Malu 'Aina

To County & State officials:
 FYI  Why have no county or state elected officials even attended the public hearings on military expansion plans at PTA?
 Jim Albertini
 www.malu-aina.org
 
-------- Original Message --------

 
 DOH Officials
 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.
 Mahalo.
 Jim Albertini
 President
 Malu Aina
 www.malu-aina.org
 
-------- Original Message --------

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
GeoMike5@att.net
November 26, 2011
 
 
COMMENTARY
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 
corrected.
 
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 
Pickett’s charge.

  
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 
presented.
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: 
(http://www.garrison.hawaii.army.mil/du/reports/waikii_ranch.pdf).


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 
in place.

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 
were found.

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.
 
References: 


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, 
Jan. 1997.

DOE HANDBOOK, 1994,AIRBORNE RELEASE FRACTIONS/RATESAND RESPIRABLE FRACTIONS 
FORNONREACTOR NUCLEAR FACILITIES, Volume I - Analysis of Experimental Data, 
DOE-HDBK-3010-94, http://www.orau.gov/ddsc/dose/doehandbook.pdf

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.  
http://www.engr.psu.edu/iec/publications/papers/Lit_Review.pdf
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 
UCRL-ID-155063. 

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