Please Post

[Laura Hunter <LauraH@environmentalhealth.org>]

SAN DIEGO NUCLEAR HOME PORTING UPDATE

August 1999

Dear Friends:

The Final Environmental Impact Statement (FEIS) is out. There is a limited
time to continue to register your opposition to this document and this
project. There are 3 decision points coming up soon. Since the Navy has
stated that they will not revise the FEIS to reflect public comment it is
important that you request that additional actions and information be
included in the Record of Decision. This is our last opportunity to comment
within the federal process before the project moves forward. The FEIS is
inadequate due to its: 

failure to release information around the area of impact and consequences
of an accident,

failure to include appropriate and site specific emergency response and
evacuation plans,

failure to take actions that would improve safety for neighbors such as a
warning system,

failure to properly evaluate air toxics and air pollution issues.

Please write letters addressed to the following agencies by the these dates:

1. Comments due to the Navy by September 7, 1999 on the adequacy of the
FEIS in disclosing environmental impacts from the project in accordance
with National Environmental Policy Act (NEPA). Write to:

    Mr. Bob Hexom 

    Southwest Divison (Code 4PLRBH) 

    Naval Facilities Engineering Command 

    1220 Pacific Highway 

    San Diego, CA 92132-5190 

    (888) 428-6440, FX (619) 532-1096

    email:CVN-Homeporting@efdsw.navfac.navy.mil

    cc. Copies to Secretary of the Navy Richard Danzig, your elected officials

2. Comments due by September 30, 1999 on the adequacy of the FEIS to
function as an Environmental Impact Report under the state Calif.
Environmental Quality Act (CEQA). The Regional Board must certify that the
FEIS discloses and mitigates impacts to the environment and human health
and safety resulting from this project.

Comments should be sent to:

Mr. Dat Quach/ Mr. John Robertus

Regional Water Quality Control Board

9771 Clairmont Mesa Blvd., Suite A

San Diego, CA 92124-1324

(619) 467-2978 FX (619) 571-6972

email:quacd@rb9.swrcb.ca.gov

3. Comments due in the next couple months (hearing date unknown) on
concerns about the project and its impact on coastal resources as per the
Coastal Zone Management Act. The Commission must find that this project is
consistent with the Coastal Act.

Send to: Mr. Mark Delaplaine

California Coastal Commission

45 Fremont Street, Suite 2000

San Francisco, CA 94105

415-904-5200

Environmental Health Coalition will be raising the following issues and has
contracted with technical experts to review the FEIS. Their analyses will
be part of our comment letter.

1. FEIS Fails to Include Information on Area of Impact And Consequences to
Neighboring Communities from a Nuclear Release from a Carrier Reactor

The FEIS fails to disclose the area of impact in the event of a nuclear
accident on a carrier. This is a fatal flaw with this document given that
it is supposed to be a disclosure document about impacts to human health,
safety, and the environment as a result of this project. 

EHC will submit for the record an analysis conducted by a technical expert
that shows that a moderate release of radiation could be carried 4 miles
downwind in 15 minutes. The day of the hypothetical model, (7/28/98) this
covered Lindbergh Field and neighboring residences, due to wind direction.
The public has a right to know the implications and consequences of such a
release.

The Navy responses to community concerns and data in this area are grossly
insufficient. We formally request that this information be included in the
Record of Decision and the CEQA determination.



2. FEIS Fails to Include Appropriate and Site Specific Emergency Response
Planning in the Event of a Release of Radiation

Although the Navy has emergency plans for naval personnel, the Navy has
failed to include, adopt and/or release the emergency response plans for
the community in the event of a serious nuclear accident at North Island.
This is non-responsive and seriously undermines the adequacy of the
document. Many communities could be affected, including those as far south
as Tijuana. The community has asked repeatedly for this information and it
is a significant failing that this document does not disclose this
information. Routes of evacuation, distribution of potassium iodide,
warning systems and protocol, impacts on neighboring communities, and other
aspects should be included in the emergency plans adopted and released to
the public.

We formally request that this information be included in the Record of
Decision and as a mitigation in the CEQA determination.

3. FEIS Fails to Include Mitigations Necessary to Protect Public Health in
the Event of an Emergency Such as Stores of Potassium Iodide (KI) and
Perimeter Monitoring.

The Navy stores KI for personnel on the ship. It should be, and has been
requested many times by the community, likewise stored for the neighbors of
the ship. The Navy’s refusal to care for the well-being of its
neighbors is a significant moral failing of those implementing this project
and a legal failing of the document.

We formally request that this information be included in the Record of
Decision and in the CEQA determination.

FEIS Fails to Adequately Analyze Air Toxics. 

The biggest problem is that the Health Risk Assessment (HRA) contains no
analysis of cumulative toxics impacts. A cumulative impact analysis should
include the existing inventory plus cleanup emissions plus construction
activities plus increased waste facility emissions plus proposed operations
over time. Instead, the HRA only lists the existing operations inventory
and the proposed construction emissions.

No analysis with new risk information for diesel particulates is included.
The state is developing risk estimates. While not yet formally adopted, the
Navy should have used these risk estimates. This analysis would likely
increase the risk estimates considerably. It is also important to note that
in its most recent inspection by the local and state air districts, NASNI
was cited for four violations of air pollution laws.

We formally request that this information be included in the Record of
Decision and the CEQA determination.

Call us for more information or to ask questions. Environmental Health
Coalition (EHC) 1717 Kettner, Suite 100, San Diego, CA 92101

(619) 235-0281; FX (619) 232-3670