Under direction of the Michigan National Guard, data was collected from some streams, lakes, and wetlands on or adjacent to Camp Grayling's Range 40 (the North Range) in the period of May through October 1994. The final report (ESE 47-94003) for what is known as the Range 40 Surface Water Study resides in three three-inch thick binders and contains methods, data, interpretations, recommendations, and references.
The Au Sable Manistee Action Council (AMAC) presented information on the following points to the Deputy Director of the DNR Region II's office on May 26, 1995.
We firmly believe that this study is seriously flawed and would like to share our findings with you.
Testing Schedule
Good science requires that meaningful results are the product of comparable testing schedules. However, in this study, not all streams were tested on the same schedule. Not all lakes were tested on the same schedule. Moreover, the lake testing schedule was different from the stream schedule and collected less data.
Furthermore, not all wetlands were tested on the same schedule. The wetland testing schedule was different from the stream and lake schedules and collected less data. Wetland sediment testing schedules were changed based on test results.
So we ask the simple question: How can results be interpreted and compared without comparable testing schedules?
Contamination Events
The background level concept is illustrated in Figure 1. Notice the differences between Detection Level, Average Control Site Value, and Background Level. Concentrations above background levels should be considered as statistically significant phenomena. For our purposes, a contamination event is a toxin's concentration at a test location that exceeds background level.
Contamination events on firing ranges are likely to be transient. Moreover, they are well defined by the magnitude of changes.
AMAC, without qualification, accepts the statistical definition of background and contamination, but we object to trivialization based on:
Since these assertions and practices were common in this study, we ask another simple question: Why?
Control Site Information
Some control sites had contamination events for some toxins during the study.
Background levels (at control sites) of some toxins exhibited significant changes during the study period. An example is shown in Figure 2.
Changes in some background levels are similar to external events such as troop strength (use) and precipitation, as shown in Figure 3, again using the site shown in Figure 2.
A joint 1993-1994 Michigan DNR/Attorney General's Office investigation found the state's environmental testing labs unregulated and uncertified. In this investigation similar samples tested at different labs produced widely varying results. When asked about the qualifications of the testing facility used in the Range 40 study, the DNR refused to comment. The DNR also refused to disclose if this facility was one of the testing labs investigated in the 1993-1994 DNR sting operation.
So we ask another simple question: How reliable are the control values, related background levels, and test values?
Contaminants/Toxins
During the study, contamination events occurred for the following: Aluminum, Arsenic, Cadmium, Chromium, Copper, Iron, Lead, Nickel, Nitrocellulose, Selenium, Silver, Vanadium, and Zinc. All of these contaminants are known constituents of common military munitions (e.g., 20mm, 40mm, M18A1, T45E7, 5.56mm, 60mm, 75mm, 91mm, 105mm, and 4.2-inch). They are found in TNT, and in more than 78 different propellants, primers, detonators, and explosive charges.
There is no question about the source of Range 40 contaminants. The issue is their effects on the general population and biota.
Contamination Event Locations
Please refer to the map showing the Camp Grayling Range 40 contamination event locations, ordnance impact area, and major firing points. Notice the difference between the Au Sable River North Branch and the Au Sable River East Branch (headwaters) in numbers of contaminated sites and numbers of contaminants per site. There seems to be no doubt that the adjacent firing points and impact area are introducing these contaminants into the Au Sable River system. There is also no doubt about where these contaminants are going: primarily down the East Branch to Grayling to join the Au Sable River Mainstream.
Looking for Toxins in all the Wrong Places
Anybody with a map who knows where the sun comes up and which way the Au Sable system flows would have predicted findings similar to those from this study.
The question is why didn't the study anticipate the above and test surface water in nearby populated and recreational areas? Was there fear of what might be found in Shupac Lake, K.P.Lake and Jones Lake? How do these results affect users of the Jones Lake DNR Campground?
In our view, it was immoral to leave these questions unanswered.
Another nagging question relates to a part of the study called "fish whole body analysis." This analysis checked the presence of mercury in sixty fish. The question is why? Neither the 1992 nor the 1994 water studies turned up any mercury contamination events. All the contaminants found in 1992 were found again in 1994. Why weren't the known contaminants the starting point in choosing target toxins for the fish study?
Creative Interpretations
Lead was found at one test site (the Lovells Bridge). The study attributed the lead to fishermen. AMAC challenges that conclusion for two reasons: (1) the site in question is a Quality Fishing Area (flies only) and flyfishers use less lead than other fishermen, and (2) if the assertion were true, one would expect to find lead at some of the other fifteen test sites on the Au Sable River North Branch.
The study also attempts to discredit the Lovells Bridge site because of excessive highway runoff. As far as we can tell, highways cross highway bridges and in this case, the highway and bridge were in place several dozen years before the study was designed.
A simple question is: "Why was a highway bridge selected as a test site if runoff is a problem?"
Conclusions/Recommendations
Sources
Information presented in this article comes from the following sources:
Hypothetical Possibilities: A Footnote
Let's assume you wanted to avoid the responsibilities of causing environmental contamination, what would you do? Well, you would be genuinely concerned about the cause and agree to study the problem continually. You would then roll the study costs into the normal cost of doing business.
Additionally, if you wanted to produce an inconclusive study even while you pretended to study the nature of a specific contamination, what would you do? You would use a faulty and inadequate study design. Such a study, among other things, would:
RWOL
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