1

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, 18
th
Wing,
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
2

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 todays soccer 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
3

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 - while ignoring 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)
4


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 population conclusion
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.
5


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.


6

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
masamimel.k@gmail.com.

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