[CPEO-MEF] Ballistic Missile Defense System and Perchlorate

[Lenny Siegel <lsiegel@cpeo.org>]

Perchlorate and the Proposed Ballistic Missile Defense System:

Comments on the Draft Programmatic Environmental Impact Statement

Lenny Siegel
Center for Public Environmental Oversight
October, 2004



Executive Summary

The Programmatic Environmental Impact Statement (PEIS) for the Ballistic 
Missile Defense System (BMDS) not only does an inadequate job of 
addressing the environmental impact of solid rocket propellant 
associated with this program, but it seems to ignore the purpose of the 
National Environmental Policy Act (NEPA). That is, rather than consider 
how to minimize negative environmental impacts in the design of a 
program, through "cradle to grave analysis," it uses the environmental 
document to justify decisions that have already been made.

Furthermore, the PEIS lacks a genuine "No Action Alternative," even 
though NEPA requires that such an alternative serve a baseline against 
which to compare the environmental impacts of the other alternatives. In 
particular, a No Action Alternative that posits little or no use of 
rocket propellant is essential if the program's proponents are to 
minimize releases of pollutants - particularly solid rocket propellant 
and its byproducts - into our nation's water supplies, air, or the upper 
atmosphere, either by selecting a program alternative or agreeing to 
binding mitigation measures.

Solid rocket propellant that contains ammonium perchlorate as an 
oxidizer is designed to generate large quantities of hydrogen chloride, 
which reacts with moisture in the atmosphere to create hydrochloric acid 
- that is, acid precipitation. The PEIS should consider how the missile 
defense program might develop and test alternate launch technologies 
that are not so environmentally destructive.

When rockets are launched into the upper atmosphere, they directly 
deliver hydrogen chloride to the ozone layer, exposing human, other 
animals, and other biota to the harmful, persistent effects of 
ultraviolet-B radiation (UVB). Rocket launches are among the largest 
causes of ozone depletion, and the persistence of such substances from 
other sources is no excuse for additional pollution. The BMDS program 
should at the very least evaluate the mitigation of such seriously 
harmful environmental consequences through the development and 
deployment of alternative solid rocket propellants.

Perchlorate, primarily from the manufacturing, testing, aborted 
launches, maintenance, and decommissioning of solid rocket motors, is 
polluting the drinking water of more than twenty million people and may 
be endangering natural ecosystems from Cape Canaveral to the Marshall 
Islands. The PEIS understates the risks of exposure, and it fails to 
provide data on the quantities of solid rocket propellant likely to be 
produced, used, released, and disposed by the BMDS. The PEIS should 
consider the environmental consequences of various disposal strategies 
so the BMDS program can develop the technology or capacity to address 
its waste or consider the use of alternative launch technologies or 
strategies to minimize either the waste or the negative environmental 
impacts.

Conclusion

To ensure maximum environmental protection and reduce known, widespread 
human health risks from the use and disposal of solid rocket propellant, 
the Programmatic Environmental Impact Systems for the Ballistic Missile 
Defense System should compare the proposed alternatives against a 
genuine No Action Alternative. At a minimum it should::

1. Provide more detailed estimates of perchlorate waste likely to be 
generated by system development, testing, deployment, maintenance, and 
decommissioning and acknowledge emerging regulatory standards for 
perchlorate exposure.

2. Consider in detail the management practices - launch protocols, 
treatment technologies, etc. - necessary to mitigate the significant 
environmental impacts, including increased depletion of the 
stratospheric ozone layer and the likely release of perchlorate into 
groundwater, surface water, and soil.

3. Evaluate alternative launch technologies not based upon ammonium 
perchlorate.

Based upon such additional environment review, which I believe is 
mandated by any fair reading of the National Environmental Policy Act 
and its implementing regulations, Program Managers should use the 
information generated to help evaluate all alternatives and to mandate 
actions to minimize or mitigate the serious environmental consequences 
associated with such a large and continuing use of solid rocket 
propellant. Such steps are necessary to protect the American people, the 
ostensible purpose of the Ballistic Missile Defense System.



To download Lenny Siegel's complete comments as a Microsoft Word 
document, go to
http://cpeo.org/pubs/BMDS-PEIS.doc


--
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
http://www.cpeo.org


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