By Mar-Vic Cagurangan
Andersen Air Force Base has failed to identify adequate measures to protect the ocean and Guam's water source from possible contamination that may result from its ordnance disposal and open detonation activities, according to federal and local environmental regulators.
The U.S. Environmental Protection Agency and Guam Environmental Protection Agency have returned the AAFB's application to renew its hazardous waste facility permit, citing deficiencies and noncompliance with federal requirements for toxic waste management.
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“The OD unit is located approximately 50 yards away from the ocean, based on USEPA Region 9 and Guam EPA’s field observations and the statement in the AAFB permit renewal application submittal. Moreover, the groundwater lies approximately 6 feet below the OD unit where the sole source aquifer is,” according to Martha Guzman and Michelle Lastimoza, administrators of USEPA and GEPA, respectively.
In its application, the AAFB said the OD unit is located in "the upper beach area on highly permeable materials."
The AAFB claimed that given the unit's location, "even in major precipitation events, run-on and run-off are negligible at this site. Management of run-on and run-off at the OD unit is therefore not necessary,” it added.
Guzman and Lastimoza, however, disagreed.
“A sediment control system with run-on and run-off controls at the facility must be addressed in a revised permit renewal application submittal,” they wrote in an Aug. 6 letter to Capt. Roberto Antonio P. Trujillo, USAF commander of the 36th Civil Engineer Squadron.
“In addition, the revised permit renewal application needs to provide the appropriate details regarding how AAFB will prevent run-off from the hazardous waste treatment operations at the OD unit," they added.
The AAFB has until Sept. 20 to correct the deficiencies and submit a revised application for permit renewal.
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Guzman and Lastimoza's evaluation report summed up the USEPA and GEPA inspection teams' observations during their tour of the facility on April 25.
The report took issue with the lack of groundwater protection.
The AAFB said, “There are no existing wells downgradient of the OB/OD range because it was impractical to install a downgradient well when the regulated
unit is less than 150 feet from the ocean and the likelihood of damage from the OD activities to the monitoring well.”
Instead, AAFB monitors four groundwater seep locations during low tide to meet the groundwater monitoring requirements.
“USEPA Region 9 and Guam EPA continue to believe the current groundwater evaluation program is insufficient to identify any groundwater impacts (as in migrating inland) or any marine impacts (as in migrating to the ocean) from the open detonation activities at the unit,” Guzman and Lastimoza said.
The environment agencies also ordered the AAFB to submit a closure plan for the open burn and open detonation units, noting that the law requires the facility to “commence closure operations within 30 days after a unit receives its last shipment of hazardous waste.”
The OB unit at AAFB has been inactive for several years.
“With the newly enacted Guam legislation prohibiting OB operation, the OB unit at AAFB cannot and will not be able to receive hazardous waste for treatment. To address the Air Force’s expressed desire to delay closure of this unit, while the regulations do allow for delayed closure when there is capacity and resumption of waste management, the intent of the regulations is to require closure if the unit is not actively managed,” Guzman and Lastimoza said.
According to Earthjustice, a group formed by environmental lawyers, "the OB/OD site lies on a beach between the Pacific Ocean and the jungle" and "sits above a shallow, unconfined aquifer."
Earthjustice warned that OB/OD operations threaten the aquifer, which supplies drinking water to more than 80 percent of Guam’s population.
It further warned that contaminants could also enter the ocean and harm residents who frequent nearby beaches and fishing sites.
“The law prohibits OB/OD of waste explosives when there are safe alternatives,” said Thien Chau, senior associate attorney at Earthjustice. "It’s long past time for Guam EPA to deny the permit and put an end to open detonations on Tarague Beach.”
“We’re glad to see that USEPA and GEPA are finally holding the Air Force accountable to the law. For the last three years, our group has been advocating for a ban on open detonation, pushing for increased protections, and arguing for Guam EPA to deny the Air Force’s permit application,” said Monaeka Flores, a member of Prutehi Litekyan: Save Ritidian.
"This letter from both Guam EPA and U.S. EPA has finally validated our efforts and concerns. But this letter should have come three years ago to require the Air Force to evaluate safe alternatives. Instead, we’ve continued to suffer the harms and environmental impacts from open detonations," she added.
Military bases and private facilities across the country have relied on OB/OD to destroy excess, unserviceable, or obsolete military munitions for decades.
OB/OD facilities collectively burn and detonate millions of pounds of munitions and other hazardous waste in the open air as part of their day-to-day operations.
Officials said there are currently 67 OB/OD facilities operating in the U.S., including Guam.
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