State of Nevada Review Comments Draft Environmental Assessment Resumption of Use of Depleted Uranium Rounds at Nellis Air Force Range Target 63-10

Carson City, Nevada  September 15, 1997

September 15, 1997

Colonel Michael F. Fukey
Director, Environmental Management
Department of the Air Force
Headquarters, 99th Air Base Wing
Nellis Air Force Base, NV 89191-7007

RE: SAI # E1997-160: Draft Environmental Assessment of Resumption of Use of Depleted Uranium Rounds at Nellis Air Force Range Target 63-10

Dear Colonel Fukey:

   Thank you for granting the State of Nevada an extension of the comment period for the above referenced Draft Environmental Assessment (EA). We also appreciated the Air Force's prompt response to our request for the supplemental materials incorporated by reference in the Draft EA.

General Comments:
   Our review of the Draft EA and accompanying materials suggest that the environmental effects that could be anticipated from the resumption of air-to-ground firing of depleted uranium (DU) munitions have not been adequately assessed. There are two central reasons for this opinion. First, neither the Draft EA nor its predecessor, the Limited Site Assessment, reflect awareness of the scant scientific and technical information on the use of DU and the large uncertainties that characterizes the issue of using DU munitions in the environment. For example, the Draft EA cites the study involving the Yuma Proving Grounds (YPG), LA-13156-MS, September 1996, but fails to capture the large degree of uncertainty about the impact of DU in the environment.

   The YPG investigation included an extensive and detailed review of the scientific information available and attempted to construct an environmental transport mechanism for DU as a means of evaluating the risks that environmental DU poses to ecosystems and to humans. This proved to be impossible because of insufficient data and an incomplete understanding of DU in the environment. Thus, the conclusions from the YPG study were based on unsubstantiated conjecture. This should be reflected in the Draft EA.

   Additionally, the Draft EA should note that the YPG study found DU residues in all components of the environment, that environmental concentrations varied widely, that corroded DU residues are soluble and mobile in water, that wind dispersal during testing is the prevalent means of dispersal of DU particles, and that an unknown degree of risk was posed to human health by DU in the environment. Moreover, there appears to be no insight into the issue of long-term (100 to 1,000 years and longer) environmental threats posed by DU residues. The study concluded by identifying the environmental field and laboratory studies needed to provide a credible assessment of the risks to both ecosystems and humans from environmental DU. This information should also be reflected in the Draft EA.

   The second reason for our conclusion that the Draft EA is inadequate is based on a lack of attention by the Air Force to implementing a comprehensive monitoring program to assess DU airborne emissions and/or transport of DU particulates in surface and groundwater at Target 63-10. The necessity of doing so was one of the most obvious and strong conclusions from the YPG study. Accordingly, an on-site monitoring program for Target 63-10 should be initiated before a responsible assessment can be conducted of the potential for short and long-term effects on humans and ecosystems from transport and corrosion of DU in the environment. Likewise, wind dispersal of dust containing DU generated from air-to-ground firing is a probable transport mechanism of concern¹, one that must be considered in developing a monitoring program for the target area.

   While the Air Force has prepared a brief DU management plan for the range in question, this plan has not been publicly reviewed and appears to fall short of achieving a comprehensive monitoring program to document the possible migration of DU from the target area. Elements of the proposed program apparently have not been initiated even though the Air Force wishes to resume the use of DU munitions at Target 63-10.

   As mentioned above, the Draft EA relies on studies conducted at the Yuma Proving Grounds in Arizona to suggest that no impacts would occur from firing DU munitions at Target 63-10. The EA states that "the general results of this evaluation (at Yuma) should be similar to NAFR Range 63 conditions." In addition, the proposed Finding of No Significant Impact (FONSI) for the Draft EA says that airborne emissions of DU particulates "would settle quickly resulting in minimal air migration." Yet the Draft EA provides no factual evidence, through either on-site monitoring or modeling, to substantiate that dispersal of DU would in fact be minimal and contained to the vicinity of the target area. The document simply states that "air migration of DU particulates is not likely to occur at any great distance due to the extreme density of these particulates and the oxides." The term "great distance" is not quantified. And as mentioned above, an assessment of wind dispersal of dust containing DU that is generated by direct air-to-ground firing has not been performed.

   In a related matter, the Draft EA acknowledged that the nearest population center to the range is Indian Springs, located 12 miles southwest of the target. However, the document fails to mention that a major state institution, the Southern Desert Corrections Center, (with an inmate population of over 1,400 ), is located in the same general vicinity and is likely to be closer to the target than the community of Indian Springs.

   The Draft EA also failed to present, or assess, disposition alternatives for hazardous materials ² and DU wastes. This is a significant issue given the Air Force's failure to provide specific information on the physical forms and probable locations of the estimated 27,000 kilograms (30 tons) of DU that has already been deposited in the target area and on target vehicles. If the preferred alternative is adopted, this volume of contamination would be expanded by an estimated 2,370 kilograms, or 2.6 tons of DU per year.

   Accordingly, by not assessing the "cradle to grave" management of existing and expected to be generated DU materials and soil contamination, the EA is deficient in scope, in terms of compliance with Council of Environmental Quality (CEQ) regulations for defining the "range of actions, alternatives and impacts to be considered" (CFR Parts 1508.25). Moreover, the EA provides little or no information about the management plans, alternatives, and potential hazards concerning disposition of the 200 plus contaminated vehicles that remain in the range holding area; the same can be said for the disposition of thousands of cubic meters of permanently contaminated soil that currently exists [and would be significantly expanded] at Target 63-10.

Recommendations:
   The State's review of the document suggests that the Air Force should not implement the draft Finding Of No Significant Impact for the referenced EA.

   Alternatively, if Target 63-10 is to be used for DU test and training activities, then a detailed Environmental Radiological Monitoring (ERM) program (i.e., risk assessment/DU transport model) should be developed, peer reviewed, and implemented for actual site conditions in the Three Lakes Valley region of the Desert National Wildlife Range. Development of a comprehensive ERM program should proceed any action by the Air Force to resume DU air-to-ground test and training activities at Range 63-10.

   The National Environmental Policy Act (NEPA) review process should also be reinitiated to cover the full scope of issues associated with the management, use, and final disposition of DU munitions. As currently written, the Draft EA is silent on the final disposition of DU contaminated targets and soils. And this is clearly inappropriate, given the volume of legacy waste (i.e., expended military ordnance) that exists today on public lands throughout the west. If the Air Force fails to address final disposition of these wastes in a revised EA, then such an analysis must be presented in the Nellis Range Renewal EIS.

   Finally, the long-term use of DU munitions on the Desert National Wildlife Range appears to be an incompatible activity. To address this issue, the Air Force and the Department of Interior should assess options for land exchanges through appropriate legislative initiatives such as the Nellis Range Renewal process stipulated under P.L. 99-606.

Please contact me if you have any questions about these comments. Sincerely,
 
 

Julie Butler, Coordinator
Nevada State Clearinghouse

JB/jbw
cc:
Richard Urey & Tim Crowley, Governor's Office
Robert R. Loux, NWPO
Lew Dodgion, NDEP
Leo Penne, Washington Office
Michael Wickersham, NDOW
John B. Walker, NWPO
Charles Malone, NWPO
Paul Liebendorfer, NDEP
Karen Beckley, NDEP
Les Monroe, DOE
Ken Voget, USFWS, Las Vegas
Mike Dwyer & Brian Amme, BLM,
Connie Lewis, The Keystone Center
Michele Leslie, The Nature Conservancy
 
 

FOOTNOTES

¹  Ebinger, M.K. et. al., "Long Term Fate of Depleted Uranium at Aberdeen and Yuma Proving Grounds, Phase II: Human Health and Ecological Risk Assessment." September 1996, Los Alamos National Laboratory, (see page 115).

2  The EA is silent about the potential historical generations of mixed waste, as well as the potential generation of mixed waste from future activities on the referenced range.