Where's The Beef?

Where's the Beef?

On March 26, 1993, the DNR, after completing its review of an environmental contamination study, found that Range 40 of Camp Grayling was contaminated and designated this range as a 307 site (for Superfund scoring). Moreover, at the same time it determined that

The DMA shall conduct additional comprehensive studies of other ranges at Camp Grayling.
A proposal for site remediation for Range 40 would be developed.
The toxicity of explosives residues to area biota will be determined.

As of this date, more than two years later, none of these have been conducted, developed, or determined.

In the immediate months following the DNR's action we were led to believe that since Range 40 was found to be polluted and placed on the 307 list, we would soon see a plan that would outline the mandated future behavior of the Guard on this land. Since it was obvious that military activities caused the pollution, we also expected to see a plan for the rehabilitation of the land, i.e. "a proposal for site remediation," in addition to further studies that would define in a more comprehensive manner the full extent of the pollution.

Months passed and nothing was forthcoming except discussions about further studies of Range 40.

Finally, in December, I heard we might expect a letter to the DNR from the military which would list actions to reduce known and potential sources of contamination from military training at Range 40 and other ranges. After nine months of suspense, I couldn't wait; I made an FOIA request for this document.

The military response was a dismal disappointment; it addressed nothing the DNR said it must, except that it would do additional studies.

In my January 1994 response to the DNR regarding this letter, I said my main problem was the absence of a remediation plan for Range 40. Like the little old lady said, "Where's the beef?"

After addressing all the trivial and peripheral issues of the military's letter, I returned to the central issue, ignored by both the DMA and the DNR: ... The cardinal problem remains unchanged by the DMA's shellgame; it is an unalterable fact that the past use of Range 40 has contaminated the soils, groundwater, and stream sediments and that this use involves the explosion of large numbers of artillery shells and bombs over many decades. The residues of these explosions to a large extent are well-known; some of them are toxic. The residues just didn't disappear; they were deposited in the soils, and they migrated into the groundwater and stream sediments. ... the DNR should require the DMA to provide a military history of Range 40, and for all the other Grayling ranges. This history would list the weapons used each year for the last seven decades, and it should list the number of shells exploded, and the number of bombs detonated. The DMA with its unlimited resources should then disclose the amounts of residues of these exploded shells and bombs. With this information, the DNR will then have a better idea of the amount of toxic residues distributed within these ranges by past military use. ... the DMA should be accountable for its use of state lands; it should know what the history of use has been. The Army's engineers and chemists can educate the DMA regarding the residues from explosions of shells and bombs. (If the DNR was truly serious about its oversight function, it would also conduct its own literature search of technical references regarding the combustion products from both propellants and explosives for the "items" (in military parlance) exploded on Grayling's ranges. I personally am disappointed and puzzled by the DNR's response to this problem. In March the DNR put Range 40 on the 307 list and ordered the DMA to prepare a remediation plan. This plan included additional testing on Range 40, but since it was described as remediation it should also address the continued use of Range 40; the DMA should therefore be required to state how it will use this range without continuing the activities that caused the pollution. There is no argument that additional testing must be conducted to determine the true extent of the contamination in order to design an effective remedy, but I am puzzled why there is uncertainty about which specific activities caused the contamination. When toxic contaminants, known to be residues of explosives, are discovered in the soils, groundwater, and stream sediments, why can't the DNR then take the next rational step and conclude that the activity of firing guns and dropping bombs is the activity that has led to the contamination? The continued use of Range 40 as an artillery and bombing range is most likely a violation of the Michigan Environmental Protection Act (Act 127), presumably a breach of the Water Resources Commission Act (Act 245) and the Michigan Environmental Response Act (Act 307), and probably breaks a few other environmental laws I know nothing about. In the past I have been well aware of a number of specific actions taken by the DNR requiring site remediation by industrial companies. Though some additional testing was usually required to determine the extent of the contamination, ... I recall no instance where a company was allowed to continue the practice or the activity that caused the contamination. ... it appears the DNR is treating a government agency differently than it would treat a private company.

In March, a year ago, I received a nice letter from the DNR which said, in part, that remediation has yet to be addressed, that their science is not as clear cut as we all would like it to be, that additional testing of other ranges at Camp Grayling will take place, that the history of range use and ordnance use and the "characterization" of waste from exploded ordnance would be a very good assessment tool for defining cause and effect relationships, that the DNR will continue to press DMA to identify feasible and prudent alternatives (to present practices) to protect the environment, that a direct cause and effect relationship has not yet been identified at Range 40, and that the DNR has not treated a government agency any different than it would treat a private company.

In addition, it said it would (finally) ask the DMA to provide a history of ordnance use at Grayling's ranges, and that the DNR had in its possession information on the "characterization" of exploded ordnance.

In my answer, among other concerns, I emphasized that the DNR, after placing Range 40 on Michigan's 307 list of contaminated sites, has done nothing about controlling the activities that caused the pollution, and, therefore, the DNR has now become a significant part of the problem, whereas we had hoped that it would contribute to the solution.

Moreover, my criticism both before this exchange of views and in the following year and a half, has been directed to the DNR's behavior with regard to the following:

When X is known to cause Y, and when Y is known to be toxic and found at Range 40, and when the only significant military activity conducted at Range 40 is X, the DNR should then be able to conclude without much cerebral effort that X is the cause of Y and that the military should be held accountable for X and produce a plan to alter X so it doesn't continue to produce Y. It seems to me that is the undeniable logic regarding Range 40; that is what a rational mind would conclude. The DNR doesn't need better science. It does need less political interference, more courage, and better logicians.
I didn't understand the over-emphasis regarding the pollution where there was open detonation and burning (of excess propellant) when the same pollution is caused by the firing of guns and the detonation of shells and bombs. The DNR and the military seem to focus on the former and ignore the latter.
When Range 40 was placed on the 307 list the DNR stated that a "proposal for site remediation ... must be developed by the DMA." We were led to believe that such a proposal would be forthcoming; I personally was told we would see it in the early summer. Such a proposal would not only include further testing, but it should include a plan wherein the DMA would demonstrate how its continued use of this range would not continue to pollute it. A year has passed and we have not seen even a nod at such a proposal.

I have been dismayed by the DNR's ignorance regarding the military history of the use of the range: what specific ordnance, amount, by year. In its mission of oversight of the use of public lands it would seem to me that this information would be vital. Not only did the DNR not have this information, it never asked the DMA for it, even though it knew we had been trying to get the same information for almost eight years.

I have also been surprised and dismayed regarding the ignorance within the DNR regarding the residues caused by the firing of guns and the explosion of ordnance and I was pleasantly surprised when I read that the DNR had this information; it referred to it as "characterization of exploded ordnance."

After requesting this information, I received it in about six months, and discovered it had nothing to do with the description of what residues (and their amount) are found when guns are fired and shells and bombs are exploded. What I received was a trivial document produced by the military that stated (in part) that exploded ordnance was not a waste (presumably since the military would like us to believe that there are no residues from exploded ordnance); I believe the term used was "consumed in use." There was no reference at all to the residues produced from the gun barrel when the guns were fired.

Though we remain disappointed with the DNR in its mission of oversight regarding the military's use of state lands, and we can't help but believe that the DNR is treating the DMA in a deferential manner, I am pleased to report that the DMA was finally required to produce a report regarding the history of ordnance use at Camp Grayling. The DNR didn't request this report until June last year, and the military didn't produce it until December. (The presiding judge hearing the AMAC lawsuit would not accept this document as evidence, but that is another story.)

This document catalogs the number of rounds of artillery and heavy weapons and the number of troops trained each year since 1977, as shown in Figure 1:

The correlation between troop strength (number of troops in training) and the use of ordnance is dramatically illustrated by Figure 2:

This shows that for every 10,000 troops trained, called "troop strength" by the Guard, (say for ten days out of two weeks summer training, i.e. 100,000 troop training days) at Camp Grayling there are approximately 10,000 rounds of heavy weapons rounds expended.

Though it is a terribly flawed document (for example, it only went back to 1977), the generation of any document, such as this, by the military is a cause for celebration. If we can believe their accounting (for example, the DMA claims that there were no 500 pound bombs dropped at the range before 1989), almost 380,000 artillery and heavy weapons rounds have been expended at Grayling's ranges since 1977.

That is a significant number. It also implies that a large amount of toxic residues have been distributed in a relatively small area containing the headwaters of the Manistee and Au Sable rivers.

It now has been over two years since the DNR put Range 40 on its list of contaminated sites. Since the DNR seems unwilling to follow through on its promise of a remediation plan, we can only conclude that the military is receiving preferential treatment.

The reason for this has been an object of intense speculation. I have simply concluded it is an exercise of blatant power politics where the General goes to the Governor, the Governor steps on the DNR Director, and the Director does his thing with his hired hands. The whole process of the past two years stinks of undue political interference.

I say this with much reluctance. I have the greatest respect for the DNR field operations and the people who man them. In the past decade, however, and especially in the past five years, they seem to be operating in an environment where in order to survive they more often than not must compromise their integrity and avoid the sacred axiom to "speak the truth, and act accordingly."

I truly wish I believed otherwise.

RWOL

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