To the Editor:
I have just finished reading the March 1993 issue of Environment Hawai`i. You have made an excellent summary of STARS and related SDI activity on Kaua`i. I continue to hope that, based on efforts like yours, people will realize what dangerous and wasteful nonsense these SDI “experiments” are.
I have one correction and a few minor comments. According to the CDX environmental assessment, CDX stands for Countermeasures Demonstration Experiment.
In replies to some of my comments on the STARS environmental impact statement, the Strategic Defense Initiative Organization has stated that EDX (Exoatmospheric Demonstration Experiment) is no longer programmed for Kaua`i and that the MSX III test (called the fuel vent experiment in the STARS EIS) has been canceled.
A staffer to the Senate Defense Appropriations Committee told me that EDX was not funded at the moment but cautioned that SDIO has shifted funds between projects in the past and could do so again.
Finally, I am enclosing copies of letters I’ve written to try to draw the attention of the Hawai`i Department of Health to the lead in the exhaust of the rockets used for CDX and Vandal.
Michael Jones
Physics Department
University of Hawai`i – Manoa
Enclosed were copies of letters to Bruce Anderson, deputy director of the Department of Health, and to state Senator Mike McCartney. On March 5, 1993, Bruce Anderson replied. What follows are excerpts from those letters.
From Letter to Bruce Anderson, January 29, 1993:
You are probably aware that the hydrogen chloride concentrations that will result from STARS launches is one of the contentious environmental issues. In a December 9, 1992, letter to me from the SDIO, it is conceded that the Hawai`i HCl guideline of 0.025 parts per million will be exceeded beyond the ground hazard area. The letter further states, “Using these guidelines and the health-based standards referred to in the draft environmental impact statement, consultation with the state of Hawai`i resulted in a conclusion there would be no significant impact since the health-based limits would not be exceeded.” Does your office or any other branch of the Department of Health have documents that report on this consultation?
My second question concerns the Countermeasures Demonstration Experiment (CDX), which was launched on May 24, 1992. According to the finding of no significant impact (dated May 22, 1992) which accompanies the CDX environmental assessment, the exhaust from the Terrier rocket to be used includes 9.2 kilograms (20.25 pounds) of lead, which the FONSI states to be “a reportable amount under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. Such a release would be reported to the National Response Center, the [Department of Energy’s] Albuquerque Office, and to Hawai`i and local response centers.” Was your office or any other branch of the Department of Health consulted about this lead release before the launch? Was the release reported after the launch?
From Letter to Senator McCartney, February 26, 1993:
I believe there are important aspects of the STARS and Vandal rocket launch programs that have not been given adequate attention by the state of Hawai`i.
I have never received a reply from any state agency to my letter of September 22, 1992, which pointed out that a document in the STARS administrative record indicates that the state guideline for hydrogen chloride exposure will be exceeded for STARS launches. On January 29, I sent the enclosed letter to Bruce Anderson to ask about documents related to any consultation on this matter. After writing Dr. Anderson, I learned that the Talos booster used in Vandal launches emits about 45 pounds of lead in its exhaust. I called Anderson’s office in the first week of February and was referred to Leslie Au [in the Office of Hazard Evaluation and Emergency Response]. I suggested to him that someone in the Clean Air Branch should look at the impacts of 15 such launches per year before the state signed the Memorandum of Agreement covering STARS and Vandal. Since then, I have made several calls to Mr. Au; he has not returned them.
There seems also to be some confusion about the MOA itself. Early this month, I was told by Peter McClaren of the Pacific Missile Range Facility public information office that the MOA had been signed by the state. However, on February 9, Gary Martin of DLNR told me that the state had not signed. He agreed to send me a copy of the final version. On February 23, after several calls to DLNR, Mr. Martin faxed me a copy of the MOA. It went into effect on February 9 and was signed by William Paty on or before February 5, his last day as DLNR director.
Perhaps one should expect such slow and confused response. It is in marked contrast to DLNR’s response on the CDX program last May. The CDX environmental assessment has the curious feature that all of the letters of consultation included with the document refer to other launch programs or to other EA’s. However, I obtained from Peter McClaren a May 20, 1992, letter faxed from the Department of Energy to William Paty, asking for a quick review of CDX and the May 21 reply signed by Paty, indicating, “We agree with your ‘no effect’ determination.” On May 22, the FONSI was signed and the rocket was launched at 4:45 a.m. on May 24. The CDX EA (which does not include the May 20 and 21 letters) did not reach the Office of Environmental Quality Control until November.
From reply of Bruce Anderson to Jones, dated March 5, 1993:
This reply to your questions has been coordinated between the Department of Health’s Clean Air Branch and Hazard Evaluation and Emergency Response Office.
There are no documents in either of the DOH offices that report on a consultation with the Strategic Defense Initiative Organization. There is also no state document which agrees that there is no significant impact in having the Hawai`i hydrogen chloride exposure guideline exceeded beyond the ground hazard area for STARS launches.
Similarly, neither of the two DOH offices has been consulted about the lead release of 9.2 kilograms of lead from a Terrier rocket or the 20.5 kg of lead released from a Vandal rocket. Also, neither office has received any reports of lead release after launches. The military is encouraged to report to state agencies on CERCLA matters, but they are not required to.
Volume 3, Number 10 April 1993