WHY HARDWOOD RANGE EXPANSION IS STUPID!

["Laura Olah" <olah@speagle.com>]

Aimee, Please post. THANKS! Laura

CSWAB Comment on the draft EIS for the Proposed Expansion of the 
Hardwood Bombing Range in Northern Wisconsin: A proposal to withdraw 
6,000 acres of County Forest land and add it to the existing Hardwood 
Bombing Range in Juneau County. 

 WHY THE HARDWOOD RANGE EXPANSION IS STUPID!

"Construction and maintenance and bombing could possibly have the 
following effect on wetlands: altering groundwater discharge/recharge 
characteristics, reduced potential for filtering and treatment for water 
quality protection, reduced potential for attenuation and storage of 
stream and floodwater, loss of floral diversity, and loss of fishery and 
wildlife habitat."

 Source: Draft Environmental Impact Statement Addressing 
 the Hardwood Range Expansion and Associated Airspace Action, 
 Wisconsin Air National Guard, August 1997.

VIABLE ENVIRONMENTALLY AND ECONOMICALLY SUPERIOR ALTERNATIVES WERE 
ELIMINATED FROM CONSIDERATION EARLY IN THE EIS PROCESS AND NOT CARRIED 
FORWARD FOR DETAILED STUDY. 

Utilizing electronic scoring of simulated weapons delivery and 
increasing flight simulator training is actively and successfully used 
by the U.S. Air Force, contrary to statements in the draft EIS. These 
technologies are currently able to meet the "accuracy parameters" 
required by the USAF, contrary to the draft EIS.

Just last year, Kelly Air Force Base in San Antonio, Texas, installed a 
Unit Training Device (UTD) flight simulator. The UTD is one of 65 such 
units currently utilized by the USAF at bases across the nation. 
According to the UTD program manager for the Air Force, a "quality, 
full-mission trainer used to cost as much as the F-16 it simulated; now 
we are purchasing trainers for less than $1 million each and 
experiencing a 95 percent cost reduction in comparison to traditional 
mission simulators."

The UTD simulator is used by the 182nd Fighter Squadron of the Texas Air 
National Guard's 149th Fighter Wing to train its F-16 pilots -- the same 
aircraft used at the Hardwood Range -- in emergency procedures, 
avionics, air-to-air and air-to-ground combat, and tactical fighting in 
a dense threat environment. According to the facility's press release, 
the Guard pilots are also able to practice acquiring and identifying 
targets and accurately delivering weapons in adverse weather conditions 
at day or night. 

Unlike previous F-16 simulators, which have had to be housed in 
gymnasium-sized high bays, UTD trainers can be operated within a 
standard squadron office environment. While operating a traditional F-16 
weapon system trainer in a specially designed facility has cost about 
$50,000 a month, today individual UTD simulators can be operated for a 
fraction of the amount. The base reports these cost savings are being 
driven by a leap in computer technology that also has enabled UTD 
simulators to maintain a high degree of flight training realism. 

The UTD program, the report concludes, began to take shape when the Air 
National Guard identified the need for a unit-level pilot trainer. At 
the time its units did not have simulators, which required aircrews to 
travel to distant Air Force bases where F-16 simulators were located. 

THE POTENTIAL ENVIRONMENTAL, ECOLOGICAL AND HEALTH IMPACTS OF USING 
CHAFF ON PUBLIC, PRIVATE, AND TRIBAL LANDS WERE OMITTED FROM THE EIS.

Chaff is an airborne radar-detection countermeasure consisting of 
extremely fine fibers of aluminum coated fiberglass. A typical burst 
Chaff bundle contains approximately 2.1 million human hair size 
fiberglass strands. After its dispersal and use in military training 
exercises it becomes a waste material that falls to the ground.
The use of chaff at Fallon Naval Air Station, Nellis Air Force Base, 
Mountain Home Air Force Base, and at military installations across the 
nation is a growing concern for rural residents. According to the Rural 
Alliance for Military Accountability (RAMA), rural residents and the 
Bureau of Land Management officials are finding clumps of chaff on 
public and private lands throughout central Nevada.

The Nevada Division of Environmental Protection noted two primary 
concerns: "The first concern is from inhalable particulate below PM10 
which may occur from the decomposition and resuspension of fiber 
particulate by mechanical means. The Division's second concern deals 
with the physical deposition of what could be considered solid waste on 
public and private lands in the State of Nevada. There is very little 
information on the amounts of chaff currently deposited and how these 
fibers decompose in the environment." The Nevada Division of 
Environmental Protection concluded, "The Division does not feel that 
adequate studies have been done to assure that there are no 
environmental risks posed by the fibers."

The mechanical breakdown of these silicate fibers can be defined as 
asbestos-like, tiny filaments, and could, if inhaled or ingested, lodge 
in body tissue. The health risks associated with inhalation or 
ingestion have never been independently researched. According to 
Department of Defense studies, "The minimum dimension of a chaff fiber 
is 0.0003 inches, which converts to 7.6 micrometers. This is less than 
the 10 micrometer maximum size cutoff in EPA's standard for inhalable 
particulate." Moreover, the National Institute for Occupational Safety 
and Health (NIOSH) considers crystalline silica (as a respirable dust) 
"a potential human carcinogen."

The Air Force report Identifying and Evaluating the Effects of Chaff 
from Military Aircraft documented the lack of information on potential 
health risks, saying: "There is no documentation of human exposure 
studies to chaff." The report continued by noting: "Detailed 
authoritative data concerning the impacts of chaff on land is 
lacking...The long-term effects of chaff are unknown."

The Army in 1992 concluded: "The potential of weathering fibers to 
respirable geometries in the environment and the potential exposure from 
resuspension of these fibers need to be determined to evaluate long-term 
risk and chronic exposure scenarios." The report continued: "Glass and 
carbon fibers and, likely iron fibers deposited on soils are susceptible 
to wind resuspension until immobilization occurs. However, even those 
fibers immobilized on soil surfaces can be resuspended by physical 
forces such as foot and/or vehicular traffic. Thus, there is a 
persistent risk of fiber inhalation and mitigation efforts will likely 
be required for areas containing high fiber concentrations. . ."

THE PRESENCE OF EXTENSIVE WETLANDS, TOGETHER WITH A FACILITY-WIDE 
SHALLOW WATER TABLE, ELIMINATES THE HARDWOOD SITE AS A VIABLE TRAINING 
AREA.

The draft EIS clearly states: "Extensive wetlands are located within the 
Hardwood Range, proposed expansion area, and Restricted Area R-6904A." 
(Page 3-38). Moreover, the EIS characterizes ordnance impact as 
"significant surface disturbance." And lastly, the EIS says 
construction and maintenance and bombing could effect wetlands by 
"altering groundwater discharge/recharge characteristics, reduced 
potential for filtering and treatment for water quality protection, 
reduced potential for attenuation and storage of storm and floodwater, 
loss of floral diversity, and loss of fishery and wildlife habitat."
One of the most inane statements in the entire draft EIS is on page 
4-27: "None of the activities associated with the Proposed Action would 
have an impact on groundwater resources underlying the expanded Hardwood 
Range." As groundwater is hydrologically connected to adjacent 
wetlands, this would seem impossible. 

The Watershed Protection Approach, as recognized by the USEPA, is "a 
management approach for more effectively protecting and restoring 
aquatic ecosystems and protecting human health. The EPA Office of Water 
is using this approach to focus on hydrologically defined resource 
areas, watersheds, and aquifers. The EWPA recognizes that water quality 
management must embrace human and ecosystem health and that managing for 
one without considering the other can be detrimental to both." (Emphasis 
added.) (Source: Watershed Protection: A Statewide Approach, EPA Office 
of Wetlands, Oceans and Watersheds, USEPA, August, 1995.) 

EPA Administration also supports this approach saying: "The EPA's 
overall goal is to prevent adverse effect to human health and the 
environment and protect the nation's groundwater resources in accord 
with federal laws. It will counter adverse effects (significant and 
reasonable risks) to the resource and the pollution in the near and 
long-term. Prevention is emphasized because groundwater cleanup is 
costly and difficult. Safe drinking water is the primary goal, along 
with the protection of interconnected surface water resources and 
ecosystems." (Source: Protecting the Nation's Groundwater: EPA strategy 
for the 1990s. July 1991. Final Report of the EPA Ground Water Task 
Force.)

THE MUNITIONS DISPOSAL SITE SHOULD BE CLOSED AND REMEDIATED AS SOON AS 
POSSIBLE. 

The draft EIS states no live ordnance is utilized at Hardwood, 
subsequently there is no apparent need for keeping this site open. The 
draft EIS reports: "One Defense Installation Restoration Project is 
located on the Hardwood Range. This site has been used since 1976 for 
annual burning and burial of spent munitions. A small plume of 
contaminated groundwater has been identified in that area...No monitoring 
is currently being performed at the site."

THE CHARACTERIZATION OF THE COMBUSTION PRODUCTS IN THE EIS IS BASED ON 
OBSOLETE, INCOMPLETE INFORMATION.

In an attempt to measure and identify emissions from the burning of 
propellants, Sandia National Lab recently conducted the so-called "Bang 
Box" tests. According to this report, emission factors from these tests 
included toxic and carcinogenic substances such as carbon monoxide, 
methane, benzene, 2,4 dinitrotoluene, 2,6 dinitrotoluene, and nitrogen 
oxides. Potential toxic emissions include lead, cadmium, and chromium 
-- standard constituents of conventional propellants.

According to the Overview of the Health Effects of Selected Munitions 
Chemicals published by the USEPA and the Department of the Army. "DNT 
is classified B2 (probable human carcinogen) and thus a Lifetime HA is 
not recommended. The cancer potency is associated with hepatocellular 
and mammary gland carcinogenic activity in rats after 2,4-DNT treatment. 
 2,4-DNT also may be a promoter. There is some evidence which suggests 
that 2,6-DNT has both initiation and promotion activity and, therefore, 
may be a complete carcinogen." 

The Army's Health Risk Assessment for the Open Burn Facility at Badger 
Army Ammunition Plant describes the incremental carcinogenic risk for 
exposure to DNT's from open burning of propellants. Of considerable 
concern are the multiple potential exposure pathways including 
inhalation, soil ingestion, dermal contact, and food ingestion and the 
increased and additive risks associated with each of these exposure 
pathways. Non-carcinogenic health risk are increased as well; toxic 
metals-contaminated ash, disbursed by open burning, exposes soldiers and 
nearby residents through inhalation, soil ingestion, dermal contact, and 
food ingestion. Other pollutants including NOx, CO, VOC's and TSP 
increase and compound risks to human health. 

In addition to fire hazards, burning red phosphorus emits toxic fumes of 
oxides of phosphorus and can react with reducing materials.

THE CHARACTERIZATION OF POTENTIAL ECOLOGICAL, ENVIRONMENTAL AND HUMAN 
HEALTH IMPACTS OF TITANIUM TETRACHLORIDE IN THE DRAFT EIS IS INCOMPLETE, 
AND THEREFORE INCORRECT.

Titanium Tetrachloride is a colorless or light yellow, fuming liquid 
with a pungent odor. Signal charges used in training ordnance at 
Hardwood reportedly each contain 17 cubic centimeters of titanium 
tetrachloride. The "smoke" described in the draft EIS is actually 
poisonous gases, according to the US Department of Health and Human 
Services (USDHHS) Toxicological Profiles. In a fire, poisonous 
emissions include titanium oxides and hydrochloric acid.

Titanium Tetrachloride is classified by the Department of Transportation 
and the US Environmental Protection Agency as a Hazardous Substance, and 
is on the Special Health Hazard Substance List because it is corrosive.

According to the USDHHS, breathing Titanium Tetrachloride can irritate 
the nose, throat and air passages, causing cough and phlegm. Repeated 
exposure can cause chronic bronchitis and may cause emphysema. Higher 
exposures can cause fluid in the lungs, a medical emergency, and even 
death. Skin contact can cause burns.

The USDHHS reports acute (short-term) ecological effects may include 
"the death of animals, birds, or fish, and death or low growth rate in 
plants. Acute effects are seen two to four days after animals or plants 
come in contact with a toxic chemical substance. Insufficient data are 
available to evaluate or predict the acute, short-term effects of 
Titanium Tetrachloride to aquatic life, plants, birds, or land animals."
Chronic toxic ecological effects may include shortened lifespan, 
reproductive problems, lower fertility, and changes in appearance or 
behavior. Chronic effects can be seen long after first exposure(s) to a 
toxic chemical. Insufficient data are available to evaluate or predict 
the chronic, long-term effects of Titanium Tetrachloride to aquatic 
life, plants, birds, or land animals. 

Laura Olah, Executive Director 
Citizens for Safe Water Around Badger
E12629 Weigand's Bay South
Merrimac, Wisconsin 53561
olah@speagle.com
Phone (608)643-3124 Fax (608)643-0005
Website http://www.speagle.com/cswab