January 30, 2001
|SUBJECT:||Update: Army Corps of Engineers Testing and Excavation on Campus
This is another in a series of communiqués I am sending to ensure that the campus community is fully informed about the activities of the Army Corps of Engineers on our campus and the results of their work. Since the release of my memorandum last week, new preliminary data and analyses have come in, as well as plans for addressing the issues that have been identified.
The work of the Corps is quite visible, sometimes noisy, and has caused some disruption and inconvenience to our normal operations. More importantly, as their investigations have now identified a few small areas of contamination on our 85-acre campus, there is natural concern about the impact upon the health and safety of all who live and work on the campus. Perhaps inevitably, there are also rumors, speculation, and misinformation that may lead to heightened anxiety. Therefore, this rather lengthy memorandum not only will convey information we have to date but also will address some questions that have emerged in formal and informal settings during the past week.
To improve university-wide coordination and communication for project- related activities, I have assembled a project team of campus professionals that reports directly to me. The team meets regularly to compile information, review findings, develop appropriate response options, and facilitate effective communication. The group includes David Taylor, President’s Chief of Staff, who will continue to be the university’s spokesperson for the project; Bethany Bridgham, Associate University Counsel; Jorge Abud, Assistant Vice President of Facilities, Beth Muha, Executive Director of Human Resources; Patricia Kelshian, Executive Director, Contracts & Risk Management; and Willy Suter, Director, Physical Plant. Others will be involved as resource persons, such as Nina Roscher, Professor, Department of Chemistry, and Dr. Paul Chrostowski, an environmental health scientist trained in toxicology and epidemiology, whom we have retained as an outside specialist in these matters. He is a founding member of Chrostowski, Pearsall, Foster, Durda & Preziosi (CPF Associates), a Qualified Environmental Professional (QEP), and a Fellow of the Royal Society of Health.
What is the Army Corps looking for?
The Corps of Engineers is searching for any materiels - including warfare implements, testing remains, containers, shells, and chemicals - that may have been left behind in 1917-20 when the Army used AU as its experimental testing station. The Corps is working from a set of pictures, maps, and general descriptions of the buildings and activities of the time to locate where such materials might be buried and to determine whether there is any remaining contamination of the environment that could conceivably pose health risks to persons near such locations.
What have they found?
The Corps completed its excavation behind the Hamilton building on January 11, and found no sign of residue from the Army’s World War I activities on the AU campus. The soil and air quality tests did not reveal cause for concern, no chemical warfare materiel was found, and the Hamilton building has been safely re-occupied. A small sampling of lead in the soil was attributed to a buried automobile battery that was uncovered in the digging operation.
The Corps has also completed the excavation of two burial pits in the South Korean Ambassador’s yard, which adjoins our campus behind the Watkins and Kreeger buildings. Munitions, glass containers, and higher-than-normal concentrations of arsenic in the soil were found and removed. The soil there is being completely replaced with new soil and the area is being fully restored.
A few months ago, initial test samples from the ground surrounding AU’s Child Development Center (CDC) indicated no cause for concern. However, preliminary test results received ten days ago from a second and more thorough sampling process revealed higher-than-normal concentrations of arsenic in the soil in sections of that area. We immediately relocated CDC operations to another area of the campus. The Corps will remove and replace all the soil around CDC over the next few weeks.
Preliminary test results received within the past few days from samplings in the area behind CDC and on the playing field behind Watkins and CDC indicate higher-than-normal concentrations of arsenic in certain areas. When final results are confirmed, the Corps will remove and replace the soil from that entire area. In the meantime, as a safety precaution we are closing the playing fields while further tests are conducted. We will determine alternative playing field sites as soon as possible after reviewing pre-set schedule commitments and the availability of other fields.
Although it is unclear from the 1918 maps of the area, there is some reason to believe that the yard of a private residence next to the South Korean Ambassador’s residence may be the location of another munitions burial pit. Extensive excavation of the front and rear yards of the 4825 Glenbrook Road residence was begun last week but has yet to turn up any materials or higher-than-normal readings of arsenic.
Tests have also been conducted on the area surrounding the AU President’s residence. Four anomalies have been identified that will require further exploration and analysis.
Finally, an initial reading of higher-than-normal arsenic has shown up in a test boring along Nebraska Avenue between the SIS and Hurst buildings. The entire area along Nebraska Avenue from Gray Hall to Ward Circle will be tested further.
What are the health and safety concerns for the AU community?
For arsenic to pose a health risk to persons, it would have to be directly ingested. It is not transferred through the air, and soil containing elevated levels of arsenic poses no danger by simply touching it. Based on the levels that have appeared in the CDC and other campus tests, a person would have to eat roughly a tablespoon of contaminated soil every day for many years before showing signs of adverse health effects. While it is believed that the risk is extremely low, nevertheless we have targeted the obvious groups of persons who would ordinarily come into contact with soil in areas with higher-than-normal test readings - for example, CDC children and staff, AU grounds keepers, construction/maintenance workers, athletic teams, etc. - to make health tests available, if they choose. All steps that can be taken will be taken to provide a safe and secure environment for everyone on the AU campus [see further steps below].
What is arsenic?
Arsenic is a gray, metal-like substance that occurs naturally in soil, water, and in the foods we eat. Arsenic has been used widely in the manufacture of agricultural and wood preservation products designed to control insects, weeds, and other pests that damage crops and goods, as well as in an assortment of consumer products such as dandruff shampoo, herbal medicines, and some home electronics. It was used in the experiments conducted on our campus during World War I.
What are the symptoms of arsenic poisoning?
Prolonged ingestion of high levels of inorganic arsenic can cause the potential for skin conditions, irritation to the digestive tract, and perhaps skin cancer. However, this is only possible with high doses over a very long period of time. We do not believe that anyone would experience illness from the levels of arsenic found in any area of the AU campus.
What is the federal standard for arsenic? What level is safe?
No federal standards exist for arsenic in soils because it is site specific. It is difficult to say what a safe level may be because it would be based on the activities of each individual. The background level of arsenic in soil in the Spring Valley and American University areas ranges from 3.3 to 18 ppm (parts per million), based on 30 tests taken by the Environmental Protection Agency (EPA) near the targeted sites, but outside the areas likely affected. Ninety-five percent of those 30 samples are below 13 ppm, which, according to Army Corps protocols, is used as a screening level for future sampling in the Spring Valley area. In past clean-up projects involving arsenic in soils, EPA has used a range of 0.7 ppm to 750 ppm as the basis for soil removal. The EPA’s current guideline for removing arsenic-affected soil in our region is 43 ppm.
What about the water? Is there any reason for concern?
Along with the neighborhood around our campus, AU’s water system is dependent upon the Dalecarlia Reservoir. The water flowing into the reservoir (that passes through the soil of the Spring Valley region) has been tested several times and has shown no evidence of health concern. There is no evidence of elevated levels of arsenic in the water nor any concern about the water posing health risks as a result of any of the World War I burials. What do we know about the areas around Kreeger, Watkins and Hamilton? We know more about the Kreeger area than the Watkins and Hamilton sites, based on aerial photographs from 1918 and other historical documentation. We can tell that there are ground scars in this area, which show disturbed earth in some spots or a lack of vegetation. There could be a variety of causes for these types of ground scars, not necessarily related to munitions-related testing. We also know that there were several buildings constructed in this area for the operation of the Experiment Station. In fact, because so many buildings were constructed there at that time, it is unlikely that the area was used as a burial or disposal site. It is very difficult to draw a conclusion about the exact use of this area because the War Department did not keep records of this nature during the WWI era.
What kind of sampling has taken place in the areas near these buildings?
From 1993 to 1995, the Army Corps conducted sampling around these areas. They found one elevated sample of arsenic near the roadway not far from the Kreeger building service entrance. In 1999, EPA sampled these areas and found four samples with elevated level of arsenic. One sample in front of Kreeger registered 141 ppm, two samples on the side of Watkins Hall showed 59ppm and 23ppm, and one sample in the wooded area behind Hamilton was 31 ppm. Other samples during these time periods were at or below background levels for the area. EPA has written a draft risk assessment based on their sampling efforts in the area. It focuses on the areas around Kreeger and Watkins, and just behind Hamilton, and says the arsenic concentrations are not significantly different from the background level concentrations.
What about other areas of the AU campus?
The Army Corps has conducted sampling on 28 lots on the southern portion of the AU campus. Preliminary results have been received and 7 lots have results above 13 ppm, which is the screening level for the area established by the range of EPA’s samples from "background" areas. EPA, DC Health, the Army Corps, and AU have been meeting to decide on additional sampling procedures. It is anticipated that 20-foot grid sampling will be done on each of the lots with elevated readings. Since the northern portion of the campus was used for housing soldiers, it is extremely unlikely that any compounds would have been deposited in that area, based on historical documentation and aerial photographs. Nevertheless, we are developing a comprehensive plan to ensure that every area of our campus will be tested and that all appropriate measures will be employed to ensure the safety of the AU community.
What has the university done to protect the AU community from potential harm from the soil?
Even though we do not believe members of the AU community are at risk, we have closed the CDC building and transferred all CDC activities to Leonard Hall. Prior to that, the university put a thick layer of mulch on top of the soil surrounding CDC to ensure that children and staff would be protected from any direct contact with the soil. Again, even if a child or staff member were to be exposed through direct contact, there is no indication that the levels of arsenic present would cause adverse health effects.
We have also taken precautionary measures, such as relocating office, classroom, or other building occupants during testing, sampling, and remediation procedures, in order to ensure that all members of the AU community are entirely safe. We will now be closing the intramural playing field while additional tests are conducted in that area.
Additionally, we are working closely with the staffs of all the agencies involved to implement a comprehensive plan to assure that we have a campus completely safe from any effects related to the World War I experiments carried out on our campus. We will continue to take every necessary precaution to provide for the safety of everyone on campus.
To what extent is AU responsible for these events?
In 1918, American University had been open and operating only four years. There were fewer than 50 students enrolled and only three university buildings had been built. As part of the war effort, the War Department of the U.S. Government used our campus to establish Camp American University, construct temporary facilities, and test munitions. When the war was over, the clean-up operations were thought at the time to be appropriate. Unfortunately, they included the burial of some munitions and chemicals.
AU had no part in producing or testing these materials; this was done entirely by the U.S. Army. Like the property of our neighbors in Spring Valley, a few sites on our campus have been found to be contaminated and they will need to be excavated by the Army Corps.
Is AU cooperating fully with the Army Corps or has it resisted efforts to test and excavate the campus?
In public settings and with me personally, representatives of the Army Corps have expressed appreciation for the openness and cooperation that AU has provided. We have "gone the extra mile" not only by giving the Corps access to everything they need to carry out their testing and excavation work on our campus but also by allowing the Corps to use our campus to park vehicles and store excavation equipment that is used for their work at off-campus sites. We have also allowed them to build and use a temporary road on the edge of our campus so their excavation activities on private neighborhood properties would not disrupt the neighborhood by clogging public streets.
Is there something the university is not communicating about what it really knows?
Throughout this process the university has communicated the information provided by the Army Corps or other agencies to keep the AU community abreast of what is known about the situation. Frankly, not only would we have nothing to gain by doing otherwise, but also, and more importantly, to withhold vital information on these important matters would betray a trust with university constituents that the institution is morally obligated to uphold.
Will AU pay for medical testing for arsenic for university students, faculty and staff?
Based on the data collected in the Spring Valley and AU areas, there is no indication that the levels of arsenic present would cause adverse health effects. It is highly unlikely that anyone would experience either illness or any symptoms of illness as a result of arsenic in the soil at the CDC or in other areas of the AU campus. However, the university’s health plans - Kaiser or Blue Cross/Blue Shield - will cover medical testing, if anyone wishes to be tested. You will be charged the standard co-pay for the office visit and laboratory tests. Children of the Child Development Center whose parents choose to have them tested will participate in a process facilitated by D.C. Department of Health and coordinated by the Agency for Toxic Substances and Disease Registry. We are in process of designing an appropriate testing protocol for these and other campus populations that have had direct exposure to soil in their daily work or activities, if they wish to be tested.
Who can I talk to about my health in relation to the effects of arsenic?
We have consulted with an environmental health scientist, Paul C. Chrostowski, Ph.D., to help us understand how arsenic acts in the human body. Dr. Chrostowski is trained in both toxicology and epidemiology, and can answer your questions about general effects of arsenic in children and adults. If you have questions that are specific to you or your child, we suggest that you speak to a family doctor who is familiar with your medical history. Also, you can have your family doctor speak with Dr. Chrostowski.
What are next steps, and how long is the Corps project likely to continue?
Our commitment is to a comprehensive and thorough testing and remedy of the entire AU campus - including soil, air, and water. This is a slow process involving many persons and agencies. There are preliminary tests, different kinds of tests, and final results that are certified by government agencies. Some actions based on projections are merely precautionary, others are more directly safety-related as a result of extensive excavation disturbance.
The university has retained independent outside experts to review procedures and results, and to interpret and advise us as we plan each step of the project as it unfolds. It is likely that the sequence of testing, data analysis and interpretation, remediation, and restoration will last a minimum of six more months - though it is difficult to project an accurate time frame at this point.
For more information
An information line has been set up specifically to address questions from the American University community about the Corps of Engineers Project at AU. Please call 202-885-2020 and leave your name, phone number, and question or concern. We will return your call as quickly as possible. The D.C. Department of Health also has an information line at 202-535-1755. The university is creating a web-site as an information resource, which should be finished this week. In addition, the Army Corps of Engineers maintains an informative web-page at http://www.nab.usace.army.mil/projects/WashingtonDC/springvalley.htm. The Army Corps has established an information repository that contains additional documents pertaining to the investigation and clean up, and can be found at the Palisades library, at 4901 V Street, N.W.