One day when I was an engineer working at the Mare Island Shipyard Post Closure Detachment I was assigned to oversee the removal of PCB's at the long closed Hunter's Point Naval Shipyard in San Francisco. PCB's are a class of substances that were very useful for a long time. They were a completely effective fire prevention additive used in electrical transformer oil and were used and leaked into the ground just about everywhere that electrical transformers were located. There are a lot of transformers at a Navy shipyard. It took a long time for scientists to figure out just how bad PCB's are. A PCB starts out fairly harmless and is essentially non-toxic, but over time when it is released into the environment, bacterial action changes it and increases and magnifies its power as a carcinogen by as much as a million times or even much more. These "activated" PCB's are so extremely carcinogenic that the EPA has named them to be an entirely new class of human poisons called "Dioxin-Like Toxins" and they are subject to very strict regulations. Dioxin is the most powerful carcinogen there is.
I had been trying, without much success, to convince my supervisor, this kind man, to implement more stringent safety procedures, which were more than the none he had implemented, for the workers who were actually doing the cleanup work and for him to more closely follow the applicable federal regulations, which he had not been doing. His shouted response to me was the "He had not seen one speck of evidence by himself that PCB's were harmful and that I was an idiot for thinking so". To this day I still have not figured out how to make an effective response to a total ignoramus of this magnitude. His attitude is much the same elsewhere in the U.S. Navy. If you are in a community located close to a U.S. Navy Shipyard or other Navy industrial facility or if you actually work at such a place, please keep in mind that the U.S. Navy high officials have a knack for selecting monsters just like this man to "monitor" their regulatory compliance. There's no doubt in my mind that the new lower emission limits are in the capable hands of people just like him.
Here is a document that demonstrates the U.S. Navy attitude when it comes to regulatory compliance. It deals with the sampling conducted at sites suspected to be contaminated in some way at the closed Mare Island Shipyard. The thing to understand is that if a sample is not properly handled and documented it can be thrown out and an entire case can fail because of this. This sort of thing was amply demonstrated at the infamous murder trial of a football star. The Los Angeles Crime lab had not observed proper chain of custody procedures with its sampling of the murder scene with the result very important evidence was not considered by the jury.
If you think the Navy has changed anything between the issuance of new hexavalent chromium regulations and now, is operating honestly and is a good steward of the environment please read this Consent Agreement between the Navy and the State of California Department of Toxic Substances Control in 2004 regarding the way the Navy conducted chemical sampling at Mare Island in violation of just about every regulation there is:
You Can't Trust the NAVY - Consent Agreement
The most important thing to understand about this Consent Agreement is that it is completely worthless. The U.S. Navy has a long-standing policy of doing everything in its power, honestly or dishonestly, to avoid having to live with a court judgment. When the Navy is sued the first thing is does is to collect the evidence and then hide it. Then it engages in a campaign of accusing the other party of overloading the Navy with "excessive and burdensome" data requests for data it no longer has. Finally, when the other party has run out of money or patience or both the Navy offers a generous consent agreement that appears, on its face, to give the other party much of what he wanted to begin with. The reality is that once the Consent Agreement is signed it is turned over to a low ranking employee who is well known to be a management pleaser". He, of course, does nothing to change anything and everything goes on much as it did before except now the Navy has a disposable fall guy in place if things go wrong again.
When I visited the California EPA offices in San Francisco and examined the Mare Island file I saw a letter addressed to the Shipyard Commander. Its topic was the Mare Island Naval Shipyard sewage system. The letter demanded that the Shipyard Commander specify to the State of California the date by which it was either going to fully treat all Mare Island sewage for cyanide and hexavalent chromium contamination using a permitted treatment facility or, if it didn't want to do that, when it planned to upgrade the Mare Island sewage system to meet the design requirements of a certified hazardous waste pipeline. There's no doubt the State of California knew that Mare Island sewage was actually also hazardous waste. What the Navy did was to ship all of the shipyard sewage, about 200,000 gallons per day, out of the State of California to a disposal facility in the State of Utah. The way this was done was to deliberately and falsely call the sewage "bilge water" or water from the bilges of ship. They did this because under California law there is a specific exemption for bilge water. This is that it must be manifested and shipped as hazardous waste inside California, but once it leaves the State it's no longer considered hazardous waste. Many railroad tank cars were used to ship all of the Mare Island sewage, falsely called bilge water, to a disposal facility in Utah that did not know it was sewage. At this facility all of the railroad cars were dumped into a huge lagoon that was allowed to stagnate in the desert sun. This sewage did what all sewage does when it's allowed to just sit, went rotten and began to give of huge amounts of hydrogen sulfide gas. This "rotten egg" gas is more toxic to human beings than the cyanide gas used in the prison gas chambers. The facility operators thought it was just bilge water which is basically clean fresh water with a little oil in it and were very surprised to find out it was actually raw sewage. The result was the disposal facility had to be abandoned, was severely damaged and the owners suffered huge financial losses and sued the Navy. The court ordered the Navy to turn over all of its hazardous waste manifest documents for all these thousands of railroad car loads. The Navy refused and replied with its usual "excessive and burdensome" routine. The many boxes full of these documents were cleverly hidden about 20 feet from where I worked and were never turned over. The story the Navy finally concocted would be funny if it wasn't such a huge lie. The facility operators were finally put off by being told the big lie that all of the water that had been shipped to them was actually bilge water, but it had been taken from a super secret spy submarine, and the sailors on that submarine routinely urinated into the bilges. So many rail cars were used to transport this sewage that the post closure activity at Mare Island took three years to clean all of the cars, certify them clean, and then disperse them throughout the United States.
The subject of this Memorandum of Understanding was a professional topic of mine while I was employed at Mare Island after it closed. I was asked to write sampling recommendations for the people who did the sampling, and I did so according to the specified Federal and State requirements. The first thing that happened after I turned this in was that I was made subject to a campaign of harassment, intimidation and entrapment schemes designed to put my employment in jeopardy. I was told by the sampling personnel that there was no way they were going to conduct sampling according to my "stupid s..t". My understanding of the matter at that time was that the U.S. Navy wanted Mare Island to be sampled dishonestly and in complete violation of applicable rules and regulations and was happy with the results that came from this policy.
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