(Comments submitted by James Barton to the National Marine Fisheries Service in regard to seismic airgun blasting in the Atlantic.)

18 July, 2017

Modern seismic airguns used to detect off shore natural resources miles below the sea bed have ample power to disrupt severely corroded yet otherwise stable concentrations of sea dumped munitions, thereby inviting dispersal of fragmented chemical weapon filler content “across the sea bed onto dolphin feeding grounds”, and or “spills” ashore; where beachcombers risk injury collecting what they think are interesting rocks instead of something far more dangerous.

Survey companies are now making application to deploy these powerful airguns in U.S. coastal waters of the Atlantic; home to some of the largest known deposits of sea dumped chemical weapons in the world. The simplest means to avert their disruption and dispersal is to “establish exclusion zones for seismic testing over ammunition dumps”.

Dolphin use echo location and long snouts to root through the sea bed in search of food and need only suffer mild chemical agent burn damage to the protective outermost dermal layer of the snout to become terminal victims of viral and bacterial infection, already prevalent in ocean waters.

In waters known or suspected to contain chemical weapon disposal sites, when dolphins wash ashore displaying classic signs of chemical blister agent burns, pathology invariably concludes official cause of death to be from “infection”. This is correct even with known chemical agent burns, because it’s never the burn that kills you; it’s the untreated infection caused by it. Damage to dermal tissue exposed to chemical agent occurs “on contact”, leaving behind no bio-burden or detectable trace of chemical agent to test for.

When beachcombers collect and then break through the outer layer of crust covering a loose chunk of chemical blister agent or white phosphorous ammunition filler content, they receive a serious chemical agent burn, or third degree incendiary burn from a substance that ignites on contact with air and burns at 5,000 degrees Fahrenheit.

In a California case near Camp Pendleton, four hours after Lyn Hiner drove home from the coast with beach “rocks” still in her pocket, the woman’s pants literally “caught fire” while standing in her kitchen. Both the woman and her husband (who had come to the rescue) were hospitalized, and the hardwood kitchen floor was damaged. See “Rocks Catch Fire in Mom’s Pocket”; May 18, 2012 ABC News.

Camp Pendleton officials said “there’s no evidence any military materials were involved”, even though white phosphorous is a man made compound produced almost exclusively for military use, and there is a history of white phosphorous munitions being expended in that immediate area.

An untold number of Atlantic coast watermen have already encountered chemical weapons caught in fishing gear, with some of these incidents resulting in casualties associated with dermal exposure to chemical blister agent, despite these materials having been submerged more than half a century. Entire warehouses full of harvested clams have been deemed “suspect” and voluntarily destroyed. In addition, miles of private driveways traditionally paved with recycled clam shells in the state of Delaware had to be carefully inspected, after a rusty chemical weapon was identified poking through the shells in someone’s driveway; the first of many such items later discovered. New screening requirements for recycling clam shells at processing facilities are now in place to prevent distribution of these materials.

Perhaps fearing loss of income, watermen reports of chemical weapon encounters dropped, yet casualties continue. Defense officials established programs for specialized training of area medical staff to identify, treat, and report casualties associated with chemical agent burns, as well as teaching watermen how to manage such encounters without injury. But excellent “crisis management” is not the same as “source reduction”. As standard military operating procedure dictates, no effort is expended to identify or eliminate the source of contamination; just elimination of items on hand.

It is reasonable to conclude that expanding an existing chemical weapons waste stream via “unrestricted seismic testing” will result in an increase in chemical weapon casualties by watermen.

Unlike the rest of the world, the U.S. has recorded few beachcomber casualties associated with the collection of chemical agent or white phosphorous residuals masquerading as colorful rocks; and no dolphin deaths clinically linked to chemical weapon exposure. That could change if unrestricted seismic surveys proceed because of the age, scale, geographic location, and abundance of ammunition dumps in Atlantic waters.

Establishing exclusion zones for seismic testing over ammunition dumps is a reasonable threat reduction strategy, given that until the seventies industrial quantities of chemical and white phosphorous filled munitions were routinely disposed of at sea from multiple points of origin along the Atlantic coast.

Not all ammunition dumps are charted, and specific records for any are scarce. Generally speaking, documented dumpsites were shaped like a circle or rectangle, usually ten miles or more across. The youngest of these deposits are near fifty years old; the oldest closer to 100 years old. The physical condition of what are mostly iron bombs and projectiles range from fully intact, to a non-descript pile of rust surrounding fragile remains of the original filler content. Dumps can be found inside harbors, outside harbors, near shore, and many miles offshore.

The magnetic signature of ferrous munitions allow the true margins of a dump site to be identified and charted using industry standard non-destructive technologies like “towed magnetic array” or “underwater autonomous vehicle”. These make it entirely possible for at least some ammunition dumps to be excluded from seismic survey disruption, and thereby reduce the very real potential for “seismic airgun induced expansion of an existing chemical weapons waste stream”.

It could take years after seismic disruption of an ammunition dump before hazardous fragments migrate onto dolphin feeding grounds or reach shore; if ever. But should that day come, the obvious question stakeholders will ask is “Why didn’t we restrict seismic testing over ammunition dumps?”

It’s important to note when intact munitions wash ashore, military and other assets provide a rapid response to eliminate that threat. Once set in motion however, there is no effective response to natural stone looking raw fragments of hazardous material washing ashore, or preventing them from migrating onto dolphin feeding grounds.

Since our exploitation of coastal marine resources continues to evolve, it is difficult to accurately predict the full repercussion of blasting ammunition dumps with powerful seismic airguns, but logic suggests over time we should expect a notable rise in the following:

1. number of dolphin deaths due to “infection”
2. number of “exposure casualties” among beachcombers and watermen
3. number of beaches where residual chemical agent “spills” occur
4. number of “intact munitions” washing ashore
5. number of denials that seismic survey activity could have “influenced the above”
6. recognition that “no one can be held liable for such losses”
7. recognition that establishing “exclusion zones” for seismic testing over ammunition dumps would have been preferable to the predictable expansion of an existing chemical weapons waste stream

Action:

Application for “Incidental Harassment Authorizations” sought by survey companies that allow them to disturb or harm marine mammals during the course of airgun surveys should be remanded to;

1. assess the potential for harm to dolphins resulting from seismic airgun induced expansion and dispersal of an existing chemical weapon waste stream
2. assess the potential for harm to humans and economic enterprise resulting from seismic airgun induced expansion and dispersal of an existing chemical weapon waste stream

For more information, search: “unexploded ordnance washes ashore in (enter any state or nation)”

James Barton
Defense Wastes Policy Advisor
A19371968@gmail.com
(757) 572-7750