[CPEO-MEF] Request For Full EIS on Vieques

[CPEO Moderator <cpeo@cpeo.org>]

[CPEO was asked by the organization below to post the following letter that
was sent to EPA Region II.  The letter requests that EPA require the Navy
to do a full  Environmental Impact Statement on Navy land located on  the
western portion of Vieques that is in the process of being transfered.
--Aimee Houghton]


Union for the Protection of the Environment of Vieques
PO Box 1504
Vieques, PR 00765
787-741-0584


April 2, 2000


Ms. Jeanne Fox
Administrative Director
U.S. Environmental Protection Agency
Region 2
290 Broadway , 26th Floor
New York, NY 10007-1866

Dear Ms. Fox,

By means of this letter we wish to inform you of our certainty that the
>undertaking of an EIS is required for the Department of the Navy, NAF
>Vieques property to be transferred to the Government of Puerto Rico. We
are convinced that essentially important, site-specific characterization,
assessment, and survey of this military facility
can only be effectively provided by means of an Environmental Impact
Statement. Accurate risk evaluations that consider the impact of
contamination and potential health effects are vital for the proper
transfer of these lands.

This facility has been active since 1941 operating as a division of the
Naval Station Roosevelt Roads Weapons Department. Its operation has
involved maintenance of over a hundred ammunition storage depots
containing, explosives, missiles, torpedoes and other ordinance. There are
a munitions loading and unloading pier and causeway, as well as 
underground storage tanks located there. A RCRA OB/OD EOD range, in use for
40 years, for the disposal of NAF, AFWTF, and Marine Force operations
UXO's, waste and unserviceable military materials,
as well as testing and development of military weapons is located at NAF.
As of yet, the exact boundaries of this EOD range have not been
described. The chemical component of the materials stored and disposed of
is not known. Extensive areas of NAF were used for decades, by the Marine
Forces, as maneuver areas and landing beaches for training exercises. Three
CERCLA identified  disposal landfills are located there also.

As we have discussed with EPA region II, over the past year we have been
reviewing the long outdated EIS 1979 and the Administrative Record File
(ARF) documents. Assistance with this review has been provided by Center
for Public Environmental Oversight (CPEO), Director Lenny Siegel, and other
technical assistance has been provided by
Northeastern Hazardous Substance Research Center, TOSC Program of New
Jersey Institute of Technology and  Metropolitan University of Puerto Rico.
We insist that an EIS is required and that the EIS provide for commentary
from the regulatory agencies and the public in its development. I am also
sending this request to Captain James Starke, Jr., Property Manager,
Vieques. I look forward to your response.

Sincerely,


Stacie Notine
Union for the Protection of the Environment of
Vieques (UPMAV)
Vieques Conservation and Historical Trust (VCHT)
El Comité Pro Rescate y Desarrollo de Vieques
(CPRDV)
Coordinadora de Justicia y Paz para Vieques



CC: Daniel Pagán, Secretary, Department of Natural Resources, P.R.


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