts of TCE per billion parts water. The EPA has also developed regulations for the handling and disposal of trichloroethylene. The Occupational Safety and Health Administration (OSHA) has set an exposure limit of 100 parts of trichloroethylene per million parts of air (100 ppm) for an 8-hour workday, 40-hour workweek. [Source: ATSDR ToxFAQs accessed 12/29/10 http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=172&tid=30]

See also the ATSDR December 2009 report on the ATSDR website http://www.atsdr.cdc.gov/HAC/pha/FtDetrickAreaBGroundwater/FortDetrickPHAFinal12-09-2009.pdf or click to it from the link on the www.FrederickCountyMD.gov/CancerInvestigation web page under resources.

5. What is Vinyl Chloride and where was it found?

[Source MDE August 2010] Vinyl chloride (VC) is a second generation breakdown product of trichloroethylene (TCE) {TCE-Dichloroethene (1,2-DCE)- VC} and a third generation breakdown product of tetrachloroethylene (PCE) {PCE-TCE- 1,2-DCE-VC}. Both TCE and PCE are principal contaminants found in groundwater at Area B.

VC has been found in the source area near the B-11 pit. In 2007, 21 Area B monitoring wells were sampled with only 1 detection of VC (9.6 ppm, in BMW 56D) near the B-11 pit area. There were no off-site detections of VC. Consistent levels of vinyl chloride (VC) throughout the contaminant plume would indicate that the known contaminants (i.e. TCE, PCE) may be naturally degrading through the process of dehalogenation to a benign endpoint (i.e. ethane) through biologic and natural processes. Certain anaerobic bacteria, principally Dehalococcoide ethenogenes, have been shown to effectively accomplish this conversion. The optimum pH range for D. ethenogenes has been reported in scientific literature as neutral to slightly alkaline, i.e., between 7 & 7.5. During the 2007 sampling event, the average pH reported was 7.56 or slightly beyond the optimum pH range. Also, with the exception of the anaerobic pit areas in Area B, the aquifer is oxygenated (i.e., aerobic). For this reason, significant D. ethenogenes activity is unlikely to be detected beyond the pit areas.

6. What toxins are emitted from incinerators in Area A?

[Source: MDE August 2010] Fort Detrick currently has four incinerators at the main base - Area A. They include two medical waste incinerators, each capable of processing up to 0.5 ton per hour medical waste; and two small municipal waste combustors, each capable of processing up to 1.5 tons per hour of municipal solid waste. Each of these units are equipped with rotary atomizing scrubbers designed to control emissions of particulate matter, heavy metals and acid gases. The air emissions from these incinerators are subject to very stringent Federal rules developed under the Clean Air Act (1990), sections 111(d)/129. The Federal rules address the emissions of criteria pollutants (sulfur dioxide, nitrogen dioxide, carbon monoxide, volatile organic compounds, particulate matter, and lead) and non-criteria pollutants such as hydrogen chloride, cadmium, mercury, and dioxins/furans.

With regard to toxic air pollutants (TAPs), screening levels (i.e., acceptable ambient concentrations for toxic air pollutants) are generally established at 1/100 of allowed worker exposure levels. The Maryland Department of Environment has also developed additional screening levels for carcinogenic compounds. The additional screening levels are established such that continuous exposure to the subject TAP at the screening level for a period of 70 years is expected to cause an increase in lifetime cancer risk of no more than 1 in 100,000.

The Fort Detrick incinerators are required to perform routine stack testing in order to demonstrate compliance with both federal and State emission standards. Based on these stack test results, Fort Detrick is in compliance with both the Federal and State regulatory requirements for air emissions. In addition, the same controls would reduce emissions of other unregulated toxic air pollutants.

7. Where does the City of Frederick get its water?

[Source: City of Frederick Annual Drinking Water Quality Report accessed September 2010 and personal communications] There are two types of water sources. They are ground water and surface water. Ground water is from a well and surface water is water from lakes (Lake Linganore), creeks (Linganore Creek), and reservoirs (Fishing Creek). The Monocacy River and Potomac River also provided water. We have both supplies available, however our wells (wells 3,7,9 located on Schifferstadt Blvd) were only in production for 4 months during the 2002 drought. The City of Frederick regularly tests its water supply for regulated and unregulated contaminants. A full report can be found on the City's website - http://www.cityoffrederick.com/cms/files/dpw/annual-drinking-water-quality-report.pdf.

8. What agencies are coordinating on the remediation?

Area B ground water and associated sources will be assessed during the Remedial Investigation (RI). The generated data will be shared among Federal, State and Local government agencies (including EPA, ATSDR, MDE and the Health Department, as well as Ft. Detrick). These entities will be in communication regarding all relevant issues and decisions, including those associated with the investigation and any clean-up efforts.

9. What testing is the currently underway?

[Source: US EPA September 2010] As part of the new Remedial Investigation, the Army is conducting surface water and sediment sampling to determine whether contamination from Area B has migrated off-site. In the course of completing the new remedial investigation of the groundwater beneath Area B, an analysis will be conducted for a wide range of potential pollutants including metals, semi-volatiles, pesticides, herbicides, and volatiles. Additionally, the Army will be conducting a new dye trace study of the karst geology to identify groundwater flow pathways from Area B. Additionally, the EPA has requested that the Army undertake an Archives Search Report to identify all materials used, tested, and disposed of at Area B over time.

10. What is vapor intrusion?

[Source: US EPA August 2010] Vapor intrusion (VI) refers to the migration of volatile chemicals from the subsurface into occupied buildings. As a general rule of thumb, the potential for VI of concern exists when structures are within 100 feet (horizontally and vertically) of volatile chemicals in the subsurface. It is proposed that the Army will conduct a vapor intrusion study as part of the new Remedial investigation for Area B. The vapor intrusion study will include the collection of soil gas samples through the foundations of occupied buildings that are known or suspected to be within 100 ft. of the PCE/TCE groundwater plume.

11. What are dioxins and are they being monitored in the vicinity of Ft. Detrick?

[Source: US EPA August 2010] The term "dioxin" refers to a group of chemicals with fairly similar structures, but different cancer potencies. To standardize the different types of dioxins and their propensity to cause cancer, internationally-accepted toxicological practice is to convert each dioxin potency to a concentration that would be equivalent to the most toxic form of dioxin, 2,3,7,8-TCDD. It is this form (2,3,7,8-TCDD) that is associated with Agent Orange.

There are 7 principal dioxin compounds, 10 furan compounds, and 12 polychlorinated biphenyl (PCB) compounds which act similarly and may pose potential health risks. The compounds in this group (dioxins, furans, and PCBs) have different levels of toxicity, so a particular level of one compound does not necessarily pose the same risk as an equal level of another compound in the group. Dioxins are widespread environmental contaminants that tend to be present in soil at background levels. The background level of dioxins and related compounds in Frederick County has not been determined.

The only dioxin results reviewed by U.S. EPA thus far were submitted by John Bee on behalf of the Kristin Renee White Foundation. These soil samples, when evaluated in terms of 2,3,7,8-TCDD equivalents (2,3,7,8-TCDDeq), revealed dioxin levels (up to 7.89 parts per trillion [ppt] 2,3,7,8-TCDDeq) that are within the background range expected for rural areas of the U.S. (up to 11 ppt 2,3,7,8-TCDDeq ).

None of the levels reported in the referenced sampling effort exceed U.S. EPA's current residential clean-up standard for dioxin (1000 ppt 2,3,7,8-TCDDeq), proposed interim Preliminary Remediation Goal (72 ppt 2,3,7,8-TCDDeq) or risk-based concentration for residential exposure (450 ppt 2,3,7,8-TCDDeq), at an excess cancer risk of 1 in 10,000). As part of the ongoing investigation of Area B, EPA and MDE are discussing how best to conduct dioxin sampling for both on-post and off-post locations. This effort should provide more thorough coverage than the limited dioxin sampling conducted to date, and should capture the extent of dioxin contamination, if any, in the vicinity of the Area B.

12. What groundwater tests will be completed?

[Source: US EPA August 2010] The Army has in the past conducted dye tests and installed monitoring wells within the Area B property boundaries and reported the findings in several reports. However, EPA and MDE have raised concerns about some of these studies. Additionally, questions still exist regarding the bedrock features and the degree in which groundwater flow is affected by the orientation and connection of the voids and conduits within the bedrock and the flow direction within the deeper portions of the aquifer underlying Area B. New dye studies, installation of wells and sampling and analysis of new and existing wells will be part of the new upcoming Remedial Investigation activities.

13. Were Carroll Creek sampling results presented at the March 23, 2010 RAB meeting?

At the Ft. Detrick Restoration Advisory Board (RAB) meeting, data were presented for Robinson Springs. The values were 7.4 ppb for TCE and 0.8 ppb for PCE. The springs drain into a pond and then into Carroll Creek. It was determined years ago by the Army's testing that by the time the outfall reaches the creek it is well below MCLs or non detect. Measurements of Carroll Creek in the 90's showed that where springs enter the creek that dilution and volatilization rapidly reduce concentrations below MCLs to non detect within a short distance. Based on the monitoring data it was determined by the Army, MDE and EPA in the partnering meetings years ago that there was not a threat to the public use of Carroll Creek and that there is not any need to restrict access. Both TCE and PCE are not bio-accumulating compounds. The current Area B groundwater workplan includes taking new measurements in Carroll Creek to create a new baseline.

14. How many wells surround Fort Detrick?

[Source: MDE September 2010] Within two miles of the boundaries of Ft. Detrick, there are 15 wells that are used by public water systems (7 community water systems, and 8 transient non-community water systems). The statewide well database indicates that there are approximately 1967 individual wells located within this 2-mile area. The specific locations of the individual wells have not been verified.

If the Maryland Department of the Environment determines that there are area-wide contaminations that could impact individual private wells, an investigation in collaboration with the local County Health Department will be made. Depending on the significance of the contamination and number of impacted wells, corrective actions will be recommended. If wells are contaminated at a level that exceeds federal or State drinking water standards, solutions under consideration will include the provision of public water. There is also the option for the responsible party (e.g. Ft. Detrick) to request that the City connect those properties.