My HSF-DEIS Comment

SUBHEAD: A real comment to a fake Draft Environmental Impact Statement.

 By Juan Wilson on 23 February 2009 for Island Breath
(http://islandbreath.blogspot.com/2009/02/my-hsf-deis-comment.html)
 

Image above: A Davy Crocket tactical nuclear field weapon being calibrated during the Cold War. These devices were tested in Hawaii with DU (U238) substituted for weapons grade uranium. 

The following is a letter mailed today as my comment to the Superferry Draft EIS. Today is the deadline for postmarks on comments. Any comments must be mailed to both addresses listed at the beginning of the letter. to: 

Ms. Katherine Kealoha, Director, Office of Environmental Quality Contro
l235 South Beretania Street, Suite 702. Honolulu, HI 96813 

cc: Mr. Michael D. Formby, 
Deputy Director, Dept of Transportation Harbors Division 
79 South Nimitz Highway, Honolulu, HI 96813 

REGARDING PUBLIC COMMENT ON:

The “Statewide Large-Capacity Inter-Island Ferry” (HSF) Draft Environmental Impact Statement is a sham. (DEIS)

This DEIS document is a sham. It is a pseudo EIS (PEIS). It is an after-the-fact effort to provide cover for the State and HSF Corporation. An honest before-the-fact EIS, revealing the costs, cultural degradation and environmental dangers of Superferry operations would have scuttled the project. 

The State’s executive, transportation and legislature have, in effect, conspired to ignore the law-of-the-land to accommodate a privatized/military scam to finance building and operating two prototype Joint-High-Speed-Vessels (JHSV) for John Lehman (Chairman of HSF Corp) and the U.S. Navy. 

That said, I will comment on the PEIS. My focus is the environmental risks associated with potential contamination of the HSF with Depleted Uranium (DU) through it military use. The PEIS states in section 3.5.2 Depleted Uranium:

“Public exposure to depleted uranium (DU) is highly unlikely, and the risk of exposure via a large-capacity ferry vessel is considered non-existent. DU-containing equipment and munitions are not used in Hawaii. The risk of cross-contamination from contaminated ranges is highly unlikely given existing stringent controls that prevent military personnel and equipment from entering DU-contaminated areas, as well as controls that prevent contaminated military equipment from entering the U.S. Additionally, the military operates its own fleet of ships to transport its vehicles and equipment between the islands, and currently there are no plans for military us of a civilian large-capacity ferry vessel.“

This statement is patently false on several details. The US military has definite plans to use the HSF for transporting the Stryker Brigade from its its headquarters at Schofield Barracks to the Stryker firing range in Pohakuloa Fire Range on the Big Island. John Lehman was quoted saying so on 3/26/05 in Pacific Business News. 

Moreover, the loan guarantees that allowed the construction of the HSFs was granted by the U.S. Maratime Adminsitration on the condition that the HSF be part of Voluntary Intermodal Sealift Agreement, or VISA, program that makes merchant vessels available to the U.S. Navy as needed whenever required. Until recently the US Army has strongly denied that DU had ever used in Hawaii.

The 4/23/08 Honolulu Advertiser detailed the DOD decision to leave in-place Depleted Uranium found at both Schofield and Pohakuloa, saying it was harmless. This contradiction demonstrates that either the military was ignorant or misleading in its statements about the existence of DU use in Hawaii. In either case this negates the assessment by the DEIS that there is no possibility of exposure in Hawaii DU.

Weapons platforms associated with the Stryker Brigade that use DU munitions include the M113 Armored Personnel Carrier, the Apache Attack Helicopter, the Cobra Gunship Helicopter, and 155mm towed Howitzer canons. The Superferry is designed to carry all of these platforms in its cargo bay.

In its “Brief Summary of DU” in 3.5.2 the DEIS states:

DU is a common, naturally occurring and radioactive substance. A normal part of rocks, soil, air, and water, it occurs in nature in the form of minerals. DU is a slightly radioactive metal toxic to humans when ingested in large quantities.

This statement gives the impression that even if there were use of DU in Hawaii, and it were to contaminate the equipment and personnel, there would be little danger. Nothing could be further from the truth. This is a false impression. “Depleted Uranium” is really a misnomer. It is radioactive Uranium 238. It is typically created as a residue in atomic energy plants or nuclear weapons processing. DU has a radio-active half-life of 4.46 billion years. It is associated with cancer and other human illnesses. That translates to DANGEROUS FOREVER.

As far back as January 2001 it was reported in The New York Times:

U.S. warned of Depleted Uranium in Kosovo By Marlise Simons on 9 January 2001 in the New York Times

“After the NATO bombing campaign of 1999, the United States urged allied armies to take special precautions on entering Kosovo because American ammunition littering the landscape contained depleted uranium that posed possible health risks.

A document called ''hazard awareness'' issued by the Joint Chiefs of Staff warned soldiers and civilians against touching spent ammunition or other contaminated materials. It said personnel handling the heads of anti-tank shells or entering wrecked vehicles should wear protective masks and cover exposed skin, and people involved in the more hazardous clearing tasks should undergo health assessments afterward.

The document, dated July 1, 1999, was circulated among the militaries of the countries involved in the Kosovo campaign, and Germany, France and other countries passed along the warnings to their soldiers.

The Dutch defense ministry said it gave specific instructions about how troops were to confront the uranium problem before they went to Kosovo. ''Our troops were told to mark or cordon off contaminated areas, avoid any contact and call in special demolition units,'' a spokesman at the foreign ministry said. A growing number of former peacekeepers from Europe and Canada have contracted cancer or cancer-like diseases. At least 15 have died of leukemia -- 6 in Italy, 5 in Belgium, 2 in the Netherlands and 1 each in Portugal and Spain.

While acknowledging the hazards, both the Pentagon and NATO, pointing to medical experts, have denied that any links could exist between exposure to depleted uranium and the illness and deaths of veterans. Defense ministries in several countries have acknowledged receiving the American document, which has not been released. It was made available to The New York Times in Europe today by a militry official from a NATO country.

While NATO officials said it was normal practice to inform troops about hazardous materials, the warnings about depleted uranium are likely to deepen concern in Europe. Ten countries have ordered investigations into possible links between the illness of soldiers and their exposure to depleted uranium. Only American planes fired such uranium-tipped weapons during the 11-week Kosovo air campaign, using some 30,000. Uranium is one of the heaviest metals, which makes it effective in piercing targets like tanks or concrete.

A byproduct of enriched uranium, the depleted form is only mildly radioactive, but when it pulverizes in an explosion or fire, its dust is considered potentially hazardous if ingested or inhaled. The German government said today that while it would not order mandatory screening of those who served in the Balkans, all 50,000 of them could ask for a free checkup at a military hospital. Portugal dispatched three cabinet ministers to Kosovo today and also sent a team of military inspectors after the recent death of a soldier from leukemia.

The Dutch ministry of Defense said it was reopening the investigation into the recent deaths of all soldiers, although only two died of leukemia. Several governments said they were still poring over health records to establish whether cancer rates among peacekeepers were different from those of the same age group of the population. The American document said that D.U., as depleted uranium weapons are known, ''is a safe and effective munition.''

But ''residual heavy metal toxicity in armored vehicles struck by D.U. perpetrators could pose possible health risks for those that access those vehicles,'' it said. The document says soldiers entering armored vehicles hit by depleted uranium weapons should wear masks and cover exposed skin, and should be examined and their potential exposure recorded. The document does not mention radiation, which is said to be weak in the employed form of depleted uranium. It recommended that suspicious debris be reported for clearance. It also said potential risks should ''be passed on to both nongovernmental organizations and returning refugees.''

Despite such warnings, 14 scientists from the United Nations Environment Program said they found remnants of uranium-tipped ammunition still lying around. The team, recently returned from a two-week mission in Kosovo, said it found remnants of depleted uranium ammunition accessible to playing children and animals. The team has urged that contaminated sites be restricted and cleaned as soon as possible.

It is clear that the US military intends to continue the use of DU munitions, regardless of collateral health concerns, because it is so effective in the field. Why worry about Depleted Uranium? Just ask any Gulf War One veteran. 

In 1991, the US allies fired almost a million depleted uranium rounds (or some 2700 tons). Today, about a third of those veterans are on disability. Many of the surviving vets claim they have been permanently disabled by widespread use of depleted uranium. Moreover, thousands of Iraqi civilian deaths have been attributed to DU poisoning. 

Birth defects here and in Iraq have also been reported. After the 1991 Gulf War, Colonel Doug Rokke served as the U.S. Army Depleted Uranium Project Director. Once in the field he found that an effective clean-up was unachievable and he was poisoned by DU himself. Rokke now agrees with the Untied Nations that the use of Depleted Uranium constitutes a 'war crime'. Below is a small portion of a statement he wrote in February 2007.

“I was assigned to the 3rd U.S. Army Depleted Uranium assessment team as the health physicist and medic by order of Headquarters Department of the Army in Washington, D.C. What we found can be explained in three words: "OH MY GOD". According to official documents each uranium penetrator rod could loose up to 70% of it's mass on impact creating fixed and loose contamination with the remaining rod passing through the equipment or structure to lie on the terrain.

On-site impact investigations showed that the mass loss is about 40% which forms fixed and loose contamination leaving about 60% of the initial mass of the penetrator in the solid pencil form. We found that standard radiacs will not detect this contamination. Equipment contamination included uranium fragments, uranium oxides, other hazardous materials, unstable unexploded ordnance, and byproducts of exploded ordnance.

U.S. Army Materiel Command documents sent to us stated the uranium oxide was 57% insoluble and 43 % soluble and at least 50% could be inhaled. In most cases except for penetrator fragments, contamination was inside destroyed equipment or structures, on the destroyed equipment, or within 25 meters of the equipment. During the 1994 and 1995 Nevada tests we found DU contamination out to 400 meters from a single incident.

After we returned to the United States we wrote the Theater Clean up plan which reportedly was passed through U.S. Department of Defense to the U.S. Department of State and consequently to the Emirate of Kuwaiti. Today, it is obvious that none of this information regarding clean up of extensive DU contamination ever was given to the Iraqi's.

Consequently, although there still are substantial radiation contamination hazards existing within Iraq these hazards have been ignored by the United States and Great Britain for political and economic reasons at the same time additional use of uranium weapons has occurred resulting in additional confirmed contamination.”

Dr. Rokke recommends that contaminated and damaged equipment or materials should not be recycled to manufacture new materials or equipment. However, the U.S. routinely returns weapons platforms from overseas combat duty. The Olympian, an Oregon newspaper reported in October of 2007 that the Stryker Brigade officially ended it second tour of duty in Iraq, citing: 

By Christian Hill | The Olympian • Published October 12, 2007
"The long, tough fight is over. The 3rd Brigade, 2nd Infantry Division (Stryker Brigade Combat Team) ended its second deployment to Iraq on Thursday during a welcome-home ceremony at which it celebrated the service of its 3,600 soldiers and their families and remembered its fallen."

In section 4.2.5.2 The DEIS states that:

“DU-containing equipment and munitions are not used in Hawai‘i and the risk of cross-contamination from contaminated ranges is highly unlikely given the existing stringent controls to prevent the military personnel and equipment from entering DU-contaminated areas, as well as the stringent vehicle and equipment cleaning procedures at the overseas location (just prior to being transported to the U.S.). “

It has been documented that there are serious challenges cleaning up equipment that has been in combat areas where airborne powdered depleted uranium has contaminated the environment. DU after impact in a munition is transformed into vapor and fine powder that is breathed by personnel. It can work its way into inaccessible parts of equipment. Extraordinary diligence is required to eliminate it from anything contaminated. Hawaii is scheduled to be headquarters for U.S. Army Stryker Brigade operations. Certainly many of the weapons platforms will be rotated out and back to theaters of operations. The Hawaiian public needs assurances that there is testing and mitigation of any military equipment that may have been in contact with environments contaminated with DU, has fired DU munitions, for been returned from combat before it is transported on ferries (HSF) carrying civilians.If we could trust the State of Hawaii and U.S. Military there might be reasonable tests made for risks associated with depleted uranium.

TESTING FOR, AND DETECTION OF DEPLETED URANIUM

After battle simulations on the Big Island, military cargo and vehicles could inspected for traces of radioactivity by an appropriate Hawaii State agency before they are loaded onto the Superferry. The Superferry itself could be inspected for radioactive contamination after carrying military shipments between Pohakuloa Fire Range and Schoffiled Barracks.

Public routes between Schofield Barracks and Honolulu Harbor as well as between Kawaihae Harbor and Pohakuloa Fire Range could be tested regularly for DU contamination. Parking areas and docks used in off-loading and on-loading Stryker Brigade vehicles and equipment could be inspected regularly for radioactive contamination. But, given the record of the military, and without reliable testing for DU and possible mitigation, is seems prudent to expect the possibility of the spread of uranium 238 contamination of Oahu, Maui, Kauai and the Big Island by battlefield equipment transported on the Superferry for the Stryker Brigade between Schoffiled Barracks and Pohakuloa Range.

Since we know the military plans continued use of DU in its arsenal; and that it has been either ignorant or deceitful regarding DU presence in Hawaii, and considering the potential risk to civilians sharing public transportation with the military, it is urgent that the something effective must be done. As the military has found out with the discovery of DU at Schofield Barracks and Pohakuloa Fire Range, mitigation efforts due to the discovery of depleted uranium contamination is costly, time consuming and prone to be only compromised effort. There is concern that any conventional cleanup procedure that might be employed to assure that the Superferry is not contaminated, might endanger the environment at large.

For example, the washing down of dusty military equipment at the Kawaihae Harbor dock before loading onto the Superferry could endanger the environment of the harbor and nearby reefs with radio-active runoff. Imagine. The very spot on the deck of the Superferry where a muddy Army Stryker (with a DU armed Bushmaster machine gun) is parked back from the Pohakuloa Fire Range carry an open civilian pickup truck (with food and camping equipment) bound for Hilo on the return leg. That should make anyone apprehensive.

MITIGATION RECOMMENDATION
The DEIS should restrict HSF operations to civilian and commercial use only. The Superferry and deny the military any use of the vessel that would include combat equipment or vehicles that are involved DU munitions or armor.

Juan Wilson: Architect-Planner (HI Lic #10138) PO Box 949 Hanapepe, HI, 96716

See also:
Island Breath: DU Confirmed at Pohakuloa 8/21/07
Island Breath: Army to leave DU in Hawaii 4/24/08
Island Breath: Your Comments on HSF-DEIS 2/19/09