letter to Kadena Air Base

8/11/2019 letter to Kadena Air Base

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Citizens Network for Biodiversity in Okinawa

304 Ginowan Seminar House

4-24-7 Shimashi

Ginowan City, Okinawa

Japan 901-2213

October 9, 2014

James B. Hecker

Brigadier General, USAF

Commander, 18thWing,

Kadena Air Base

Dear Mr. Hecker:

We, the Citizens Network for Biodiversity in Okinawa (Okinawa BD), are an environmental

NGO, which addresses issues of contamination in the prefecture - including military-related

pollution. Now we are writing in regard to your letter to the Kadena Air Base (KAB)

community dated August 7, 2014, titled an update of the excavation in the Okinawa City

soccer field.

First we would like to express our appreciation for your prompt updates on the KAB website,

the aforementioned letter, and the summarized translations of the investigations of the

Okinawa City soccer field conducted by the Okinawa Defense Bureau (ODB) and Okinawa

City. Thanks to your announcements, the KAB community is now aware that the Japanese

Government (ODB), Okinawa Prefecture, and Okinawa City have been working together

diligently to solve the issue. Likewise people in Okinawa are informed of how KAB is

disseminating information to the U.S. military community and beyond.

However, we are concerned, that your letter fails to provide the KAB community with an

accurate, sufficient summary and discussion of the results and analyses of these investigations.

In particular, we would like to highlight four points:

1) Your letter fails to adequately incorporate the results of Okinawa Citys investigation.

2) Your letter ignores information in the report which contradicts your conclusion that

there are no health risks to the local population.

3) Your letter does not discuss the possibility of contamination at Bob Hope Primary

School and Amelia Earhart Intermediate School depending on the treatment of

contamination of the soccer field.

4) Your letter includes parts which have been inadequately - or incorrectly - translated


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leading to possible confusion among readers.

In the following, we would like to elaborate these four points of concern.

1. Okinawa Citys investigation

While your letter mentioned Okinawa Citys investigation and the translated summary was

uploaded onto the KAB website, the update and discussion in your letter was based primarily

on the Okinawa Defense Bureaus report - not on the information provided through Okinawa

City. Concurrent with the ODB investigation, Okinawa City has been conducting a

cross-check/counter investigation on the soccer field to ensure that all investigations are

accurate, sufficient, and transparent. Since Okinawa Citys report has proven invaluable, your

exclusion of it is a disservice to the KAB community.

For example, Okinawa Citys report includes comments from Dr. Katsuhisa Honda, an expert

on dioxin at Ehime University, regarding the possibility of the presence of

herbicides/defoliants in the soccer field. Dr. Honda states that it is highly likely that, in the

past, herbicides containing components of defoliants such as Agent Purple, Green, Pink and/or

Orange were present in the soccer field. (Incidentally, Dr. Honda rules out the possibility that

Agent White was present in the soccer field since the investigation did not detect picloram -

one of Whites components - in the samples.)

Dr. Hondas comments contradict the ODB analyses and conclusions. ODB analyzed the

results of the surveys only in terms of relationships with Agent Orange, but not in terms of

other defoliants. Thus, while the ODB report concludes that it was unable to find Agent

Orange defoliant in the drums,it neglects other Vietnam War defoliants.

Moreover, Okinawa Citys report provides information pertaining to the possibility of the U.S.

militarys involvement in the contamination of the soccer field. It presents two eye-witness

accounts of U.S. servicemen dumping barrels in the area where the soccer field is presently

located. The accounts include the following information:

Around 1964 - the year in which Tokyo Olympics were held - 6 or 7 U.S. servicemen

were working from10:00 AM to evening near the area of todayssoccer field.

These service members unloaded barrels from a U.S. military truck(s), rolled them into

the bottom of a small valley and covered them with soil using military bulldozer(s).

They placed plywood on the slope allowing the barrels to be rolled smoothly.

Having incorporated these witness accounts into the Geographical History Survey section of

its report, ODB produced the following analysis:

There were also many deposit samples considering that 2,4,and 5-T[sic] result


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was due to the drum intentionally being crushed at the time of burial, and as a

result, PCP and PCB were mixed in the drum. (p.10, Former Kadena Airfield (25)

Soil Investigation Survey (Part 2), Survey Report Executive Summary June 2014,

Procurement Department Okinawa Defense Bureau).

The ODB report, however, fails to mention this particular analysis (the drum intentionally

crushed) was based upon the witness accounts in Okinawa Citys report. As a result, the

translated Survey Report Executive Summary also fails to mention this fact - and your letter

fails to refer to the possibility of the U.S. militarys involvement in the contamination of the

soccer field.

Furthermore, with regard to the cause of arsenic and fluorine detected from residues inside

barrels and soils beneath the barrels, Okinawa Citys report and the ODB report provide

different interpretations. While the ODB report states that it was a natural cause, Okinawa

City report indicates the possibility of an artificial cause. Your letter fails to discuss this

important difference between the two reports.

Finally, Okinawa Citys report states that As for the burial area of the drum deposits, there

was complex contamination and caution was needed for the disposal and handling methods.

We believe the concept of complex contamination (or multiple contamination) is the

appropriate concept to describe the particular contamination of the soccer field. The ODB

report neglects to examine this concept - nor does it discuss the overall characteristic of the

contamination.

Given the above discussions, we suggest that you review Okinawa Citys report and consult

with Okinawa City officials to understand better the contamination of the soccer field.

Following this, the information which you obtain through review and consultation ought to be

incorporated into your future updates to the KAB community.

2. Misleading the KAB community regarding the OBD investigation

Your letter focuses on information from the ODB report that supports the conclusion - no

health risks to the local population - whileignoring information that could indicate otherwise.

In our view, your letters descriptions of the ODB investigation and report are both inaccurate

and inadequate - and may mislead the KAB community.

For example, with regard to dioxin, your letter erroneously states that Finally, the dioxins

found are below Japanese soil standards.This contradicts the ODB report.

The OBD report describes the results of surveys on dioxins as follows:

Although there was no result in which the dioxins of the drum exceeded 3 ng-TEQ/g

(3000 pg-TEQ/g), it was over 1000 pg-TEQ for about six samples. (p.14)


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Moreover, while your letter states that An agriculture herbicide (2,4,5-T) was detected it

does not specify where or from what source 2,4,5-T was detected. Given that identification of

the sources of 2,4,5-T contamination is very important, it would have been appropriate to state

in your letter exactly where 2,4,5-T was detected.

We have consulted with three experts regarding your letter, the OBD report, and Okinawa

Citys report. Their analyses reinforce our concern that your letter focuses on information

from the ODB report that supports your no health risks to the local populationconclusion

but ignores information that could indicate otherwise.

Ms. Komichi Ikeda, a Japanese expert on dioxin contamination, pointed out that, according to

ODBs report data, the residues of 18 barrels contain 2 ,3,7,8-TCDD, which accounts for more

than 50% of their respective TEQ values. Accordingly, she provided the following suggestions

to be incorporated into your discussion and update:

The fact that 2,3,7,8-TCDD, which was detected in samples from the soccer field, is the

most toxic isomer among the dioxin compounds should be emphasized.

The relationships between concentration of 2,4,5-T and 2,3,7,8-TCDD should be

discussed.

Emphasizing that 2,4-D is a component of weed killers and such weed killers are widely

available at local stores does not assure safety. When, and how dioxins and herbicides

were used and kept by the U.S. Military on Okinawa should be addressed

Dr. Wayne Dwernychuk, an expert on Agent Orange and herbicides who headed investigations

into dioxin hot-spots in Vietnam, gave the following comments via email (Aug.1, 2014)

My feeling is that the question of whether or not any of the drums contained the

specific Agent Orange mixture of 2,4-D and 2,4,5-T in a 50:50 ratio of

concentration may only be of a secondary consideration/importance. What is

primary in my mind is the presence of dioxins, particularly TCDD the dioxin

congener specific to the 2,4,5-T fraction of the AO mixture. Focusing intently on

Agent Orange specifically, tends to detract from the reality of the situation wherein

it is the dioxins which are and should be of major concern. Denials by authorities of

the actual presence of AO in any of these drums will undoubtedly carry on. However,

one cannot refute the presence of dioxins and their association with potential health

concerns. This aspect of the issue should be the primary consideration.

Dr. Shingi Kuniyoshi, who worked on the environmental cleanup program at the March Air

Reserve Base, California, gave the following comments and suggestions, regarding the barrels

found in the soccer field.


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Although it is highly unlikely that the human body is exposed directly to the

contaminated soils, the rain water may seep into the soil and dissolve contaminants

and carry to the groundwater. The groundwater in Okinawa is currently not the

major source of drinking water. However, the groundwater may end up in storage

ponds or reservoirs for agricultural and domestic uses. Therefore, the possibility of

human contact with contaminated groundwater cannot be ruled out. All

groundwater in California is considered potential source for drinking water and

protected vigorously. At March ARB, cleaning of contaminated groundwater has

been the most expensive and time-consuming program.

We believe that the discussions above should be brought to the attention of the KAB

community.

Therefore we suggest that you thoroughly review the ODB report and consult with ODB

officials to better understand the contamination of the soccer field. In addition, we request that

you incorporate into your update to the KAB community the information you have obtained

through review and consultation.

3. Possible Effects on Bob Hope Primary School and Amelia Earhart Intermediate

School

Your letter states that Kadena (the Bob Hope Primary School and Amelia Earhart

Intermediate School) was not impacted in any way by the excavation site. While this may

be accurate, in our view your letter should have explained this assertion in more detail.

Moreover, your letter ought to have addressed the possibility that Bob Hope Primary School

and Amelia Earhart Intermediate School could be affected by the contamination depending on

whether and how the soccer field will be remediated.

Ms. Ikeda presents the following points and suggestion, resonating with our concerns:

It is unlikely that the contamination of the soccer field has a substantial effect on the soil

and air of the KAB schools given there is no risk of the students being directly exposed to

the barrels, soil or breathing the airborne dust.

In the event that the contaminated site is not treated properly in a timely manner, or is

left as it is, there could be the possibility that toxic compounds may exude into the

environment and contaminate the ground and surface waters.

In the event that development projects take place in the soccer field or in its vicinity

without proper preventive measures, it is likely that dust containing toxic substances

could be released from the soil through construction activities such as excavation.

Sufficient preventative and counter measures should be taken.


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4. Issues of Translation

Your letter was written based upon the information obtained from the translations of the OBD

report and Okinawa City's report. While the overall quality of these translations is acceptable,

we find some parts of the translations inadequate, confusing or even wrong. The following

sentences are one such example. The translated version of the OBDs Survey Report

Executive Summary reads:

The dioxins at the bottom of the soil were 1000pg times or less- TEQ/g which is at

the environmental standards of the soil in all samples. The dioxin toxic equivalent

of the base soil is lower than the drum dioxin toxicity, and in general tend to show

higher values. (p.14)

Concluding notes

Considering the concerns noted above, and the fact that ODB investigations are still underway,

it is both impossible and irresponsible for any declarations of safety to be issued at this point.

At the very least, the ongoing investigations need to be completed before any conclusive

statements are issued. Meanwhile, the KAB community and people of Okinawa expect you to

provide updated information on the investigations which are accurate, sufficient, and

transparent.

Thank you in advance for your consideration of our suggestions. If you have any questions or

would like to discuss the issues further, please dont hesitate to contact me at

[email protected].

Sincerely,

Dr. Masami Kawamura

Director,

Citizens Network for Biodiversity in Okinawa

cc: Okinawa Defense Bureau

Okinawa City

Okinawa Prefecture

Consulate General of the United State, Naha

Minister for Foreign Affairs, Okinawa Liaison Office

Association of Three Municipalities Hosting Kadena Air Base
mailto:[email protected]:[email protected]:[email protected]

letter to Kadena Air Base

Documents

Transcript of letter to Kadena Air Base