Comment to Town of Brunswick Resolution Session 9/3/2024
Spills of oil and hazardous chemicals are not inevitable!
Spill Prevention Control and Countermeasures Plans (SPCCP) have been required by federal and state regulations for over 50 years! Integrated Pollution Prevention Plans (IPPP) are the modern version of SPCC plans that are the evolution of a half dozen federal and state regulations requiring the SAFE MANAGEMENT of every aspect of development, storage, handling, transportation and use of all oils and chemicals throughout the USA.
Brunswick Landing and its ongoing Management by MRRA, a regional government authority, inherited the mismanagement of oils and chemicals by the US Navy since WWII. SPCC AND IPPP plans remained the responsibility of the US Navy with general management and oversight of those plans MRRA’s responsibility.
Yes! ACCIDENTS HAPPEN!
In my opinion, the PFAS environmental incident shows that government regulations are only effective when they are IMPLEMENTED!
Response to the PFAS spill has been immediate and coordinated at the highest levels of government. By definition: RESPONSE IS AFTER THE FACT!
Perhaps the PFAS incident is merely a wakeup call for a timely correction to future MANAGEMENT with emphasis on IMPLEMENTING PREVENTION!
As an environmental engineer licensed to practice in four states, I have extensive experience with issues of this kind including over 50 years’ experience preparing and implementing SPCC and IPPP plans. I have been personally responsible for preparing and guiding IMPLEMENTING PREVENTION for commercial and heavy industrial facilities like the Great Northern Pulp and Paper Mills in Millinocket and East Millinocket and Crowley Energy (formerly Thibeault Energy) in Brunswick.
Here are some points for your consideration in developing an objective path forward in the PFAS saga:
- The presence of hazardous chemicals and other oils and chemicals at BNAS and now Brunswick Landing has been public knowledge at some level since WWII.
- Mismanagement of those oils and hazardous chemicals has been public knowledge with ongoing, detailed, after the fact, responses for adverse environmental incidents for over 30 years.
- Every single one of the Combined Command Agencies, including selected Federal, State and Municipal Employees and Elected Officials were responsible for ensuring PREPARATION and IMPLEMENTATION of PLANS that are COMPLIANT with applicable federal, state and local laws, rules and regulations governing the handling, storage and use of oils and hazardous chemicals to PREVENT harmful uses and releases to the air, land and waters of the Town of Brunswick and all other potentially affected Federal, State, Regional, and Local environments.
- Had the individuals and combined agencies diligently performed their duties and responsibilities to the public, the disastrous PFAS spill should have been PREVENTED.
- Systemic failures caused the PREVENTABLE PFAS SPILL. Labeled as an accident, the PFAS spill consequences are now a long term, monumental environmental and realistically potential human health disasters.
- Scapegoating and standing in a collective circle pointing left is not the long-term answer to minimizing the total environmental impact of this systemic human failure.
- In the immediate aftermath, the PFAS SPILL’s COMBINED COMMAND RESPONSE can only minimize the human and ecological impacts of this systemic failure. This will require massive and timely infusion of FISCAL and QUALIFIED Application of Human Resources. It will also require commitment to the principles of objectivity, critical thinking and cooperation among all parties at all levels during after-the-fact emergency RESPONSE to this PREVENTABLE spill.
- Papering the PFAS SPILL with Knee jerk political and legislative initiatives must be avoided in o to focus and not dilute limited resources from effective short-term and long-term solutions.
- There are plenty of existing laws, rules and regulations applicable to the Brunswick Landing Site.
- Resolutions at all levels must coordinate and focus on renewed COMMITMENT to IMPLEMENTING EXISTING Federal, State, Regional and Local COMPLIANCE MANAGEMENT of the thousands of pages of overlapping LAWS, RULES, STANDARDS and REGULATIONS. These govern the safe production, handling, storage and use of oils, hazardous chemicals and hazardous materials.
- Resolution of SYSTEMIC FAILURE based on lessons learned from the PFAS incident must be carefully CRAFTED by OBJECTIVE ANALYSES.
- Renewed commitment to realistic, broad- spectrum MANAGEMENT focused on IMPLEMENTATION and COMPLIANCE will minimize systemic REPETITION of PFAS-like conditions by emphasizing PREVENTION.
- In my opinion, the first local, functional resolution should be a redoubled effort on comprehensive inventories of all oils, hazardous chemicals and hazardous materials now handled, stored and used at Brunswick Landing and elsewhere in the Town of Brunswick.
- Item 13 above should be controlled and implemented locally with a new Committee or potentially by expanding the scope of an existing Committee such as the CLIMATE ACTION COMMITTEE. Cooperation with MRRA and fiscal support for professional assistance should be funded from the ongoing Federal Superfund program, the US Navy, US Army Corps of Engineers, US Coast Guard, NOAA, USEPA and Maine State EMERGENCY RESPONSE funds.
- Reallocation or expansion of existing Federal funding sources should be aggressively pursued with assistance from congressional representatives – especially Senator King.
- It is my understanding that PFAS is a National Defense facility management issue that was scheduled to be removed from all defense facilities by September 30, 2024.
- Everyone should recognize that combined Federal, MRRA, State and Local professional personnel have been pursuing respective responsibilities for the safe PREVENTION of the PFAS incident since the creation of MRRA OVER 20 YEARS AGO. PASSIVE WATCHDOGGING DOES NOT WORK!
The path forward requires objective, critical, thinking with active management of all oils, hazardous chemicals and hazardous materials WITH EXISTING LEGISLATION, RULES, REGULATION AND STANDARDS applicable at BRUNSWICK LANDING and elsewhere in the TOWN OF BRUNSWICK. The focus of future actions must be ECOLOGICALLY REGIONAL aimed at IMPLEMENTING PREVENTION.
Charlie-
Charles F. Wallace, Jr., PE
Founder & Owner
FMI: resourcesystemsengineering.com
Resident of Mere Point Road since 1955