Re: NASA Draft EIS

     It is important to remember that SFVAS sent a letter to the NASA Office of the Inspector General (OIG) months ago concerning the egregiously excessive clean-up standard NASA agreed to with the California Department of Toxic Substances Control.  The OIG concluded that the clean-up provisions in the agreement, entitled the “Administrative Order on Consent” (AOC) were unreasonable.  However, NASA management blithely ignored the OIG’s conclusions in preparing the current DEIS.  The AOC is the underlying justification for this environmentally damaging process, which will result in the trucking of approximately one half million cubic yards of soil, including irreplaceable topsoil, to landfills across the country.  In following this process, NASA is ignoring less environmentally damaging alternatives, including actual risk-based alternatives.