To County & State officials:
FYI Why have no county or state elected officials even attended the public hearings on military expansion plans at PTA?
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||Fwd: Comments on Depleted Uranium (DU) at PTA: DPEIS Modernization of PTA…
||Sun, 27 Nov 2011 16:20:00 -1000
||Jim Albertini <email@example.com>
||Gill, Gary L. <Gary.Gill@doh.hawaii.gov>, Jeffrey.Eckerd@doh.hawaii.gov
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Gary and Jeffrey,
Please read the comments below of Hawaii resident, Dr. Mike Reimer, PhD. Retired geologist. His comments on DU at PTA are particularly note worthy.
The DOH should be involved in this process, speaking out for citizen health and safety. Please end your silence. Support the call for comprehensive, independent testing and monitoring at PTA, with citizen oversight, to determine the full extent of DU contamination there. The testing and monitoring should be paid with federal dollars since its federally caused contamination.
The military has admitted to DU Davy Crockett spotting rounds being used at Schofield and PTA (and likely Makua as well) only after citizen peace groups exposed the facts. It is possible, even likely, that other DU contamination exists from a wide variety of military DU munitions and DU used as ballast in military activities. Hawaii citizens deserve DOH involvement in this issue on behalf of citizen health and safety. To date DOH involvement has been terribly lacking. Please change this.
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COMMENTS ON: Draft Programmatic Environmental Impact Statement Modernization of
PTA and Construction and Operation of an IPBA
Written comments may be addressed to PTA PEIS, P.O. Box 514, Honolulu, HI
96809. Facsimiles may be sent to (808) 545-6808. Email comments may be addressed
to PTAPEIS@bah.com. by November 30, 2011.
Herewith are provided limited comments on the Programmatic EIS for the
Modernization of PTA and Construction and operation of an IPBA. I am not going
to make this a scholarly treatise with academic annotations and will presume
that the reader has sufficient background knowledge of the topics presented in
the DPEIS. However, if that is not the case and additional explanatory is
needed, please contact me and I will provide that additional information.
Michael Reimer, Ph.D., Geologist
November 26, 2011
A) There is some confusion with the downloaded copy of the document: In volume
1, perusing the executive summary and table of contents, the document is
referred to as both a draft PEIS (Title page and page footers) and a Final PEIS
(unnumbered page in introduction of executive summary and table of contents,
immediately following the signed authorization sheet). This discrepancy must be
B) The discussion of noise seemingly avoids the issues related to military
training activities. For example, the chart of noise levels at 3.5-1 should
include sound levels common with military activities, such as tanks without
muffled exhaust systems, weapons firing, helicopter and jet flights and bombing
practice with live munitions.
For example, the threshold of pain and permanent damage to hearing is 130-140
db. Jet aircraft typically are at 140 db and higher, artillery fire at 160 db
and higher and jets at full power (takeoff or climbing) are at 180 db and higher
as would be 1 ton of TNT exploding or at the muzzle of artillery. Of course,
there are the low frequency pressure waves (impulsive noise) associated with
explosions that can rupture ear drums if a person is within a certain close
radius of the detonation site.
There have been reports by individuals quite some distance from PTA hearing
explosions, especially when local noise from daytime activity is reduced
(vehicular traffic, for example). Those who may have visited the Gettysburg, PA
civil war battlefield and had a guided tour will have heard of the reports of
Pittsburgh residents, 150 miles distant, hearing the cannon fusillade preceding
The DPEIS should address this issue of distant noise as nuisance and disruptive
from PTA training and hopefully training will minimize use of artillery at night
or schedule training when atmospheric conditions are minimally conducive to
carry or reflect the noise larger distances.
C) Of particular interest is the concern with depleted uranium (DU). It has
been a continuous concern for the Army at PTA ever since it was physically
discovered at Schofield Barracks and PTA.
Depleted uranium is discussed in the Draft PEIS but is glossed over compared to
similar training upgrades proposed for Schofield on Oahu. It is my position
that the issue must be equally addressed for any upgrades involving land use at
PTA to occur. It is interesting the risks of radiation are underplayed in this
report when discussing potential radiation risks and hazards to the public. In
part, such disinformation is understandable because of the general public’s fear
of radiation, a poorly understood natural physical process that has been used by
man for both destructive and constructive purposes. Foremost in the public’s
mind are the atomic weapons and the contamination of “down-winders” and the
great releases of radioactivity from failed nuclear plants. Overlooked are the
benefits from diagnostic and therapeutic medical applications. When radiation
is associated with the military, it brings forth the destructive side and fear
of public exposure risk.
Through various misstatements, the Army does itself no favor and only places
itself at a higher level of distrust. An example of this is the statement in
the PEIS describing another radiation risk to people of the BigIsland, at 3.11
that could also be present at PTA. The element is radon and the statement,
“radon is a …slightly radioactive gas...” (p. 3-111). In fact, radon is a
HIGHLY radioactive gas. Another example is related directly to DU, that the
radiation is 40 percent less than natural uranium section 3.12.2 (p.3-127).
That statement is true only at the time of fabrication of the material from DU.
Within months, the in-growth of radioactive progeny increases the radiation by
30 percent. While still less than natural uranium, it does not remain 40
percent less. These are examples of misinformation concerning radiation to down
play the apparent level of exposure. More informative are the specific activity
of the radioactive isotope and the time of exposure. The facts can be framed in
explanations so that the public can understand the framework of what is being
Do not misunderstand my intent of using these examples in suggesting the amount
of exposure is incorrect. I certainly agree that the relative radon population
risk in Hawaii is low. (see Reimer, G. M. et al, 2005.) However, there are
some areas in which the potential to individuals is high. I simply use this to
suggest credibility is not enhanced by spinning actual facts.
The primary issue here is that for upgrading the ranges at Schofield Barracks,
$30 million is being spent for range cleanup, including DU identification and
removal (depending on the NRC license authorization). There is no indication
that any funds are being allocated to cleanup DU at PTA. The suggestion that DU
is not going to be found at the upgraded range site at PTA is fraught with
uncertainty. Although searches for DU were undertaken at some ranges at PTA
(less than a few percent of the total PTA land area was searched), very few
fragments were located. In other words, if the DU is not to be found where one
is looking, it is likely to be somewhere else.
It is stated that individuals trained in UXO and DU identification searched the
proposed range construction site. One of the identification criteria was the
tell-tale yellow color of DU oxidation. However, the Army in the past has also
claimed that DU at PTA does not oxidize (probably an understatement) of does so
very slowly. Consequently, the identification criterion of color is probably
not useful. The question of whether DU could be present at the proposed
training range is unanswerable until thorough testing and searching is
performed. Remember, it is not necessary for the actual spotting rounds to be
present. DU aerosols, once created and transported, can be resuspended from the
place they have initially settled and settle elsewhere, by simple mechanical
action such as wind, walking, dusting, electrostatic shock, and vehicular
traffic (Hu et al, 2003), let alone by explosions and traffic of heavy armored
vehicles (see DOE Handbook, 1994).
Section 4.12 downplays the risk of exposure to DU mostly through speculation and
not fact. There have not been extensive studies performed and data to support
the speculation is non-existent. Radioactive aerosols can travel fairly large
distances. They have been detected to have traveled over 25 miles. There is
some evidence that DU was found in dust deposited several miles away from the
PTA site at Waiki`i Ranch (See Waiki`i Homeowners Association report at:
Only one sample was collected and the results were at the limit of detection;
yet it was a positive result at the limit of analytical detection and suggests
migration off PTA. It has been documented that DU aerosols can travel 10-25
miles from the source, as has been noted in Colonie, N.Y., where aerosols
collected on distant filters were found from a plant fabricating DU into
munitions (Dietz, L.A., 1997). The range of transport of aerosols within a 15-25
mile radius would impact the cantonment area of PTA with its military and
civilian employees, the Girl Scout camp, the state park, and the populated areas
of WaikoloaVillage and even parts of Waimea. It will also include the proposed
expansion and modernization areas of PTA (range 10). See Figure 3.6.1, p. 3-43.
Despite the claims in the Programmatic EIS, aerosols once created attach and
reattach to surfaces. The binding energy is not very great, on the order of a
few electron volts. For comparison, the kenetic energy of a flying mosquito is a
trillion electron volts. The energy of a rifle firing is ten billion times more
than the mosquito!
In fact, aerosols can be released by low energy activities found in homes, such
as dusting, the vibrational energy from walking and even differential
electrostatic forces (such as cling wrap for covering foods or paper sticking
together when loading it to your printer, less a problem in high humidity
environments). See Hu et al., 2003. Higher energy sources such as might come
from a tank crossing terrain or even modest explosions are capable of releasing
aerosols from the surface; and the presence of oxidized uranium cannot be
discounted as immobile. Radioactive aerosols can be resuspended and transported
by wind; cleanup of a site where the contaminant is found reduces the
concentration of the radioactive aerosols (Shinn, 2003).
The important action here is to have a thorough and adequate monitoring system
I feel no less an effort should be made at PTA than is being done at Schofield
and perhaps more as the range is much larger. PTA should not be shortchanged in
this issue but given the same treatment as Schofield. Are the citizens of the
BigIsland second class and not worthy of the same health and safety precautions
extended to those on Oahu? Historically, it is not unusual for the Military to
thoroughly address the citizen concern about DU. At Lowery Air Force Base
outside of Denver, Colorado, tons of dirt were removed when spent DU munitions
To address the DU issue at PTA, there should be several airborne monitoring
systems up and simultaneously running before any construction activity is
started. Of course, there will be the claim that it is unlikely DU is in the
upgrade area, but frankly, how does one know? If you implement a realistic
search program there and don’t find it, then you can say with some certainty
that it is not there and can begin to search elsewhere.
The Programmatic EIS is inadequate until this issue is dealt with properly and
that would be similar to the same actions as on Oahu. Additionally, no training
and no modifications or construction should be allowed to take place until
proper monitoring is in place.
The issue of previous monitoring will certainly come into play. There is the
claim that past monitoring has not detected any airborne DU. One could argue
equally that the past air monitoring approach was inadequate to find DU. In
fact, this was the NRC conclusion about the Army’s air monitoring plan.
“We have concluded that the Plan will provide inconclusive results for the U.S.
Army as to the potential impact of the dispersal of depleted uranium (DU) while
the PTA is being utilized for aerial bombardment or other training exercises,”
quoting Rebecca Tadesse, Chief of the Nuclear Regulatory Commission's (NRC)
Materials Decommissioning Branch, in a March 2010 letter to Lt. General Rick
Lynch, who heads the Army's Installation Management Command (see NRC Adams
library document ML100350664).
Even though NRC rejected the air monitoring plan based upon the past methodology
as part of the overall radiation safety plan for PTA as being inadequate, they
suggested a more directed and intensive monitoring program. However, air
monitoring of any sort now seems to have been rejected by the Army in their
recent and final November 9, 2011 Environmental Radiation Monitoring Plan (sec
3.5.5) in which they state: “Air samples will not be routinely collected as
part of the ERMP.”
Air monitoring must remain a requirement of constructing and operating this new
facility. Unless fragments have been transported form the areas they lie, such
as between the lugs of tires, possible but unlikely, air particulate monitoring
is the only type of monitoring to determine the probably risk. Ground
monitoring for DU has not proven effective as burial by just a few inches of
soil will attenuate the radiation being released.
In sum, the Programmatic EIS is inadequate until this issue of air monitoring is
properly adopted and DU clean up initiated as was proposed at Schofield. The
public concern is genuine and should not be belittled. No training and no
modifications or construction should be allowed to occur until proper monitoring
is in place. If the Army does not want to engage in air monitoring, then they
should provide funding cooperatively to citizen groups and the state that will
initiate and perform the collection and analysis.
L. A. Dietz, CHEM-434-LAD, "Investigation of Excess Alpha Activity Observed in
Recent Air Filter Collections and Other Environmental Samples", Jan. 24, 1980;
unclassified technical report, Knolls Atomic Power Laboratory, Schenectady, NY
12301; obtained under Freedom of Information Act. Published in Oak Ridge
National Laboratory Report DOE/OR/21950-1022, "Responsiveness Summary:
Engineering Evaluation/Cost Analysis (EE/CA) for the Colonie Site", pp. A70-A89,
DOE HANDBOOK, 1994,AIRBORNE RELEASE FRACTIONS/RATESAND RESPIRABLE FRACTIONS
FORNONREACTOR NUCLEAR FACILITIES, Volume I - Analysis of Experimental Data,
Hu, Bin et al., LITERATURE REVIEW AND PARAMETRIC STUDY: INDOOR PARTICLE
RESUSPENSION BY HUMAN ACTIVITY , U.S. Army Center for Health Maintenance and
Preventive Medicine, Environmental Health Risk Assessment Program, Aberdeen
Proving Ground, MD, USA.
Reimer, G. M. et al, 2005, Indoor radon risk potential of Hawaii, J. Rad. Nuc.
Chem., v. 264, 365.)
Shinn, J.H., 2003, Studies of Plutonium Aerosol Resuspension at the Time of the
Maralinga Cleanup, Lawrence Livermore National Laboratory, Report