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comments on Navy's plan to continue open detonation of bom bs on Vieques.........comentarios sobre plan US Navy de co ntinuar detonación abierta de bombas sin explotar en Vie ques

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  • Comité Pro Rescate y Desarrollo de Vieq
    June 30, 2005 Christopher Penny, P.E. East Vieques Project Manager Naval Facilities Engineering Command Atlantic (Code EV23) 6506 Hampton Boulevard Norfolk, VA
    Message 1 of 1 , Jul 1, 2005
    • 0 Attachment
      June 30, 2005




      Christopher Penny, P.E.

      East Vieques Project Manager

      Naval Facilities Engineering Command

      Atlantic (Code EV23)

      6506 Hampton Boulevard

      Norfolk, VA 23508.



      RE: Time Critical Removal Action (TCRA) / Interim Measures

      Work Plan for Surface Munitions and Explosives of Concern (MEC)



      Mr. Penny:



      The community organizations Committee for the Rescue and Development of
      Vieques (CPRDV), Vieques Women Alliance (AMV) and Community Group for the
      Decontamination of Vieques (GCDV) read and analyzed the document Time
      Critical Removal Action (TCRA) / Interim Measures Work Plan for Surface
      Munitions and Explosives of Concern (MEC), Former Atlantic Fleet Weapons
      Training Facility, Vieques, Puerto Rico, March 31 2005, prepared by
      CH2MHill for the Department of the Navy, Atlantic Division, Navy Facilities
      Engineering Command, Norfolk, Virginia, CTO 039, LANTDIV CLEAN III Program,
      Contract No. N62470-02-D-3052.



      Please find enclosed the comments of our environmental consultant which
      include our comments about this document.



      If you have any questions about our comments, please call us at
      (787)741-0716.





      Sincerely,





      Nilda Medina Judith Conde
      Colleen McNamara

      CPRDV AMV
      GCDV

























      Technical Evaluation of the document titled







      Final


      Time Critical Removal Action/Interim Measures Work Plan


      Surface Munitions and Explosives of Concern at Munitions


      Response Area-Live Impact Area, Munitions Response Sites


      1 through 8, 13, 15 through 20, and 29 through 31

      Former Vieques Naval Training Range (VNTR)


      Vieques, Puerto Rico


      March 2005













      Prepared for the Committee for the Rescue and Development of Vieques, the
      Vieques Women Alliance, and the Community Group for the Decontamination of
      Vieques

      by



      Dr. Jorge L. Colón, Ph.D.

      Technical Consultant



      June 30, 2005
      A. Introduction



      In this document we present our technical evaluation of the document titled
      Final, Time Critical Removal Action/Interim Measures Work Plan, Surface
      Munitions and Explosives of Concern at Munitions, Response Area-Live Impact
      Area, Munitions Response Sites 1 through 8, 13, 15 through 20, and 29
      through 31, Former Vieques Naval Training Range (VNTR), Vieques, Puerto
      Rico, March 2005 (from now on TCRA Plan) prepared by CH2MHill for Department
      of the Navy Atlantic Division Naval Facilities Engineering Command.



      The east part of Vieques was used in military practices for close to sixty
      (60) years and was known as the Vieques Naval Training Range (VNTR). The
      14,573 acres of the former VNTR include four areas: the Eastern Maneuver
      Area (EMA), with about 11,00 acres and which included the facilities at Camp
      García; the Atlantic Fleet Weapons Training Facility (AFWTF) composed of the
      Surface Impact Area (SIA) and the Live Impact Area (LIA); and the Eastern
      Conservation Zone on the east end of the island. The Navy detonated over
      27,000 tons of bombs at the LIA. Although the public notice announcing the
      TCRA Plan says aproximatelyt 6,000 of the 15,000 acres that the Navy
      transferred to the US Fish and Wildlife Service (USFWS) can contain
      munitions and explosives of concern (MEC), we have found information that
      the Navy estimates that all 1,100 acres of the LIA are possibly contaminated
      by munitions and unexploded bombs and their detonation products. In
      addition, for the EMA, the Navy estimates that 5,700 acres of the 11,070
      acres as also possibly contaminated with munitions and bombs.[1]



      The TCRA Plan was developed to complete the removal of munitions that are
      found on the surface for approximately 400 acres within the LIA and to
      reduce the danger that the explosives present to authorized and unauthorized
      land users. The following actions are proposed: “(1) Site preparation,
      including vegetation removal from the areas to be cleared of munitions items
      and performance of UXO safety support required for this operation; (2)
      Locating surface munitions items using a metal detector-aided approach; and
      (3) Identification, removal, and disposal of surface munitions equal to and
      greater in size than a 20 mm projectile. The removal action will require
      detonation of some of the munitions with explosives.” The TCRA Plan
      explains that these activities would start in May and extend until October
      2005.



      The TCRA Plan proposes that the removal of munitions should be done with the
      fastest and more economical method which they claim is the detonation of the
      UXOs where they are found (Blow in Place, BIP).



      Next we evaluate the Revised Draft Final Work Plan starting with general
      comments, followed by specific comments and finishing with a final comment.


      General Comments




      1. The Navy should discontinue the removal of UXOs by BIP until it
      evaluates modern technological alternatives, such as the controlled
      detonation chamber, that protect better the environment and human health



      Among the solid wastes or hazardous constituents contained in UXOs are:
      lead, RDX, TNT, DNT, 2,4,6 TNT, HMX, 2A-4,6-DNT, 4A-2,6-DNT, 2,4-DNT,
      2,6-DNT, N-nitrosodiphenylamine, picric acid, furans, dioxins, aluminum,
      magnesium, hexachlorobenzene, di-n-butylphthalate, pentachlorophenol,
      antimony, molybdenum, thallium, barium, copper, cadmium, 1,2-dibromoethane,
      nitroglycerin, dieldrin, and arsenic. The open burning or detonation and
      BIP of munitions is a process that releases many of these known toxins into
      the air and eventually to the soil.



      The United States General Accounting Office (GAO) has recently indicated
      that ranges contaminated with military munitions may have soil, groundwater,
      and surface water contamination for any of the over 200 chemical substances
      that are constituents of the munitions. The report states that humans
      potentially face long-term health problems, such as cancer and damage to
      heart, liver, and kidneys, when exposed to some of these constituents. Of
      the over 200 chemical constituents, there are 20 of greatest concern due to
      their potential environmental impact and widespread use. These munitions
      constituents of greatest concern are listed in Table 2 of Appendix 1 of the
      GAO report which is presented below.[2]





      The potential effects of 5 of the 20 munitions constituents of greatest
      concern are presented in Table 3 of Appendix 1 of the GAO report, which is
      reproduced below:





      According to the Environmental Protection Agency (EPA) Region 4 there are
      various ways to treat propellants, explosives and pyrotechnics (PEP):[3]



      * Open Burning/Open Detonation (and BIP)

      * Controlled Detonation Chamber (e.g., Donovan Blast Chamber)

      * Blast Containment Structure

      * Hurd Burn Units

      * Confined Burn Facility

      * Carbon and Catalyst Regeneration Units

      * Thermal Desorption Units

      * Vitrification Units

      * Ex–situ and In-situ Vitrification

      * Rotary Metal Parts Treatment Unit



      Other modern technologies are:



      a) tent and foam (used at Fort Ord, California)

      b) Water jets

      c) German-produced HL-21 shape charge (tested aat Aberdeen Proving
      Grounds)

      d) Eearth coverings of controlled explosions



      Technologies such as the Donovan Blast Chamber are alternative and safe UXO
      treatment methods. However, the Navy is only considering using BIP in
      Vieques for UXO removal. The Navy explains that it must use BIP exclusively
      since the munitions are too dangerous to be disposed in any other way.



      Studies conducted at other firing ranges suggest that explosive and
      propellant contaminants migrate to groundwater. In 1994, a study conducted
      at a firing range at Fort Ord in California found that the impact areas were
      contaminated with residues of high explosives, including HMX, RDX, and TNT.
      In 1997, the US EPA Region I ordered the military to cease training
      activities at the Massachusetts Military Reservation (MMR) on Cape Cod, MA
      due to concern for drinking water contamination. Later, EPA Region I
      invoked the Safe Drinking Water Act to protect the health of persons and the
      environment and ordered the training ranges and impact areas to be cleaned
      up. All of the contaminants listed in the GAO report exist in Vieques as a
      result of Navy military exercises.



      More relevant to this document that we are evaluating, in 2001 the EPA
      ordered the National Guard to use a controlled detonation chamber in its UXO
      removal actions at Cape Cod.[4]



      The BIP method that the Navy proposes to use in Vieques brings the problem
      of contaminated soil at each BIP site, and air particulates formed upon the
      detonation that can deposit on the soil, from which contaminants can migrate
      to the groundwater, and the sea. The EPA order in the MMR case adds: “In
      addition to the data indicating the presence of munitions-related
      contaminants following blow-in-place events at MMR, numerous studies show
      that open detonation of munitions and/or UXO causes or may cause releases of
      solid wastes and/or hazardous constituents into the environment.”4 Among
      the studies cited in the EPA order are:4



      “i. Demolition Area 1 at MMR was used for demolition training and disposal
      of munitions and UXO. As stated above, at Demolition Area 1 contaminants
      including RDX and 2,4,6-TNT were detected were detected in groundwater at
      levels greater than health advisories. Contaminants including RDX, HMX,
      2A-4,6-DNT, 4A-2,6-DNT, 2,4-DNT were detected in surface soils and
      subsurface soils.

      ii. AEHA 1983, Hazardous Waste Management Study No. 37-26-0442-84, Phase

      2 of AMC Open-Burning/Open-Detonation Grounds Evaluation, Ravenna Army
      Ammunition Plant, Ravenna, Ohio, 31 October - 3 November 1983, U.S. Army
      Environmental Hygiene Agency (AEHA), Aberdeen Proving Ground, MD.

      iii. AEHA 1985, Ground-Water Monitoring Study No. 38-26-0457-86, AMC Open

      Burning/Open Detonation Facilities, February 1984 - March 1985, U.S. Army
      Environmental Hygiene Agency (AEHA), Aberdeen Proving Ground, MD.

      iv. AMCCOM 1992, Development of Methodology and Technology for Identifying

      and Quantifying Emission Products for Open Burning and Open Detonation
      Thermal Treatment Methods, Field Test Series A, B, and C, Volume 1, Test
      Summary, Headquarters U.S. Army Armament, Munitions and Chemical Command
      (AMCCOM), Rock Island, IL.

      v. Craig, H.D., A. Markos, H. Lewis, and C. Thompson 1993, Remedial
      Investigation of Site D at Naval Submarine Base Bangor, Washington, In:
      Proceedings of the 1993

      Federal Environmental Restoration Conference, Washington, D.C., Hazardous
      Materials Control Resources Institute, May 25-27, 1993.

      vi. Racine, C.H., M.W. Walsh, C.M. Collins, D.J. Calkins, B.D. Roebuck, and
      L.

      Reitsma 1992, Waterfowl Mortality in Eagle River Flats, Alaska, The Role of
      Munitions Residues, U.S. Army Corps of Engineers, Cold Regions Research and
      Engineering Laboratory (CRREL), Special Report 92-5, Hanover, NH.

      vii. Racine, C.H., M.W. Walsh, C.M. Collins, S. Taylor, B.D. Roebuck, L.

      Reitsma, and B. Steele 1993, White Phosphorus Contamination of a Salt Marsh
      Pond Sediments at Eagle River Flats, Alaska, U.S. Army Corps of Engineers,
      Cold Regions Research and Engineering Laboratory (CRREL), Special Report
      93-17, Hanover, NH.

      viii. Walsh, M.E., and C.M. Collins 1993, Distribution of White Phosphorus

      Residues From the Detonation of 81-mm Mortar WP Smoke Rounds at an Upland
      Site, U.S. Army Corps of Engineers, Cold Regions Research and Engineering
      Laboratory (CRREL), Special Report 93-18, Hanover, NH.

      ix. Walsh, M.E., C.M. Collins, and C.H. Racine 1995, Persistence of White

      Phosphorus Particles in Sediment, U.S. Army Corps of Engineers, Cold Regions
      Research and Engineering Laboratory (CRREL), Special Report 95-23, Hanover,
      NH.

      x. NRC 1996, Open Burning/Open Detonation, UXO Baseline Volume 1 - Final

      Report, prepared by Nichols Research Corporation (NRC) for U.S. Army
      Engineer Division, Huntsville, AL, January 31, 1996.

      xi. Murphy, W.L., and R. Wade 1998, Final Report: RCRA Facility
      Investigation,

      Phase II Release Assessment for Surface Water SWMU 03/10 Ammunition Burning
      Ground, Technical Report GL-98-2, U.S. Army Corps of Engineers, Waterways
      Experiment Station, Vicksburg, MS.

      xii. COE 1999, Draft Operable Unit C OB/OD Pad, Ft. Richardson, Alaska
      Interim

      Closure Plan, prepared by CH2M Hill for U.S. Army Corps of Engineers (COE),
      Alaska District, Contract No. DACA85-95-D-0015.

      xiii. Jenkins. T.F., T.A. Ranney, P.H. Miyares, N.H. Collins, and A.D.
      Hewitt 2000,

      Use of Surface Snow Sampling to Estimate the Quantity of Explosives Residues
      Resulting from Land Mine Detonations, U.S. Army Corps of Engineers, Cold
      Regions Research and Engineering Laboratory (CRREL), ERDC/CRREL TR-00-12,
      Hanover, NH.

      xiv. Jenkins, T.F., T.A. Ranney, M.E. Walsh, P.H. Miyares, A.D. Hewitt, and
      N.H.

      Collins 2000, Evaluating the Use of Snow-Covered Ranges to Estimate the
      Explosives Residues that Result from Detonation of Army Munitions, U.S. Army
      Corps of Engineers, Cold Regions Research and Engineering Laboratory
      (CRREL), ERDC/CRREL TR-00-15, Hanover, NH.”





      Therefore, open detonation or BIP must not be selected automatically as the
      preferred method, but must be weighted against other alternatives. In
      considering which methods to use, consideration must be placed to the fact
      that the EOD personnel should determine whether or not a munition can be
      moved considering (a) whether the munition is fuzed or unfuzed, (2) if
      fuzed, whether it is armed (i.e., if the munition was deployed as designed
      but failed to function properly), and (3) the severity of deterioration of
      the munition body and the physical state of the agent fill. In addition,
      consideration must be place into modern UXOs removal technologies.



      For Vieques, even upon considering these factors, it is impossible to
      determine that ALL munitions encountered in Vieques are fuzed and armed and
      so dangerous to EOD personnel that they need to be disposed by BIP. At the
      Restoration Advisory Board (RAB) meeting that took place in Vieques on May
      12, 2005 and in which we were present, the Navy claimed that UXOs had to be
      disposed using BIP because ALL bombs that have been found and those that
      will be found during the TCRA, the explosives personnel are declaring them
      too dangerous to be moved before detonating them. However, the person
      reporting on the emergency removal action that took place from February
      until April 2005 admitted that some UXOs were transported and gathered at
      the former OB/OD site at the LIA. If the UXOs can be transported to the
      OB/OD site, then they can as well be transported to an area where the
      Donovan Blast Chamber can be located and the bombs can be detonated there
      inside the chamber.



      Before the RAB meeting, at a meeting with the Puerto Rico’s Environmental
      Quality Board (EQB) that took place on April 7, 2005, the EQB argued that
      this controlled detonation chamber (T-10 model) could not be used because it
      can only be used to detonate small bombs (less than 105 mm). However, the
      community has found documents that indicate that CH2MHill currently has much
      larger models (T-30, T-60, D-60, D-100 and D-200)[5] which could be used in
      Vieques.



      The portable detonation chamber can be transported to a bomb's location,
      eliminating the need to move the bomb. Sealed within the chamber, the bomb
      can be detonated even near heavily populated areas. Air pollution control
      devices reduce the release of chemicals and gases into the air. The Donovan
      Blast Chamber eliminates overpressure, thermal hazards, fragmentation
      hazards, protects agains noise, soil and groundwater pollution, treats air
      discharges as necessary, and is effective for conventional ordnance,
      chemical warfare material, smoke containing munitions and fireworks.5



      Constructed of heavy-gauge steel and armored plating, the transportable
      units for UXO cleanup can withstand detonations of up to 30 pounds of TNT
      equivalent (T-30 model). The fixed chamber handles detonations of over 100
      pounds of TNT equivalent (Models D-100 and D-200) for large capacity and
      high productivity. Model D-60 can be set up as either fixed or
      transportable system for large capacity and moderate productivity.

      CH2MHill, which is carrying out the TCRA removal action in Vieques, is the
      owner of its subsidiary DeMil International, Inc. the company that developed
      the controlled detonation chamber (Donovan Blast Chamber), precisely as an
      alternative to OB/OD of explosives. The Donovan Blast Chamber was
      originally developed to replace conventional open detonation operations in a
      contained environment that prevents the release of blast fragments, heavy
      metals, and energetic by-products. It was later proposed to destroy chemical
      weapons by detonation in its enclosed environment, and it has been proved
      for such purpose in Belgium by the US Army.5,[6]



      The Donovan Blast Chamber has been proposed to be considered for use at
      sites where prompt disposal of large numbers of munitions is require,6 which
      is the case for Vieques. Since CH2MHill is the owner of this technology, it
      would only cost it the transportation costs to bring one chamber to Vieques,
      but this would be paid by the Navy.



      In 2001, the EPA ordered the National Guard at the MMR that, in conjuntion
      to the use of BIP for the fuzed and armed UXOs, it had to use a controlled
      detonation chamber for the rest of the UXOs found. Vieques deserves equal
      treatment. There is no reason that can justify not using a controlled
      detonation chamber in Vieques, if we place higher consideration to the
      well-being of the population over remediation costs.



      EPA’s order to the National Guard at Cape Cod states: “Use of a controlled
      detonation chamber for the disposal of munitions and UXO will prevent,
      minimize, and/or mitigate damage caused by the discharge of solid wastes
      and/or hazardous constituents to the environment which are associated with
      in-place detonations of munitions and UXO.”



      The order further states: “When a decision is made to dispose of a solid
      waste military munition, as defined above, and the appropriate EOD officer
      has determined that the solid waste military munition is safe to move, such
      solid waste military munition shall be: (i) stored in a manner which meets
      the requirements of RCRA; and (ii) disposed of in a controlled detonation
      chamber with air pollution control equipment, or other disposal method
      approved by EPA, which meets the requirements of RCRA, this Order and the
      SOW attached hereto.”



      The Department of Defense Explosives Safety Board has approved the use of
      the Donovan Blast Chamber as an environmentally safe clean-up alternative to
      remove UXOs.[7] The advantages that is has over OB/OD are (i) reduces
      movements and handling to munitions, (ii) eliminates dependency on the
      weather and time of day as it can be operated 24 hours a day in any weather,
      (iii) eliminates residues that could contaminate soil and ground water, (iv)
      reduces noise to acceptable industrial standards, and (v) eliminates shock
      waves that disturb nearby populated areas. The chamber's use has received
      concurrence and praise from the Environmental Protection Agency and state
      regulators.



      The Navy itself has decided to use as an alternative to BIP, the combined
      use of BIP and the Donovan Blast Chamber. At the Mare Island Naval Shipyard
      in California. At a RAB meeting there the Navy officer explained the
      benefits of using the Blast Chamber:[8]



      “One of the big advantages is that both DOD and regulatory agencies have
      reviewed it and approved it for use under the appropriate conditions.



      Noise and fragmentation concerns are eliminated because of the contained
      nature.



      And detonation gases are contained and put through a filtration system
      that's on the same trailer.”



      In addition, a Blast Chamber has also been added for UXO removal in the U.S.
      Army Corps of Engineers’ Site Inspection (SI) Work Plan at Former Camp
      Beale, Yuba and Nevada Counties, California.[9]



      Recently, there has even been efforts to develop alternatives to traditional
      open detonation for munitions discovered during munitions responses that are
      determined unacceptable to move. A Fuze solution or an Alternative Donor
      Charge Solution have been evaluated. In fuze testing the premise is to
      “evaluate whether it is feasible to deactivate or remove the fuze from a
      Live UXO item without detonating, thereby rendering it acceptable to move,
      preferably with remote equipment.”[10]






      Specific Comments




      1. An alternative section must be included in the TCRA Plan



      A section detailing which other alternatives were considered for disposition
      of UXOs should be included. Considering that in the Emergency Response
      Action (ERA) that occurred between January and April 2005, on just 10 acres
      surveyed in the LIA, the density of UXOs found was 185/acre,[11] then for
      the 400 acres, if the density is the same (unlikely, since the ERA only
      surveyed the beaches), then we can calculated that a total of more than
      74,000 UXOs might be encountered. This would mean that many BIP events
      would be performed. Alternatives to BIP must be evaluated and discussed in
      the TCRA Plan.



      2. Only surface UXOs are being considered in the removal action



      Recently, the Congressional Research Service (CRS) published a report on the
      environmental cleanup at Vieques and Culebra.[12] This report says that the
      DOD standards for the removal of ordnance at former training ranges
      indicate that excavation and removal must be done down to ten (10) feet, if
      the area will be used in the future as a commercial or residential area, but
      just one (1) foot if the area will have limited public access uses, such as
      a wildlife refuge. We have also seen information that for agriculture at
      least a four (4) feet depth must be excavated and UXO be removed. These
      standards do not establish how deep to excavate and remove UXO for areas
      where no public presence will be allowed, or what are the standards for
      removing UXO in underwater areas.



      Although we understand that this a a TCRA, we believe that the Navy’s
      objective is to excavate and sweep for UXO in Vieques down to one (1) foot
      below the surface, if at all, in designated areas of the wildlife refuge,
      while not doing any subsurface cleanup at the LIA.




      The Navy must not forget that contamination can not be contained by putting
      up fences. First, run-off from rainwater can carry contaminants to the sea
      and to other areas on the LIA or outside of the LIA. Secondly, the
      contamination of the groundwater and aquifers has not been ruled out by any
      comprehensive study. Third, there is hydraulic connection between the highly
      contaminated lagoons of the LIA (were hundreds, if not thousands, of UXO
      remain) and the sea, and that when floods occur, the whole LIA gets
      submerged and connected to the sea. Therefore, existing contamination will
      migrate to the sea, contaminating the environment and the habitat of many
      species, some of which are endangered species. In addition, contaminated
      marine plants will result in an unacceptable risk of contamination to other
      animals and to the population from the bioaccumulation through the food
      chain. This migration of contamination from the LIA to other zones in
      Vieques has existed for a long time; it currently exists; and it will
      continue to exist in the future. Any cost estimate that is based on the
      false assumption that such migration does not occur is unacceptable.
      Recently, Tropical Storm Jeanne provoked that at least one bomb to surface
      at one of the beaches in eastern Vieques where the U.S. Fish and Wildlife
      Service allows public access. The USFWS` proceeded to close the three
      beaches in the area. If we consider that Jeanne was not a hurricane when it
      passed through Vieques, there is a real possibility that natural events may
      extrude UXO from land and water open to public access. Therefore, removal
      of UXO must be as complete as possible. Simply erecting fences around an
      area will not rule out these possibilities. There is a clear and present
      risk of contamination from the LIA, and the people of Vieques should not
      have to live with that risk for the rest of their lives. A high standard of
      cleanup should be reached. The lessons from the cleanup of Kaho’olawe,
      Hawaii should be learned.




      In 1995, a GAO report[13] stated that “the Navy estimates that it would take
      $2 billion and 20 years to clear the 28,800-acre Hawaiian island of
      Kaho’olawe to achieve a 4-foot depth needed for farming. The services have
      used the island as a bombing range since 1941. However, when the Navy
      concluded the clean up of Kaho’olawe in November 2003, its clean up costs
      were $460.5 million between fiscal years 1993 and fiscal years 2004.11 The
      Memorandum of Agreement between the Navy and the State of Hawaii for the
      transfer of Kaho’olawe specified that munitions had to be cleared to a level
      that would permit public access to those lands.[14] In addition, all
      munitions had to be cleared from 100% of the surface of the island’s lands,
      and 25% of the island would be restored to the point that it could be used
      for multiple purposes, including human habitation. However, now that the
      cleanup has finished, the community understands that the Navy did not met
      these standards in cleaning up Kaho’olawe.



      There are no munitions clearance levels standards stipulated in the
      Memorandum of Agreement between the Navy and the Department of Interior for
      the transfer of Vieques. However, as the CRS report indicates, the Navy plan
      is to cleanup Vieques to levels that permit very limited human presence, and
      assumes that there will never be human presence in the LIA. Kaho’olawe was
      an uninhabited island, whereas Vieques has always been inhabited. Logic
      mandates that an uninhabited island should be cleaned up to a level that
      permits human presence in those lands. It is known that the Municipality of
      Vieques and the Government of Puerto Rico will in the near future request
      that those lands be transferred to the people of Puerto Rico and Vieques,
      and that in the meantime they will ask for public access to those areas in
      the Land Use Plan being developed by the USFWS and the U.S. Navy.



      We believe that the Navy intends not to clean up the LIA to a level that
      would permit public access to those lands; if implemented, such a policy
      would be extremely dangerous. A low level of cleanup is unacceptable for
      Vieques, which relies heavily on fishing and tourism for its economic well
      being. Vieques should be developed in a sustainable way and with the full
      participation of its inhabitants. The Navy’s intention should be reversed by
      active, ongoing intervention by EPA on the AFWTA Superfund site. Regardless
      of whether and when legislation regarding public access to these lands is
      amended, the lands and waters in eastern Vieques have a long history of
      human use, including fishing and diving, as well as scientific research and
      management of ecological areas. Cleanup plans must take into account these
      long-established uses. The cleanup, including that required for the Live
      Impact Area, must be as complete as possible and must permit the lands to be
      used by the Viequenses. A merely superficial cleanup would be less expensive
      but would not guarantee the safe use of those lands by human beings. The
      United States Navy, with oversight by the EPA, must promptly clean up the
      contaminated soil and water in order to safeguard the health and sustainable
      development of the people of Vieques.



      3. EPA monitoring



      On a community meeting on April 7, 2005 the EPA admitted that they did not
      monitored the emergency removal activities that occurred from January to
      April 2005 on East Vieques, because the Navy did not gave them a permit to
      observe the removal activities. Nor had the EPA obtained a permit to
      monitor the TCRA. We believe that it is necessary that the current TCRA
      under CERCLA is monitored by the EPA in this Superfund site.



      4. No analysis of soil (or air monitoring) before and after a BIP event
      is included



      Such an analysis will help determine the amount of explosives that are
      deposited on the ground after a BIP event and can be included to access how
      much contamination the BIP event is adding.




      Final Comment




      The Vieques community expects that new technology will be used in Vieques in
      order to guarantee the safety of the population of Vieques. Just last week
      the people of Puerto Rico were notified that a study of the Puerto Rico
      Department of Health reveals that the incidence of cancer in Vieques is
      still the highest of any municipality in Puerto Rico and that it is over 50%
      higher that for the rest of Puerto Rico. Any activity that adds to the
      concern that the viequenses have for the well-being must be considered
      carefully, with all available alternatives fully studied, before selecting
      it as the alternative.



      We expect that the current TCRA will be suspended until alternative to BIP,
      such a the Donovan Blast Chamber, are considered.




      _____

      [1] East and West Vieques Environmental and Munitions Response Program
      Update, presented by Project Manager Atlantic Division. NAFVAC, 2004 Navy
      and Marine Corps IR Conference,
      enviro.nfesc.navy.mil/erb/erb_a/support/cleanup_conf/2004conf/proceedings/12
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      [14] Memorandum of Agreement between the Navy and the State of Hawaii, May
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      www.hawaii.navy.mil/CNBDATA/Kahoolawe/index.htm



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