VERTICAL GUN TEST
ENVIRONMENTAL ASSESSMENT
MISSILE DEFENSE AGENCY
AGENCY:
Missile DefenseAgency (MDA)
ACTION:
Finding of No Significant Impact
BACKGROUND: The Missile DefenseAgency (MDA) preparedan
EnvironmentalAssessment(EA) to evaluatethe potential environmental
consequences
of using thickenedtributyl phosphate(TBP) as a chemical agent
simulant in a maximum of six vertical gun experimentsto be conductedat the
EnergeticMaterials Researchand Testing Center(EMRTC) at the New Mexico
Institute of Mining and Technology(NMT), locatednear Socorro,New Mexico.
Canisterscontaining dye enhanced,thickenedTBP would be launchedvertically at
speedsapproachingMach 3 or 4 from the 3K North site and dispersedto assist
MDA in determiningdrop size distribution for a simulatedchemical agentthreat.
Aerosol and droplet debriswould be primarily monitoredusing passivesensors.
The TBP experimentswould improve MDA's ability to evaluategroundhazards
from the interceptof a threatwarheadbearingchemicalpayloads.
After reviewing and analyzingcurrently availabledata and information on existing
conditions,project impacts,andmeasuresto mitigate thoseimpacts,the MDA has
determinedthat the proposedaction is not a Federalaction that would significantly
affect the quality of the humanenvironmentwithin the meaningof the National
EnvironmentalPolicy Act (NEPA) of 1969,as amended.Therefore,the
preparationof an EnvironmentalImpact Statement(EIS) would not be required
and MDA is issuing a Finding of No Significant Impact. The MDA madethis
determinationin accordancewith all applicableenvironmentallaws.
The EA was preparedin accordancewith NEPA; the Council on Environmental
Quality regulationsthat implementNEPA (Codeof FederalRegulations[CFR],
Title 40, Parts 1500-1508);Departmentof DefenseInstruction 4715.9,
EnvironmentalPlanning and Analysis; and the applicableserviceregulationsthat
implementtheselaws and regulations.
DESCRIPTION OF THE PROPOSED ACTION: Droplet size distribution has
beenidentified by MDA as the most important factor in determiningground
hazardestimationsfrom chemicalpayloads. Therefore,the purposeof the
proposedaction is to provide MDA with test scenarioswhere the drop size and
dispersionof simulatedthreat agentscanbe monitored,and thus enhanceMDA's
ground hazardestimationmodeling capability. The datacollectedfrom thesetests
would be usedto validate MDA's Post-Engagement
Ground Effects Model
(PEGEM).
MDA proposesto conductup to six vertical gun testswithin a two-week period at
the NMT 3K North site. CanisterscontainingTBP would be launchedat the 3K
North site. Testswould occur during the summermonthswhen wind speedsare
low and any rain depositedon the groundquickly evaporateswhich would meet
the test designersobjectivesof preventingthe TBP from dispersingover a wide
areaand allow TBP depositedon the groundto rapidly photodegrade.The
canisterswould contain approximately50 kilograms (110 pounds)of TBP
thickenedusing polybutyl methacrylate(PBMA) enhancedwith blue dye for
observationpurposes. A small amountof explosiveswould be usedto rupture the
canistertanks during ascentat an altitude of approximately500 meters(1,640
feet), resulting in the creationof a short-lived aerosoldebris cloud and the
subsequentdispersionof TBP droplets. TBP dropletswould be monitored using
severalremote-sensingmethodsincluding:
.
.
.
High-speedcamerasplacedat different locationsat the test site would provide
a visual documentary.
Doppler radar would be usedto monitor velocity of the canisterduring the
tests.
Lidar would be usedto characterizethe drop formation process,with Ka-Band
radar and W-Band radarusedto monitor drop size.
Approximately twelve witnesscardsdesignedto receivethe dye enhancedTBP
would also be placedon the groundapproximatelyone to two hours prior to the
test, with their location detenninedby modeling basedon the currentprevailing
wind conditions.
The testplannershave detenIlinedthat weatherrelatedcriteria would be
establishedto detennineGo/No-Go test conditions. The test plannersdetennined
a worst-casescenariobasedon PEGEM. The model predictedwhen winds from
the west (blowing between270 to 315 degrees)were lessthan or equalto 13
kilometersper hour (8 miles per hour), the test objectivescould not be met and the
testswould not be conducted. Testplannersindicatedthat realistically given
nonIlal meteorologicalconditionsthe proposedtestswould be conductedwhen
winds are lessthan 3 miles per hour (4.83 kilometersper hour). At this wind
speed,TBP dispersionis anticipatedto remain within the immediatevicinity of the
3K North site.
ALTERNATIVES TO THE PROPOSED ACTION: While alternativesto the
proposedaction were initially consideredduring fonnulation of the test plan, these
alternativeswere consideredinfeasiblebecausethey would not adequatelymeet
MDA's objective to determinedrop size distribution for a simulatedchemical
agentthreat. The useof simulantsother than TBP was considered,specifically the
useofBis (2-ethylhexyl) phosphonateand triethyl phosphate.Using either of
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thesetwo substanceswould not achievethe test objectivesof realistically
simulating the threat. In addition, althoughparathionand malathion would
realistically emulatethe threat,they were eliminatedfrom further consideration
becauseof their high toxicity.
The High PerformanceMagazinesite at EMRTC was consideredas an alternate
site for the proposedtests. The High PerformanceMagazinesite is locatedat a
relatively high altitude. This altitude, in conjunctionwith fewer mountains
surroundingthe site resultsin increasedwind velocities. Thus, conductingthe
proposedvertical testsat the High PerformanceMagazinesite would result in the
potential for TBP to be dispersedover a greaterland massarea,and to reacha
greaterheight in the atmospherethan testplanning intended. Thesefactorswould
severelyaffect meetingtest objectives;therefore,the High PerformanceMagazine
site was dismissedfrom further evaluation.
ENVIRONMENTAL
:
EFFECTS
Methodology
Thirteen resourceareaswere consideredto provide a context for understandingthe
potential effectsof the proposedaction and to provide a basisfor assessingthe
severity of potential impacts,with attentionfocusedon key issues. The resource
areasconsideredincluded: air quality, airspace,biological resources,cultural
resources,geology and soils, hazardousmaterialsand hazardouswaste,health and
safety,land use,noise, socioeconomicsand environmentaljustice, transportation
and infrastructure,visual resources,and water resources.
The Region of Influence was determinedfor eachresourceareadiscussedin this
EA. The Region of Influence describesa unique region for eachresourceareathat
representsthe areawith the potential to be affectedby the proposedaction. The
environmentalconsequences
associatedwith the proposedaction and no action
alternativeswere analyzedfor eachRegion of Influence within the context of
resourceareas.
Proposed Action
A detailedimpactsanalysiswas conductedfor all resourceareas. No significant
impactsto airspace,cultural resources,health and safety,land use,socioeconomics
and environmentaljustice, transportationand infrastructure,or visual resources
would occur from up to six proposedtestsat the 3K North site. No significant
impactswould result from hazardousmaterialsor hazardouswasteusedor
producedas a result of the proposedaction. Applicable regulationsand operating
procedureswould be followed when handling hazardousmaterialsand waste. The
following describesthe resultsfor thoseresourceareasthat presenteda potential
for impact.
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Constructionactivities and equipment,propellant from the gun, and generators
would produceair emissions;however,no significant impactswould be expected.
PBMA and the dye are inert; therefore,no significant air quality impactswould be
expectedfrom their use. Given the rapid dispersionof the dropletsand the
facility's remotelocation, no long-term air quality impactswould be expected. In
a failed test,the canisterwould fall and rupture upon impact with the ground. The
primary receiving environmentwould be soils, and there would be no significant
air quality impacts.
It is unlikely that noisewould elicit startleresponsesin wildlife. Biological
resourcesnear the 3K North site would not be exposedto concentrationsof TBP
over 100milligrams per squaremeter. PEGEM indicatesconcentrationsofTBP
would not approachtoxic levels for birds. The useof spill preventionmeasures
would reduceor eliminate potential impactsto biological resources.Therewould
be no effects to endangered,threatened,or proposedspecies,New Mexico Species
of Concern,or designatedor proposedcritical habitat as a result of this proposed
action.
TBP dropletslanding on the groundwould photodegradewithin a few hours when
exposedto sunlight. The dye would alsobreak down rapidly; however,somedye
may be visible for up to a few months. If TBP were depositedin one spot (due to
a spill or failed test), clean up would be conductedusing existing procedures.
Therefore,no significant impact to geology and soils would be expected.
Noise from generatorswould not be heardin the community of Socorro. The
primary noisewould be from firing the gun, which would be similar to jet
flyovers. Socorrowould be buffered from noiseby the mountainsand would not
be affected. A test failure would not alter noise levels. Therefore,no significant
noise impactswould be expected.
PEGEM indicatesthat TBP concentrationsat a local spring would be 1 to 10
milligrams per squaremeter,which would be unlikely to significantly impact
water quality. Given the amountof TBP and its likelihood to photodegradein
sunlight, no significant impactswould be expected. In a test failure or spill, TBP
would impactssoils; however,becauseof spill preventionand cleanupprotocols,
soil impermeability, and the depthto groundwater, no significant groundwater
impactswould be expected.
Cumulative Impacts
According to 40 CFR § 1508.7,cumulativeimpactscan be defmedas "... the
incrementalimpact of the actionswhen addedto other past,present,and
reasonablyforeseeablefuture actions,regardlessof what agency(Federalor nonFederal)or personundertakessuchother actions."
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For this analysis,cumulative impactsinclude impactsfrom the proposedtestsand
reasonablyforeseeabletestsat EMRTC. No significant cumulative impactsto
airspace,cultural resources,land use,socioeconomicsand environmentaljustice,
transportationand infrastructure,or visual resourceswould occur from the
combinedimpact of existing testingoperationsand the up to six proposedtestsat
the 3K North site.
BecauseTBP would photodegradeand decompose,no significant cumulative
impactswould be expectedto air quality, biological resources,geology and soils,
and water resources.In addition, all applicablestandardoperatingproceduresfor
health and safety and for handling hazardousmaterialsand wastewould be
followed; therefore,no significant cumulativeimpactswould be expected.
No Action Alternative
Under the no action alternative,the proposedtestsusing TBP would not occur
from the 3K North site. Other unrelatedtestsat EMRTC would continue to occur
and would have the potential to impact the environment. Therewould be no
significant impactsto air quality, airspace,biological resources,cultural resources,
geology and soils, hazardousmaterialsand hazardouswaste,land use,noise,
transportationand infrastructure,visual resources,and water resources.
Under the no action alternative,therewould be no proposedtestsusing TBP; and
therefore,none of the potential impactsto health and safetywould occur. The
purposeof the proposedaction is to allow MDA to betterpredict the dispersionof
simulatedchemicalweaponthreatsthat could compromisepublic health and
safety. Without dataobtainedfrom the proposedtestsusing TBP as a threat
simulant,MDA would be unableto verify necessarydataand would be forced to
rely on dataproducedfrom computer-basedsimulation rather than field-tested
observations.
Under the no action alternative,no proposedtestingwould occur at the 3K North
site, and it is unlikely that the vertical gun would be developedor usedfor future
tests. Revenuegeneratedby research,testing,and training activities at EMRTC
supply a large portion of the incomefor the community of Socorro. Local hotels
and restaurantsbenefit substantiallyfrom the numberof scientists,researchers,
and individuals receiving training at the facility that visit the community annually.
Although the no action alternativewould not affect employmenttrendsin the
region, it would place limitations on the current and future test capabilitiesof
EMRTC. This phenomenoncould inadvertentlyresult in adverseeconomic
effects for the community.
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PUBLIC COMMENT: The EA and Draft Finding of No Significant Impact
were releasedfor public review and comment. The MDA establisheda toll free
fax line, e-mail address,and U.S. postal servicemailbox to receivecomments.
Threecommentswere received. Two of the commentswere determinedto be
outsidethe scopeof this project and one commentrequestedadditional
information aboutthe availability of the documentsfrom the MDA public web
site. None of the commentsresultedin revisionsto the EA or Finding of No
Significant Impact.
CONCLUSION: An analysisof the proposedaction hasconcludedthat there are
no significant short-tenDor long-tenDeffects to the environmentor surrounding
populations. After careful and thoroughconsiderationof the facts herein,the
undersignedfinds that the proposedFederalaction is consistentwith existing
national environmentalpolicies and objectivesset forth in Section 101(a)of
NEPA and that it will not significantly affect the quality of the human
environmentor otherwiseinclude any condition requiring consultationpursuantto
Section 102 (2) (c) of NEPA. Therefore,an EIS for the proposedaction is not
required.
DEADLINE FOR RECEIPT OF WRITTEN C OMMENTS
.
.
18 May 2004
POINT OF CONTACT: Submitwritten commentsor requestsfor a copy of the
Vertical Gun Test EA to: Vertical Gun EA, c/o ICF Consulting,9300 Lee
Highway, Fairfax, VA 22031;via toll-free fax 1-877-851-5451;or via E-mail
vertical gun .ea@icfconsulting.com.
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VERTICAL GUN TEST
ENVIRONMENTAL ASSESSMENT
AGENCY:
Missile DefenseAgency (MDA)
ACTION:
Finding of No Significant Impact
PROPONENT:
cLJJl-
DATE: L'i~
o,rt-
DR. CHARLES A. LIND
Core Lethality Model Lead
Modeling and Simulation Program
APPROVED:
~D~r'
DATE:
Brigadier General,USAF
Deputy for Test and Assessment
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