I wished to follow up with respect to the ELY District Managed
Natural and Prescribed Fire
Plan, EA -040-00-020.
When I spoke with Mr. Dunn on March 5, I was informed the fire plan
was being reviewed by the BLM
solicitor. I am concluding the review was completed in the interim resulting in the need for a complete EIS.
The Review Journal article is unclear in that it references part of the plan, being put on hold. Would you
clarify this with an official statement, or press release?
Secondly, I wish to discuss BLM Manual Section 1703
Hazardous Materials Management. In
light of the concern for radioactive materials being redistributed through the environment as a result of fire,
wild or man made, we need to consider this matter with the utmost care. The following sections from the
Hazard Materials Policy delineated BLM responsibility:
1. Protect public health and safety and environmental resources
by minimizing environmental
contamination on public lands and BLM owned or operated facilities.
2. Identify and control imminent hazards or threats to human health
and/or the environment from
hazardous substance releases on public lands.
3. Inventory, assess, and manage the cleanup of hazardous substance
release sites on public lands that
present a potential risk to human health and the environment and promote healthy ecosystems
4. Management of all releases or threatened releases on or affecting
public lands or BLM facilities,
giving immediate priority based on hazard and risk. Priority shall be given to the control of all releases or
threatened releases that pose an imminent health, safety or environmental danger.
5. BLM shall maintain an inventory of potential hazardous material
The Manual identifies 12 separate pieces of environmental legislation which the BLM must consider
Executive Order 12856, Federal Compliance with Right-to-Know laws and Pollution Prevention
Requirements. August 3, 1993.
Of special concern is weapons testing
done with Depleted Uranium. I would ask that your office review
the following reports:
Environmental assessment for the depleted uranium testing program at the Nevada
Test Site by the United States Army Ballistics Research Laboratory.
U.S. DOE Nevada Field Office (Ed.), DOE/EA-0398, Las Vegas, NV 1992, 60
Shinn,J H : Environmental Analysis of Metal Particle Dispersion
from an Explosive
Test at Tonopah Test Range. U.S. DOE (Ed.), UCID-21355, Washington,
D.C. 1988, 21 p.
Elder,J C; Tinkle,M C: Oxidation of depleted uranium penetrators
and aerosol dispersal at high
temperatures, Los Alamos Scientific Laboratory 1980, LA-8610-MS, 53 p. (Download full text 2.9MB
Erikson,R L; Hostetler,C J; Divine,J R; Price,K R:
Review of the environmental behavior of uranium derived from depleted uranium alloy
penetrators. U.S. DOE (Ed.), PNL-7213, 1990, 26 p.
Layton, David W; Armstrong,Anthony Q: Methodological
Considerations for Determining Cleanup Limits for Uranium in Treated and Untreated
Soils. In: Journal of Soil Contamination, Vol.3 (1994) No.4, p.319-348
Los Alamos was the site of Depleted Uranium testing, and as we know, horrific fires swept through that
facility. Currently EES 15at Los Alamos is testing for contaminates, which may have been released and
redistributed as a result of those fires. Understanding the implications of these requests, I know the level of
courage it will take on behalf of BLM leadership to fully evaluate the risks of fire, and radioactive materials
including depleted uranium. However, the implications of not full assessing these risks is potential
Nevada and Utah residents conceivably could face circumstances similar to those of Viequesa, Puerto
Rico. Here more than a third of the 9,000 inhabitants of that, Caribbean island have been found to be
suffering from a range of serious illnesses and cancers. The residents are claiming more than $100m in
damages from the US Navy over claims that ammunition including depleted uranium (DU) shells have caused
an epidemic of cancers there.
Dr. Rokke, a major in the US Army Reserve and former head of the Pentagonís Depleted Uranium
Project has stated that each day reveals more evidence that the United States' willful distribution of uranium in
Puerto Rico and other locations around the world poses serious risks. Although it is difficult to verify that
health effects were caused by DU exposure, accumulating evidence indicates that health effects include:
reactive airway disease, neurological abnormalities, kidney stones, chronic kidney pain, rashes, vision
degradation, night vision losses, gum tissue problems, lymphoma, leukemia, other cancers,
neuro-psychological disorders, uranium in semen, sexual dysfunction, gastro-intestinal problems, and birth
defects in offspring.
I am asking the BLM to find the best, most highly motivated and honorable people at its disposal to
ask tough questions, fully investigate, and completely research these hazards. It will take an tremendous
amount of personal courage, and agency integrity to engage the DOD, DOE, and Department of the Navy in
honest, meaningful dialogue on the issue redistribution of radioactive contaminants in soils and vegetation
through fire and other processes. I would encourage the BLM to dialogue with Los Alamos people. There
scientists have studied these issues for 15 years. It is critical that BLM establish a "hold harmless" approach to
these assessments. As we acquire new information, fear of reprisal or cost must not be an issue. We must
appreciate that individuals and policy makers made the best decision they could, given the information
available and political climate at the time these tests took place . It is a different time and place, we need
leadership which reflects those differences.
Goods From The Woods