Helping Our Peninsula's Environment
Burn Plan (RI/FS) Comments by Dilworth Consulting
Board of Directors
Monterey Bay Toxics Project
May 13, 2002
Comments on Interim Action Remedial Investigation, Feasibility Study and Associated Documents
Table of Contents
B.Threat Reduction Alternatives Needing Analysis
C.Ordnance Detection Alternatives Needing Analysis
D.Faulty And Unsupported Assumption That The Ecosystem Needs Fire
F.Full Method Description Needed
G.Animals Threatened By This Action
H.Environmental Impact Quantification Absent
I.Capital vs. Operations Costs
K.IA RI/FS Failures as an EIS Equivalent
L.Superfund Interim Action Plan For Ranges 43-48,
30a and Site OE-16
M.ATSDR Smoke Model Problems
N.Air Emission Technical Memo
As a Technical Advisor, I have been hired to analyze and critique the Final Remedial Investigation And Feasibility Study (RI/FS), the Technical Memorandum on Air Emissions, the Revised Draft Environmental Impact Report on the Air District's Smoke Management Plan, the ATSDR Health Consultation, the Superfund Proposed Plan and comments by Dr. William Mitchell.
The RI/FS is at the core of this process. In theory, all decisions must rely upon it. So, I begin with its review. I strongly agree with Mr. Mitchell's comments on the RI/FS's startling abundance and depth of serious deficiencies. I also agree with a majority of concerns raised by other Agencies. Agency comments are filled with vivid examples of this document's grim inadequacies. Even after using four times the amount of time for which I am hired, it is not possible to list (let alone describe) all the problems I have found. I will try to add only points not well covered by the other commenters.
The project need and purpose are, in all important aspects, wholly undefined. Because there is no definition of the need it is ambiguous, unmeasurable, untestable and unachievable. When a goal is untestable (e.g. "Let's do better") one can irrefutably claim anything as helping. An undefined purpose is as meaningless as an unsubstantiated opinion. An opinion is not testable precisely because it is not clearly defined.
"Imminent Threat" (p 1) is not defined.
There is no evidence of the need, let alone substantial evidence. Apparently the fundamental reason for this action and its analysis through the RI/FS is allegedly to "protect human health and the environment from an imminent threat..." (p 1). Yet, except for a single sentence on page 14 admitting that no one was harmed, there is no explanation or evidence for the need or purpose.
Lacking evidence and rationale for the need for the action makes it indefensible, arbitrary and capricious. That the burning project will cause human and environmental harm is abundantly obvious, yet glossed over in a similar manner.
These add up to an unneeded project that will cause potentially significant human and environmental harm costing about a minimum of some four million dollars. (RI/FS Appendix C)
The purpose and goals must be re-written with a clear definition and supported by at least some evidence. The project must be reanalyzed in light of a clear purpose and the documents must be re-written and then recirculated to agencies and the public.
Please note the subgoals must also be unambiguously clear. Is a goal to "view the ground surface" or to detect ordnance? I suggest that ordnance detection is the primary goal and visual confirmation is only a secondary goal.
Vegetation removal is not an alternative - it is only one step in the process of one alternative.
The wrong level of alternatives analysis was used. It should focus on diagnosis first.
This proposed action is wrongly aimed as a vegetation clearance project and alternatives (as is vividly admitted by RI/FS Appendix A's Title). It should be a UXO clearance project with alternatives - which it is not.
At least the analysis contains an (inadequate) Potential Solution Alternatives Summary, but it is entirely missing any Problem Diagnosis.
MYOPIC (Extremely Poorly Selected) ANALYSIS
To make an analogy with a meal having several parts (i.e. finding food, cooking, eating and cleanup) this project analysis should have several separate parts including Problem Diagnosis, Potential Solution Alternatives Summary, and a Full Description of Alternative Methods.
It has a crippling lack of a full description of any alternative including their preferred method.
Unfortunately, the document skips right past locating ordinance right to destroying vegetation (page 36). The purpose of vegetation clearing seems to be implied as obvious - yet is not explained.
In my opinion, the project appears to have two steps.
1) Locating the UXO, and then
2) Removing or destroying it. (pg 50)
The project proposes to burn or remove the vegetation (presumably in order to locate the UXO) by an undescribed method and then removing the UXO or destroying the UXO in place.
Alternative methods of locating the UXO without much vegetation, air or soil disturbance with magnetometer type sensors hung below aircraft such as helicopters, extremely low footprint pressure vehicles or aerostatic blimps is unrecognized.
If I may take the liberty of defining the project purpose as "relieving the threat of the remaining UXO" - at least one further alternative should be evaluated.
If I take the liberty of artificially narrowing the definition of the project purpose to "removing the threat of the remaining UXO" the following alternatives should be evaluated.
This would involve a coordinated team on foot (as described on page 51) or in armored vehicles, with detectors.
They first determine if there is any ordnance above ground in brush for the next 10-20 meter wide swath. Next, the surface is checked with hand held mine sweepers. When ordnance is found, the detection crew backs off and the disposal part of the team takes over.
Ordnance has an infrared signature with a high contrast to vegetation and soil both day and night. Night vision goggle technology could prove highly effective for detection - especially when using filters for use during daylight hours.
Why are such limited crew numbers provided for mechanical and manual removal? The number of teams can be easily multiplied by two or four to decrease time to threat relief.
Low -footprint-pressure vehicles are used in the arctic, in deserts with cryptogamic soils and crusts, and in swamps and other delicate ecosystems where the damage of a single footstep could last for 50 years. A well known example is a hovercraft. Less well known are lightweight balloon tire vehicles. One-of-a-kind vehicles, or perhaps more accurately platforms, are used in tree top jungle canopy studies. These platforms use inflatable beams to spread their working payload weight over huge areas.
These could be used at Fort Ord to suspend and move detection equipment across the landscape.
TIME LINE FOR EACH ALTERNATIVE NEEDED
Without accepting the faulty purpose and level of analysis, I have these concerns about the time frames.
Because it is exceedingly unclear what tasks or events would occur during any of the alternatives a graphical timeline is needed for each to compare the alternatives. The narrative thrown into the appendix is not helpful.
When does each start? Since intentional wildland burning can only be done during a 6 month window, perhaps other alternatives such as mechanical or manual can be started sooner and completed sooner even though the time in the field is longer. This should show the time to completion of relieving the threat by the active fencing alternative is by far the fastest.
When does each finish? When is the threat relieved (if that is indeed the purpose)?
With the Simultaneous Detection, Mechanical Vegetation Clearance and Ordnance Removal Alternative the threat is relieved as swatches similar to how a lawnmower treats a yard.
Several times the document asserts, without evidence, that cutting manually or mechanically "cannot be applied selectively" (e.g. A4). Any gardener or landscaper will laugh out loud at such an assertion as that is exactly what they do large scale every day.
Please remove these assertions and reanalyze the conclusions.
The Army Corp of Engineers 1997 Habitat Management Plan and this document both, without evidence, assume that natural (lightning caused) fires occur and burn everything on the order of every 30 to 50 years. This flies in the face of abundant evidence that lightning caused fires are rare - probably occurs less often than every 500 years, and potentially burn the entire base no more often than tens of thousands of years, if ever.
"The lowest incidence of lightning fires in California, by far, in the 1970's decade occurred in the Santa Cruz/San Mateo, Sonoma and Monterey/San Benito County Ranger units according to a U.S. Forest Service analysis of some 76,000 fires throughout California (Keeley)." (Dilworth, citing Jon Keeley's 1982 work)
Backing this up are multiple lines of research including Burton L. Gordon's book which states "Having searched written records covering some 125 years (and consulted local park rangers and city fire departments), the writer concludes that it is impossible to extrapolate a credible natural burn cycle of less than 500 years for the coastal half of the Monterey Bay area-and for the inland half, less than 300 years."
Lightning strikes and rainfall generally increase as an air mass lifts to traverse land rising from the sea. Similarly, lightning strikes decrease in number as land forms lower to sea level (Gordon). Keeley's USFS study of 100,000 fires in California in the 1970's under USFS jurisdiction found less than one percent of lightning caused fires occurred below 250 meters (800 feet) in elevation. This must be tempered by the fact that Forest Service has relatively fewer lands at or near sea level. Unfortunately, CDF data covering more lower elevation lands did not include fire altitudes. As far as I can determine no part of the proposed burn areas exceeds 830 feet above sea level. Thus, lightning strikes causing natural fires at this location are highly likely exceedingly rare.
Fish & Wildlife Service stated "Burning...may have a positive effect because the maritime chaparral community that supports sand gilia and Monterey spineflower is adapted to occasional natural fires." FWS Mar 1999 p 14
This is a wildly unsupported and highly misleading conclusion.
Having completed two Freedom of Information Act requests on the Ventura office on exactly this information I can state there is no evidence in this record or at Fish & Wildlife Service (unless they withheld information which would be a violation of law) that any ESA listed plant species at Fort Ord needs fire for regeneration. The evidence that does exist, solidly refutes the FWS conclusion.
Further, consider the headline from a 30-Nov-2001press release announcing the December 2001 Conservation Biology issue focusing five articles on prescribed burning.
"Prescribed Burning: Do we really know what we're doing?"
"New research shows that prescribed burning may be used too widely. The theory is that by reducing the unnatural fuel buildup caused by decades of fire suppression, prescribed burning reduces the risk of catastrophic fires. But, this theory doesn't fit all ecosystems and prescribed burning can sometimes cause more harm than good."
"Although prescription burning has proven to be a viable means of reducing fire hazard in some forest types, it is not appropriate for the boreal forests of Canada and the chaparral shrublands of southern California," says Jon Keeley of the USGS in Sequoia-Kings Canyon National Parks, Three Rivers, California. Keeley and other researchers explore fire management in five papers in the December issue of Conservation Biology.
This document fails even when it focuses on it improper but declared task. Since the prescribed burning alternative is clearly the focus of this document some questions of that preference need to be answered.
How long after the burn is started is it over so ordinance crews may begin? 4 hours, 4 days, 6 days, 6 months? The document is not clear.
How long after the burn ends will the ordnance detection and removal crews fully step onto the field? Hours, Days, months, years - never? This is never discussed, is not obvious, yet is critical to determining a preferable alternative.
What methods do the ordnance detection and removal crews use? Are they walking? (p 51)
Are they in armored vehicles? What detection equipment are they using? Is the equipment for detecting ordnance aboveground in brush different than equipment for ground and subsurface detection? These are never discussed, the answers are not apparent, yet are critical to determining a preferable alternative.
Burning will leave impenetrable brush skeletons! (p A18)
The document admits that all branches 2 inches in diameter and larger will remain after the burning and mechanical brush removal will be needed (some additional cutting may be necessary...). Worse, under ideal conditions to control burns and air pollution, cool, moist conditions, even less "very little woody material would be consumed."
This again needs an answer to subsequent ordinance detection - How will it be conducted? By hand mine detectors, visually as the analysis implies, or some other way?
How can burning be "the most effective method for reducing vegetation to within six inches of ground surface to allow for safe operation of OE detection equipment..."(p D2) when burning will leave impenetrable brush skeletons?
In essence, this section admits that not only is mechanical clearing useable on all IA areas, but that mechanical clearing is the preferable last resort!
The Army acknowledges that "a second unnatural burn that took place before mature chaparral species could produce seeds could destroy the habitat permanently." (p D2)
If burning is so natural, and so frequent, how has the ecosystem survived this principle?
Burning will cause Direct, Non-Incidental, deaths and "take" of legally protected and some unprotected animal and plant species and their habitats violating ESA Section 9 and other laws.
The US-Fish & Wildlife Service (FWS) March 1999 Biological & Conference Opinion (BO) (which replaces all earlier versions) does not authorize, quantify or even address Incidental Take of most ESA protected animal species killed by, or their habitats destroyed by, intentional fire.
The US-Fish & Wildlife Service (FWS) March 1999 Biological & Conference Opinion (BO) (which replaces all earlier versions) does not authorize, quantify or even address Incidental Take of any protected plant species killed by, or their habitats destroyed by, intentional fire. "The process of transferring lands will not directly result in take; therefore, none has been authorized." (BO p 19)
In an unusual oversight, the Fish & Wildlife Service fails to distinguish between take of individuals and take which diminishes a population. This results in a failure to recognize and prevent deaths and take of individuals of listed species.
For example, Vernal Pool Fairy Shrimp (Branchinecta lynchi) is a Federally listed Threatened species. Its range includes the vernal pools of Monterey County and Fort Ord.
Fish & Wildlife stated "No ponds are expected to be disturbed." FWS Mar 1999 p 14 yet, fire could not only directly kill many individual Vernal Pool Fairy Shrimp, it will destroy its habitat, its nesting and sleeping areas, its food and could permanently destroy its habitat preventing its recovery. These direct ESA take impacts are wholly disregarded in all documents associated with the proposed burning project.
This species is known to inhabit Former Fort Ord, is on the CITIES Appendix II Threatened list. Many of its subspecies are Federally listed as Endangered (Felis Concolor), and it is Specially Protected in California by law due to a people's initiative (California Department of Fish and Game Code 4800 "The mountain lion is a specially protected mammal. It is unlawful to take, injure, possess, transport, import, or sell any mountain lion, part or product, except as provided.")
Burning could directly kill individuals, will destroy its habitat, its sleeping areas, its food such as deer. These impacts are wholly disregarded in all documents associated with the proposed burning project.
Burning could directly kill many individuals, will destroy its habitat, its nesting and sleeping areas, and its food. These direct ESA take impacts are wholly disregarded in all documents associated with the proposed burning project.
"The badger is an uncommon, permanent resident found throughout most of [California], except in the northwest area. It is most abundant in drier open stages of most shrub, forest, and herbaceous habitats." Caughley 1978, Analysis of vertebrate populations, p 200 John Wiley & Sons cited by California Department of Fish and Game "Furbearing and Nongame Mammal Trapping" ED, April 6, 2001
The Badger is on the California Department of Fish and Game's list of Species of Special Concern "because they have declined or disappeared in large sections of the state, particularly areas west of the Cascade-Sierra Navada mountain axis and in coastal basins of southern California." Id.
"Using a home range of one badger per square mile (the most conservative number), it is estimated that the low range end of the adult badger population is California is 96,362 badgers." Id.
Burning could directly kill individuals, will destroy its habitat, its nesting and sleeping areas, and its food. These direct ESA take impacts are wholly disregarded in all documents associated with the proposed burning project.
This species is State and Federally listed as Endangered which lives in Monterey County.
Burning could directly kill individuals, will destroy its habitat, its nesting and sleeping areas, and its food. These direct ESA take impacts are wholly disregarded in all documents associated with the proposed burning project.
Burning could directly destroy its habitat, its sleeping, estivating and nesting areas, and its food. These direct ESA take impacts are wholly disregarded in all documents associated with the proposed burning project.
The document seems to imply that Central Maritime Chaparral is an ESA listed plant. It is not because sadly the Endangered Species Act does not recognize ecosystem protection. Maritime chaparral is a plant community dominated by ceanothus and manzanita species; and chapparal, dominated by chamise.
Seaside Bird's Beak, Sand Gilia & Monterey Spineflower are the only officially ESA listed plant species in the proposed burn area.
Having read the included maps I find no evidence in the RI/FS that these three plant species exist on the target areas. What maps specifically identify Seaside Bird's Beak, Sand Gilia & Monterey Spineflower in the three areas to which this document applies?
My analysis of the HMP maps show no occurrence of any of the three officially listed species Seaside Bird's Beak, Sand Gilia & Monterey Spineflower) in area OE-16. This means there is no need to burn this area - even if one accepts the unsupported claim that the area "needs" burning. In addition, Seaside Bird's Beak appears to occur in only small areas of 43-48 and 30A. Sand Gilia does not occur at all in those areas. Even if one advocates prescribed burning this leaves those areas more open for non-burning alternatives.
The document claims fire causes seedlings regeneration of some 3,000 per acre as opposed to natural fire-free conditions at 29 seedlings per acre (e.g. p 44). This is used to argue that fire is not merely good for ecosystem health but mandatory for system health.
This is a extremely loose assertion which needs to be controlled. First two questions need to be answered -
If nine (9) seedlings per acre per year is adequate - then 29 is three times what is needed and 3,000 per acre could be stifling or overcrowding. It should be noted that the document only gives data in two dimensions - seedlings per area. An ecosystem view would look at seedlings per area per time (e.g. seedlings per acre per year) to determine what is necessary over several different natural cycles. You can't force feed an ecosystem.
Are they listed or protected species? If so why aren't they described and quantified? If they are invasive species, they are ecologically harmful and weaken the intentional burning argument.
The RI/FS document zips past environmental impacts as though fired from a gun.
For example - "Smoke would be generated for two days during the burn..." yet there is zero quantification of the smoke or its hazard.
California Health and Safety Code (Section 41,800) forbids burning of hazardous waste.
Yet, the Habitat Management Plan seems to require vegetation burning which is known to ignite massive amounts of the UXO which is legally recognized as hazardous waste.
The only apparent legally available solution is to postpone burning until after the hazardous waste is removed.
Burning UXO as Hazardous Waste can not be called incidental when the Army knows it is "going off like popcorn" as described by firemen at the 1997 burns and since the (unstated) purpose of the project is to disarm the same ordnance that is exploding.
EPA and DTSC both commented on lack of O & M costs.
The document confuses and mixes Capital costs and operations costs. Please have someone familiar with basic accounting fix this and recirculate a properly budgeted document.
The inclusion of an Evacuation Plan should alert any normal person to the breathtakingly irresponsible tone of this project. Some $90 thousand dollars is budgeted - yet no actual plan is available.
I have evaluated hundreds of environmental analysis documents. On a scale of 0 to 10 where zero (0) is fully objective and ten (10) is fully biased I would rate the RI/FS at about a seven (7) on the Bias Scale which anyone should find unacceptable. (A five means enough information is available to begin an independent evaluation of alternatives.) I could give many bias examples but here are just two.
This first, supportive of the preferred burning action, claims certainty using "would" with little to no supporting evidence.
The second, which could undermine the preferred burning action, is dismissed as only faintly possible with "may" in the face of overwhelming evidence to the contrary.
Functional equivalency of an EIS is only granted when EPA "engages in regulatory activities designed to protect the environment." (Bass & Herson) Functional equivalency has never been granted by courts for CERCLA activities. Id.
This document presents no new information - it only summarizes other documents, primarily the RI/FS.
The ATSDR model uses shockingly poor assumptions making its conclusions probably worthless.
* It assumes smoke will be rising no faster than 10 feet per hour (1/1000 meter per second). Even the lowest temperature candle has smoke column rising at least ten times faster than that. The proposed burn will generate its own significant updraft that will exceed this amount by perhaps 100 fold.
* It assumes a maximum fire diameter of 220 feet (72 meters).The out-of-control 1997 fires had a width many times wider than that.
This document only covers ranges 43 through 48.
Why were the other areas excluded?
I am hard pressed to find a single phrase, paragraph or concept that is not skewed to the Army's pre-determined aim. It is painfully apparent this "analysis" is not objective and was designed to prove the Applicant's pre-determined intent - to burn vegetation period, independent of whether burning will help achieve UXO removal or not; independent of whether there are more effective methods or not; and independent of whether there are less environmentally harmful methods or less expensive methods or not.
I cannot provide a conclusion on whether the preferred alternative or any other, is superior or meets the objectives - because of the document's strong bias and failure and refusal to fairly evaluate feasible and cheaper alternatives.
But the biggest roadblock is the missing purpose. Until the project purpose is defined, it is impossible for me or anyone else anyone to credibly even begin an objective analysis of proposed actions.
Unacceptable Conflict of Interest - Polluter Writing and Approving His Own Cleanup Plan?
This document was placed in the wrong hands. What is the entirely predictable result when a fox is placed in a henhouse? The Army is composed of people who make mistakes just as we all do. The Army is biased and is blind to its own bias - just as we all are. In this case the lines between the responsible party and the Cleanup party have been harmfully blurred and to a large degree forgotten.
USEPA should take immediate control of this process and put have their own experts conduct repairs to the RI/FS if possible, or start over which is probably necessary.
Hearing the echoes of Hamilton Air Force base and the Army's recent lawsuit loss over open detonation at Sierra Army Deport - if USEPA fails to take immediate control, it may well be paving the way for years, if not decades, of litigation and inaction.
David Dilworth, Technical Advisor
Bass, R., Herson, A., Mastering NEPA: A Step by Step Approach, 1993, Solano Press
Gordon, Burton L., 1996. "Monterey Bay Area: Natural History and Cultural Imprints", Boxwood Press, Pacific Grove, California. 375 p.
Keeley, Jon E., 1982. "Distribution of Lightning and Man Caused Wildfires in California", General Technical Report. PSW-58. Berkeley, CA: Pacific SW Forest and Range Experiment Station, USFS, U.S. DoA.
1) SIMPLE SMOKE IS DEADLY
Simple smoke from burning vegetation has gases and particles deadly to normal people - independent of the poison oak smoke and the toxic smoke.
The most common cause of death in a building fire is smoke inhalation.
"60,000 U.S. residents per year die from breathing particulates at or below legally allowed levels" - U.S. EPA, Joel Schwartz 1991; and that EPA study did not include people harmed by breathing the pungent smoke from fires.
Vegetation smoke alone contains a complex mixture of compounds, including the toxic and cancer causing formaldehyde, and the deadly poison carbon monoxide. It also contains polycyclic aromatic hydrocarbons (PAHs), oxygenated hydrocarbons, and compounds of sulfur, nitrogen and halogenated organics.
Vegetation Smoke alone causes and worsens asthma. The Air District Lawsuit against the Army has air pollution experts describing the smoke cloud as a "thick plume of dark smoke" at some 15 miles away from the burn location.
2) CHILDREN AND ELDERLY HAVE HIGHER RISK
Vegetation smoke's harm is even worse on children and elderly. The wealth of evidence behind the EPA's new standard for fine particulates (smoke) demonstrates the serious health consequences for everyone, but especially for sensitive populations, such as children, the elderly, and those with heart and lung disease.
Approximately 6 percent of Monterey County's residents (about 22,000 people) already suffer from asthma according to a report released this week (May 7, 2002) by researchers at UCLA Center for Health Policy.
3) WE'RE BREATHING POISON OAK SMOKE TOO
Burning Fort Ord's vegetation also causes clouds of Poison Oak smoke.
Poison Oak smoke is worse than simple vegetation burning. It can be lethal for some people to get poison oak in their lungs. In California, the poison oak shrub or vine is everywhere except the "inner city," the hotter deserts, and above 4,000 feet elevation.
"Never burn [Poison Oak] plants. The urushiol can spread in the smoke and cause serious lung irritation." - FDA Consumer magazine (September 1996)
"Urushiol can be vaporized when exposed to a fire. If you have a neighbor who is burning poison ivy, the resin will rise with the smoke. If you are downwind when the resin cools off and rains back down to earth, you could receive a coat of urushiol on any uncovered areas resulting in a surprise case of poison ivy." "Under no circumstances should you burn the plant; the smoke is as potent as the plant itself. Inhaling the smoke can produce a systemic reaction, including potentially serious, and life-threatening, lung inflammation." Charles H. Booras, M.D. Listed in "The Best Doctors in America", 2000. Listed in "How to Find the Best Doctors: Florida - 1st Edition".
Caution: Burning poison oak can result in a dangerous smoke that can cause severe symptoms to the eyes, nose, throat and lungs. -UC Davis Health System Website
"Burning poison oak results in an extremely dangerous smoke that can cause severe symptoms to the eyes, nose, throat and lungs. A severe allergic reaction from inhaling the smoke, 'anaphylaxis', is life-threatening. Burning is not recommended as inhaling dust and ash from the smoke can result in poisoning of the lungs that can require hospitalization. Never burn the plants. The urushiol carried in smoke from burning poison ivy is extremely toxic. It can cause lung infections and a rash all over one's body." -The Cooperative Extension Service includes The University of Georgia and Ft. Valley State University, the U.S. Department of Agriculture and counties of the State of Georgia.
Poison Oak's smoke's harm is even harsher on children and elderly.
4) BURNING AMMUNITION SPREADS DEADLY CHEMICAL GASES
"Some explosives, when burned, emit toxic fumes." Former Fort Ord Engineering Evaluation/Cost Analysis pg 4-13
Burning Fort Ord's vegetation ignites uncountable tons of unexploded ammunition, grenades and rockets.
"It was going off like popcorn." said one fireman. Air District Manager Doug Quetin testified "I heard a substantial number of small explosions coming from the area of the [August 25, 1997] fire." That 32 acre fire went out of control because the fire fighting personnel had to be pulled back because "there was too much ordnance detonating." (Air District Report)
Also according to Quetin the "thick plume of dark smoke" extended past Chulalar - some 15 miles from the burn location. Others report tracking the smoke plume south all the way down the Salinas Valley to San Luis Obisbo County - over 100 miles away.
In addition, the Army explodes a pile of recovered unexploded ammunition, grenades and rockets every Wednesday afternoon.
The unexploded ammunition, grenades and rockets are considered hazardous waste because contain they contain materials which are toxic both before and after burning.
Some known toxics burned in the Fort Ord vegetation include the explosives HMX (liver and central nervous system toxicity), and RDX (can cause seizures), Lead, and Cadmium - a radioactive metal.
5) DIOXINS - THE MOST TOXIC CHEMICAL ON EARTH
Whenever materials containing chlorine are burned, dioxins can be produced. The tons of unexploded ammunition, bombs, grenades and rockets do contain products with chlorine (propellants, cases).
"[Dioxins are known] to the public as 'the most toxic chemical on earth.'" There are 75 chemicals in the dioxin family.
A National Academy of Sciences 1993 report "found sufficient evidence to link exposure to dioxin-contaminated herbicides to three cancers: soft-tissue sarcoma, non-Hodgkin's lymphoma, and Hodgkin's disease." "Our Stolen Future", 1999.
As little as one billionth of an ounce can cause chloracne in humans as well as headaches, dizziness, digestive upsets, and pain. Larger doses can cause cancers, liver and kidney problems, stillbirths, birth defects and immune suppression. Scientific American, "Dioxin" Feb. 1986 Tshirley
"Guinea pigs died after swallowing only one-millionth of a gram per kilogram of Body weight." "Our Stolen Future", 1999
Trout eggs or newly hatched fish exposed to doses of as little as 40 parts per trillion begin to show significant mortality. "By one hundred parts per trillion, all the eggs die." "Our Stolen Future", 1999. p 157
6) UNCONTROLLABLE WARFARE AMMUNITION DAMAGE OVER A MILE WIDE
The Army wrote in their 1994 evaluation report (and confirmed at a 2000 RAB hearing) that the "bombs and projectiles with a diameter of 5 inches or more" will explode and send hot fragments some four thousand feet (4,000) and will start secondary fires "with 100 percent certainty!" This means those hot fragments can travel anywhere in a circle of 8000 foot diameter and start a new fire. Former Fort Ord EE/CAp 4-12
It also means that any humans, buildings, trees or wildlife within 4,000 feet could be hit with the burning metal fragments.
The August 25, 1997 event was only intended to burn 32 acres. It went out of control and incinerated 700 acres due to burning ordnance flying over the intended fire boundaries. The fire fighting crew had to be pulled back because "there was too much ordnance detonating." (Air District Report)
7) FLYING SHRAPNEL CAUSES SECONDARY FIRES
White hot, burning shrapnel will fly up to 4000 feet (almost a mile) and start secondary fires with 100 percent certainty. The Army's own EE/CA admits this and when questioned the ARMY reaffirmed this in a public meeting.
"non-fragmenting explosive material will have a debris distance of 1,250 feet, whereas bombs and projectiles with a diameter of 5 inches or more will have a debris distance of 4,000 feet." Former Fort Ord EE/CA pg 4-12
8) CHEAPER ALTERNATES EXIST !!!
As of 2001 the ARMY has now admitted mechanical brush removal costs about half as much as burning brush. $500 per acre for mechanical removal vs. $900 per acre to burn the vegetation.
When the ARMY made their original decision to burn they said that mechanical removal would cost five thousand dollars ($5,000) per acre and burning would only cost one hundred dollars ($100) per acre. The dollars have significantly changed, and now have changed which method is the cheaper. The Army's decision has not yet changed.
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This Page Last Updated June 25, 2003