Kabul Press, May 8, 2010
More than 350 toxic sites need to be studied
The American military continues to operate burn pits in Afghanistan eighteen months after the U.S. Congress banned their use. See the February 1, 2010, article by Lindsay Wise and Lise Olsen of the Houston Chronicle. They used the burn pit at Camp Taji in Iraq as an example. It continues to open-burn 120 tons of waste each day. This provides a glimpse as to the volume of waste that is being illegally burned on American bases every day. Multiple that times hundreds of bases and posts in Afghanistan, and factor in that it has occurred every day for the past nine years and the scope of the problem becomes evident. The burn pits are only part of the problem. Other pollution results from spills, releases, illegal ash disposals and secret burials into unmarked landfills.
Last month the American military withdrew from its combat outposts in the Korengal Valley of Kunar Province and ceded the area to the Taliban. While the Western media reported on the American withdrawal, no one asked the question:
"Did the Americans remove all the hazardous waste that they spilled,
released or disposed of in the Korengal Valley, and did they restore
the locations to their original condition?"
The answer appears to be "No." There is no evidence of any environmental investigation or soil sampling, let alone environmental cleanup and restoration at these outposts. All the hazardous waste generated by the American military appears to have simply been abandoned.
Similarly when the Americans withdrew in 2008, from Combat Outpost Wanat in Nuristan Province, there does not appear to have been a cleanup of the contamination at that location. The fear is that this is the Pentagon’s model for all American bases in Afghanistan. The underlying (and undisclosed) policy seems to be "cut and run." Cutting out on their responsibilities and running away from the toxic consequences.
In the mid-1980’s, the American military closed down a number of old radar sites along Canada’s northern border that had been part of a defense system called the DEW Line. During decades of operations hazardous materials had spilled or been released at these facilities, including PCBs (polychlorinated biphenyls). The Government of Canada insisted that the Pentagon dig up all the contaminated soil and ship it back to the United States for disposal. Similar measures were ordered by the Kingdom of Saudi Arabia after the liberation of Kuwait and invasion of Iraq in Operation Desert Storm. These are the models that the Government of Afghanistan should follow. At the other end of the spectrum are examples of countries which have not insisted on American accountability and responsibility. These include the Philippines, Somalia, Iraq, Vietnam, Cambodia, Laos etc. They will have to continue to bear the toxic legacy of Pentagon "assistance" to their countries.
The Pentagon has its own environmental cleanup program which it calls the Defense Environmental Restoration Program (DERP). DERP has been a lackluster effort. See "Superfund: Greater EPA Enforcement and Reporting Are Needed to Enhance Cleanup at DOD Sites." GAO-09-278 March 13, 2009.
Originally 985 American military bases were evaluated due to the contamination present. 140 bases were listed as major problems and were assigned to what is called the Superfund program. Each base might have dozens of separate toxic sites. The balance of the bases was given a lesser priority. They were assigned to different programs or transferred to local cleanup authorities. There is no total list of every toxic site created by the Pentagon within the United States, but the number is believed to exceed 2,000. Virtually none of these sites have been completely cleaned up (i.e., all contamination removed). Major American cities such as Tuscon, Sacramento, Denver, San Diego, Irvine and others are threatened due to pollution from these bases that has spread into the groundwater.
This author has worked on DERP sites. Unfortunately, the Pentagon cannot be relied on to conduct a comprehensive investigation of its illegal waste practices. It has too much of a conflict of interest. The Government of Afghanistan must insist on independent experts being in charge.
The format for an investigation of the estimated 350+ American military toxic sites in Afghanistan is well-known. It begins with a listing of all known and suspected sites or facilities where any American hazardous material was present. Then, there is a historical investigation of each site, followed by an analysis and environmental assessment of the data for each site. The next step is to conduct soil and water sampling at each site. Then there is more analysis and finally remediation of all the properties begins, with each being restored to its original condition.
IDENTIFICATION OF POTENTIAL POLLUTION SITES
The DERP process commences with a compilation of all locations in Afghanistan where the American military has operated for any period of time. Such listing is not limited to facilities, posts and bases but would include firing ranges, maneuver areas, staging areas, free fire zones and areas which have suffered any significant aerial or artillery bombing. Sites to be evaluated would also include dirt roads leading to and from these locations and areas downwind and/or down-gradient from them. Each American facility should be defined not simply by its perimeter fence line, but it should encompass areas extending out at least 2,000 meters in all directions. Any remedy for each facility should include efforts to recover as many toxic shells and bullets as possible that the Americans fired since 2001. This would include unexploded aerial munitions.
Once a list of potential sites is finalized, an historical investigation of each location can begin. They are generally undertaken in two phases:
Phase 1: Gather all written data available regarding each location. That includes preparing a database of all materials and equipment shipped into and out of that facility or used in that area. The next step is to assemble all aerial and other photographs taken before the Americans arrived, and during the period 2001, to the present. The photos will help identify where operations were conducted that may have resulted in a release of hazardous materials. Aerial photographs are particularly important because they can be used to detect burn pits and permit one to follow the resulting plumes of toxic smoke. The photographs can pinpoint trenches, landfills, ponds of liquids, sumps, fuel bladders, vehicle wash down areas and storage tanks. They can detect changes in color in the surface soils, which may indicate spills, releases or secret burials of toxic wastes. This information would be useful in locating potential hot spots that will require intensive soil sampling.
Once all the available documents have been assembled, it may be that the documents are not adequate to provide a complete picture of what has occurred since 2001. At that point, Phase 2 would be initiated.
Phase 2: Conduct witness interviews. The idea is to locate military officials who would have been involved in any generation or disposal of hazardous waste at each facility during each of the past ten years. Usually one begins with warehouse officials, maintenance crew chiefs, fuel depot managers, fire department officials; and transportation drivers. The list expands if more information is needed. This information, hopefully, would permit one to develop a dynamic model of how each facility operated, what wastes it generated and where/how it was disposed of each type of waste.
MASTER DATA BASES
Concurrent with this effort, the Pentagon should prepare eight master data bases regarding Afghanistan:
1. A database of all materials shipped into Afghanistan by the American military beginning in 2001 to the present. The database would include types of chemicals and materials involved, their chemical formulas and quantities;
2. A database of all materials which have been shipped out of Afghanistan;
3. A database of all major fuel storage facilities (temporary and permanent) where more than 1,000 liters of fuel has been stored or dispensed;
4. A database of all maintenance, wash down and repair facilities (temporary and permanent), where oils, grease, solvents and other chemicals would have been used;
5. A database of all official burn pits, incinerators, disposal pits, landfills and latrines;
6. A database of all known releases, spills, disposals of any metals or chemicals, with copies of all reports, memos, notices and other data;
7. A database of all Material Safety Data Sheets (MSDSs) for all materials which the United States shipped or had shipped into Afghanistan beginning in 2001; and,
8. A database of reports of illness or injury by military personnel that might be linked to an environmental exposure in Afghanistan. That database would include a listing of the most likely exposure sites.
Once the databases are completed, their information would be analyzed. Planning could then begin on how to comprehensively sample all soils, groundwater and surface water within, near and downwind from all sites where the American military operates and has operated. The sampling would be followed by laboratory testing for all major metals, all military pesticides, all hydrocarbon byproducts (including solvents, degreasers, fuel, diesel), dioxins and furans, volatile and semi-volatile compounds, asbestos, PCBs, chlorine, E-waste chemicals, radioactive waste and dozens of burnt plastic compounds. In addition, surface water sampling should be conducted to address biological toxicity, biological oxygen demand, coliform (i.e., indicators of sewage) and a range of other parameters.
There is not enough in this article to explain the proper methods for sampling groundwater, surface water, sumps, pits, piles and other areas. Military firing ranges, for example, require a unique sampling method, as do drums of liquid. All that can be said in this short series is that sampling data is easy to "fudge" (to use an American slang term).
What that means is that it is possible to sample a heavily contaminated site and find nothing because of bias in the sampling. One obvious method is to sample clean looking soil and avoid any discolored soil. Another is to only take surface samples when the contamination has had time to leach a few feet below the surface. Another method is to take what are called "composite" samples. These are two, three or four samples that are then mixed together, thereby diluting the results.
This should never be permitted. Sampling plans can be fabricated to avoid pollutants. One tactic is to arbitrarily limit the number of samples per area. For example, the military may elect to take only 20 samples in an area the size of a football field. This is inadequate. In areas heavily used by the military, samples at multiple depths may be necessary for each square meter. One popular scheme is to designate "target contaminants" and only sample for those "most likely" to be present. The theory being that if they are not present, the soil is completely clean. This technique may be valid in contaminate-specific sites (such as a battery-breaking site where lead is the primary contaminant of concern), but not where thousands of chemicals may have been burned and/or released.
Another scheme is to sample for a released chemical but not its byproducts. Some chemicals (such as the solvent TCE) are unstable and rapidly degrade into more toxic byproducts. If one "forgets" to sample for the byproducts, the soil will appear clean. There are dozens of such schemes that can be used to dilute, avoid, minimalize and cross-contaminate samples. The Government of Afghanistan needs to insist that the Pentagon fund a team of independent experts selected by the Government of Afghanistan. That team must approve all sampling plans and oversee all sampling events.
Once all the sites have been identified and sampled, agreement must be reached on how to remedy or clean-up the contamination in each location. The most favored environmental remedy in the United States is to remove all contaminated soil and dispose of it in a safe, approved landfill. Ideally (for the citizens of Afghanistan) those landfills would be somewhere outside of Afghanistan. If groundwater or surface waters have been polluted, the remedy is more complicated and may take years or even decades to complete.
It is not enough to remove toxic chemicals from the soil and groundwater. The area must be biologically restored and returned to its original, pristine appearance and condition. This is a standard requirement of the American Government when persons or groups use federal land in the United States. Site restoration requires another layer of planning, analysis and implementation.
International law is on Afghanistan’s side. The 1977 Protocols Additional to the Geneva Convention of 1949 (Protocol 1), and ENMOD (The Convention on the Prohibition of Military or other Hostile Use of Environmental Modification Techniques) prohibit "environmentally destructive actions." These two treaties give "nature" legal rights and standing. Injury to the environment can be a war crime.
The U.S. Congress needs to establish a "Military Environmental Remediation Fund for Afghanistan" (MERFA) and appropriate at least $10 billion for the fund as an initial investment. If this is viewed as an excessive amount, the reader would be sadly mistaken. The actual price tag for the cleanup of the military’s pollution in Afghanistan may be more than ten times that amount.
On February 1, 2010, the BBC reported that the Obama Administration was canceling its "Constellation Program"- a NASA plan to build a Moon rocket called the Orion spacecraft. NASA has already spent $9.5 billion on this spacecraft and the cost of shutting down the program and paying all the contract penalties will be another $2.5 billion. In its place, President Obama has proposed a $19 billion budget for NASA for 2012, which includes efforts to begin studying how to build a Mars spacecraft. If the United States can waste $12 billion on studying a moon rocket and another $19 billion, which includes funds to study a Mars rocket, it can spend billions cleaning up the environmental mess it has created in Afghanistan. The Pentagon should clean up the Earth first, before it begins polluting outer space.
Under American and European environmental laws, "hazardous materials" is the broadest term and encompasses all things hazardous. Each hazardous material may contain one or more hazardous constituents (chemicals, metals, salts etc.). There are a variety of subsets of the general category "hazardous materials" and every one of these may have been disposed of in Afghanistan. They include:
- Hazardous wastes
- Corrosive wastes
- Ignitable or flammable wastes
- Petroleum wastes (including used tires)
- Reactive wastes
- Infectious wastes
- Radioactive wastes
- Toxic wastes
The term "toxic waste" includes wastes that are:
— Eco toxic
— Dermally toxic
— Bio toxic
— Mutagenic (i.e., cause mutations); and/or
— Carcinogenic (i.e., cause cancer), etc.;
PCB wastes. PCB wastes and other similar types of waste deserve special mention as they span multiple waste categories. They are toxic, persistent in the environment (i.e., they do not naturally degrade) and they are thermally resistant, which is why this author recommends that military incinerators should operate at higher temperatures than municipal incinerators in Europe do.
What is missing from this list is what the Pentagon informally calls "exotic wastes." This author encountered some of them while remediating military sites in the United States. There are an estimated 60,000 organic chemicals in use in the United States. In addition, there are chemical compounds being secretly developed by the Pentagon in its research programs and used in its weapons systems and equipment. It is not cost effective to test for the presence of all 60,000 chemicals and it is impossible to test for the presence of chemicals classified as "secret" as we do not know what parameters or constituents to test for. For example, legal attempts in American courts several years ago to discover the names of exotic chemicals used at a secret Pentagon base called "Area 51" failed. As a result of this veil of secrecy, no American military base, site or outpost can ever be declared 100% clean of pollution.
DAMAGE TO AFGHANISTAN’S DESERT ECOSYSTEMS
The instances of environmental damage listed in this series are not exclusive. American military operations have also likely caused other types of environmental damage. These includes the destruction of habitat, the killing of endangered species, damage to archeological sites (known and unknown), destruction of burial sites and long-term destruction to the ecosystem, especially in the deserts.
Afghanistan’s deserts, like the deserts in the United States, are particularly fragile. Contrary to common belief, most arid and semi-deserts are alive with plant and animal life, but it is life that exists in a precarious state. Living deserts are covered by a thin layer of bio-crust called "cryptobiotic crust." It is an interconnected mass of algae, moss and lichens that stabilize the soil and permit plant life to exist. The crust is resistant to harsh climate extremes, but is "compression-fragile" which means that it is easily destroyed by vehicle traffic and the heavy boots of combat troops. If damaged, this crust can take 50-250 years to recover. If areas are destroyed, renewal may take up to 3,000 years.
In the American southwest, strict rules have been imposed by the U.S. Bureau of Land Management on the use of motorized off-terrain vehicles in desert areas in order to protect the bio-crust. Likewise, American military bases located in desert areas, such the Twenty-Nine Palms Marine Corps base, have to observe a host of strict environmental rules.
In Afghanistan, the American military follows none of these rules. Its tanks and other armored vehicles appear to operate wherever they want. The amount of desert that has been run over by tracked and wheeled vehicles must be enormous to-date. The extent of the damage to the desert flowers, flora and fauna and animal species can never be calculated. The only thing that is certain is that it will take hundreds of years for these areas to recover, if they can ever recover. For example, large areas of the Sahara Desert never recovered from the damage done to them. Today, vast stretches are biological wastelands. Without an extensive study by biologists, there is no way to calculate whether the damage done to Afghanistan’s deserts is temporary or permanent.
The environmental restoration of Afghanistan should be a goal that the West and the Taliban share. It would be in the interests of both sides to declare local cease-fires in order to cooperate in this effort at specific sites. Such confidence-building measures might permit a broader dialog.
The author is a former U.S. Air Force Captain. He advised on environmental cleanups at Logistics Command regarding the Air Force’s most contaminated bases and depots. He then worked for Bechtel Environmental and was involved in Superfund cleanups across the United States and radiological cleanups at U.S. Department of Energy sites. He later served as a consultant to a group of environmental remediation companies, smelters and waste recyclers.