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
- 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)
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
Nilda Medina Judith Conde
Technical Evaluation of the document titled
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
Prepared for the Committee for the Rescue and Development of Vieques, the
Vieques Women Alliance, and the Community Group for the Decontamination of
Dr. Jorge L. Colón, Ph.D.
June 30, 2005
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.
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
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.
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.
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
According to the Environmental Protection Agency (EPA) Region 4 there are
various ways to treat propellants, explosives and pyrotechnics (PEP):
* 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
* Exsitu 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
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.
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
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
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,
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
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
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.
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,
xiv. Jenkins, T.F., T.A. Ranney, M.E. Walsh, P.H. Miyares, A.D. Hewitt, and
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 Ricos 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) which could be used in
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,
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.
EPAs 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. 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
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:
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
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.
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.
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, 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. 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 Navys
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 Kahoolawe,
Hawaii should be learned.
In 1995, a GAO report stated that the Navy estimates that it would take
$2 billion and 20 years to clear the 28,800-acre Hawaiian island of
Kahoolawe 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 Kahoolawe 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 Kahoolawe specified that munitions had to be cleared to a level
that would permit public access to those lands. In addition, all
munitions had to be cleared from 100% of the surface of the islands 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 Kahoolawe.
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. Kahoolawe 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 Navys 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
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.
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.
 East and West Vieques Environmental and Munitions Response Program
Update, presented by Project Manager Atlantic Division. NAFVAC, 2004 Navy
and Marine Corps IR Conference,
7.pdf accessed on May 17, 2005
 Military Munitions: DOD Need to Develop a Comprehensive Approach for
Contaminated Sites (GAO-04-147, Dec. 19, 2003).
accessed on June 26, 2005.
 ADMINISTRATIVE ORDER, AS MODIFIED, FOR USE OF CONTROLLED DETONATION
CHAMBER FOR WASTE MUNITIONS, USEPA Region 1, EPA Docket No.: RCRA
 Evolution of Blast Chamber Technology for Demilitarization, Mark S.
Morris, President DeMil International, Inc., 30th Environmental and Energy
Symposium & Exhibition,
www.dtic.mil/ndia/2004enviro/sessions/session3/morris.ppt accessed May 1,
 Systems and Technologies for the Treatment of Non-Stockpile Chemical
Warfare Material (2002), www.nap.edu/openbook/0309084520/html/47.html, The
National Academy of Sciencies, 2002, accessed June 30, 2005.
 Approved Protective Construction (Version 2.0), Technical Paper No. 15,
Department of Defense Explosives Safety Board, Alexandria, VA June 2004.
 MARE ISLAND NAVAL SHIPYARD RESTORATION ADVISORY BOARD (RAB) MEETING
HELD THURSDAY DECEMBER 11, 2003,
www.efdsw.navfac.navy.mil/environmental/Pages/mi031211.htm accessed on June
 Site Inspection (SI) Work Plan Former Camp Beale, Yuba and Nevada
Final, U.S. Army Corps of Engineers, Contract No. DACA87-95-D-0017, Task
Order No. 0027, Project No. J09CA013601Earth Tech, Inc. September, 2004.
 Environmental Impacts of Blow In Place Detonations, D. Walker, T. F.
Jenkins, J. C. Pennington, DOD Environmental Monitoring and Data Quality
Workshop, May 2004.
 Restoration Advisory Board Meeting, PHASE I Expanded Range
Assessment/Site PHASE I Expanded Range Assessment/Site Inspection Status
Inspection Status Update, May 2005,
accessed June 30, 2005.
 Environmental Cleanup at Vieques Island and Culebra Island,
Congressional Research Service, (Memorandum to Honorable José Serrano,
Congressional Research Service, Aug. 4, 2004).
 Unexploded Ordnance: A Coordinated Approach to Detection and Clearance
(GAO/NSIAD-95-197, Sept. 20, 1995).
 Memorandum of Agreement between the Navy and the State of Hawaii, May
6, 1994, Article VI
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