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Chemical Weapons Disposal:
The Citizens' Solution to the
Costly Mistake of Incineration
1st Edition
March 28, 1995
Prepared by:
Kentucky Environmental Foundation
P.O. Box 467
Berea, Kentucky 40403
Tom Burch, Citizens Against Incineration at Newport. Tangier, Indiana.
Gina Chamberlain, Common Ground. Berea, Kentucky.
Jim Harmon, Families Concerned About Nerve Gas Incineration. Anniston, Alabama.
Debra Hille, Common Ground. Berea, Kentucky.
Tim Hensley, Common Ground. Berea, Kentucky.
Cindy King, Utah Sierra Club. Salt Lake City, Utah.
Rufus Kinney, Families Concerned About Nerve Gas Incineration. Jacksonville, Alabama.
Linda Koplovitz, President, Concerned Citizens for Maryland's Environment, Inc. Maryland State Citizens Advisory Commission on Demilitarization.
June Ottinger, Families Concerned about Nerve Gas Incineration. Advisory Board Member, Legal Environmental Assistance Foundation.
Suzanne Marshall, Serving Alabama's Future Environment. Anniston, Alabama
Sara Morgan, Citizens Against Incineration at Newport . Newport, Indiana.
Sue Rice, President, Aberdeen Proving Ground Superfund Citizens Coalition. Bel Air,
Maryland.
Annie Szvetecz, Life of the Land. Honolulu, Hawaii.
Alan Urban, Citizens for Safe Disposal. Sierra Club Member. Pueblo, Colorado.
Chip Ward, Tooele County Clean Air Coalition. Tooele, Utah.
Evelyn Yates, Pine Bluff for Safe Disposal. Pine Bluff, Arkansas.
Table of Contents
The preparations for war have left this country saddled with a toxic time bomb. Clean-up and safe disposal of this nation's chemical weapons stockpile demands an unprecedented level of cooperation of all parties: the Army, Congress, and those with the most at stake, citizens who live near these lethal stockpiles. Citizens desire and are willing to cooperate with a solution that would be safe, protective of public health, cost effective, and efficient. Now is the time to move decisively towards an acceptable solution.
The U.S. Army's 11 billion dollar chemical weapons incinerator program is out of control. It is 550% over budget, ten years behind schedule, and violates laws which protect public health. Safer, cost effective technologies could accomplish the mission of chemical weapons disposal more efficiently than incineration. The major stakeholders in the disposal program, citizens who live near the lethal stockpiles, support implementation of disposal technologies which do not emit toxic chemicals and lethal warfare agents into the air, water, and the food chain.
The incineration program is characterized by poor planning, fictional schedules, huge cost overruns, flawed implementation, broken promises, and the imminent threat to public health and environmental disaster. Citizens whose communities have fallen under the shadow of the chemical demilitarization program have gone beyond their initial reaction of "not in my backyard" to a more unified and responsible position: "Stop incineration and fund acceptable technologies for the disposal of these weapons."
The major flaws of the incineration program as outlined in this paper are:
There is a window of opportunity in this issue for safe, cost effective solutions. The incineration program for disposal is grossly over budget and woefully behind schedule with no relief in sight. The desire of Congress to cut wasteful programs, and the existence of safer, potentially more cost effective solutions to chemical weapons disposal make this an opportune moment for Congress to redirect this program.
The Chemical Weapons Working Group, an international citizens group made up of citizens from affected sites, has been taking a lead in the movement towards safe disposal. They advocate a phased chemical demilitarization program which would meet treaty requirements and protect public health and safety. The phased approach is as follows:
When concerned citizens are encouraged and empowered, solutions will follow.
The Army's chemical weapons incineration program is out of control. It is ten years behind schedule and more than 550% over budget. This program has never come close to meeting a schedule and the cost overruns have been scandalous. Moreover, the current schedules and projected costs are understated. There is a consistent pattern of developing cost estimates and mission schedules according to what will sell to the Congress and not according to capability and performance results.
In the last ten years, cost overruns within the Army's chemical weapons incineration program have cast serious doubt on the economic viability of this technology. In a January 1995 letter to Army Secretary Togo West, the General Accounting Office (GAO) strongly criticized the Army's methodology for estimating the costs of incineration, particularly projections based on its prototype facility (JACADS ) at Johnston Island in the Pacific Ocean. This GAO analysis concludes that the Army's program to incinerate the US. chemical weapons stockpile will cost at least $11 billion. That is a 29% increase from estimates made as recently as one year before, in December 1993, and makes the program more than 550% over its original 1985 budget of $1.7 billion. In addition, the GAO notes that "cost estimates to destroy the US. chemical weapons stockpile continues to increase and the current $11 billion estimate is understated."1
Recently the Army filed a permit modification to extend the Johnston Atoll facility's life by four years, at an added cost of $640 million, because it failed to complete its mission in its original permitted period. This brings the projected cost of the Johnston Atoll prototype to $1.3 billion compared with the Army's 1987 projection of $233 million. The JACADS facility alone is now estimated to cost 450% above the original estimate.
Cost overruns and schedule slippage are results of the failure of incineration technology to meet performance standards. Technological problems continue to plague the JACADS model incinerator. The Army attributes the delays at JACADS in its permit modification request to unexpected technical problems related to the incineration technology, including:
The planned expenditure of $17.7 million of taxpayer funds for dunnage incinerator equipment that may never be used is another example of wasteful spending based upon unrealistic expectations of this technology. The dunnage incinerators at JACADS have not been proven to accomplish the mission for which they were created. The GAO specifically criticizes the planned purchase of dunnage incinerators noting, "the Army's strategy could result in acquisition of unneeded equipment." The report strongly recommended that the military "postpone acquisition of dunnage incineration equipment until alternative waste management practices are fully evaluated, and the operational effectiveness and need for the current equipment are demonstrated." 2
In addition, taxpayers will continue to pay the fines when this technology fails to meet the EPA's minimum public health standards. The JACADS facility has been fined by the Environmental Protection Agency (EPA) a total of $122,300, that will be paid by US. taxpayers, for recent operational violations. The fines include $50,000 for its March 23, 1994, smokestack release of live GB agent into the atmosphere, and $72,300 for mishandling and improper storage of hazardous waste. These fines levied on March 14, 1995, are the first fines for this facility and one can predict there will be many more.
The Army's first chemical weapons disposal schedule became outdated as soon as it was released. The 1988 Final Programmatic Environmental Impact Statement outlined a disposal program that would be completed by Fall 1994. Now it is 1995, and due to technical failures and permitting problems, both related to the incineration technology, the Army's most optimistic schedule puts the chemical weapons disposal completion date at April 2004.
The Army's unrealistic schedules directly and adversely impact the cost of the program. For example, the Army has assumed future facilities will operate around-the-clock even though Johnston Atoll averaged only 8 hours of operation per day. 3 This is just one example of how the Army creates schedules that are based upon wishful thinking and what will sell to Congress rather than on actual performance. Throughout this program, Army officials have assured Congress of their capability to maintain disposal schedules. However, experience at the JACADS and TOCDF demonstrates that the Army cannot predict or control its incineration technology.
Several additional factors will increase the costs of incineration and delay the current Army timeline even more:
The Army has rushed this program ahead without meeting the intent of Congressional guidelines. Congressional legislation intended that the Chemical Weapons Disposal Program be developed in stages beginning with research and development (R&D), followed by Operational Verification Testing (OVT) at a pilot facility on Johnston Island (JACADS ), and finally staggered construction at the eight continental US. sites. The purpose for building this program incrementally was to correct any major deficiencies before proceeding forward. As previously mentioned, on January 3, 1995, the Army requested a permit
modification at JACADS to extend operations by four years, with an additional 650 million tax dollars, as "another step in the continued improvement of the JACADS operations and commitment the Army has made to prove the technology for the destruction of lethal chemical weapons."(emphasis added) 4
This is curious, considering that the Secretary of Defense certified "prove out" of the facility in August of 1993.
The Army continues to misrepresent to Congress the capability of its incineration technology to meet deadlines and budgets. This is demonstrated in the context of the certification process. In September 1988, Congress required the Army to successfully complete operational verification of the disposal technology at JACADS before proceeding with destruction of chemical weapons in the continental US. Four months before completion of verification, in April of 1993, the Army presented Congress with timelines for JACADS incineration which showed incineration operations close to its original schedule, starting in July of 1990, and ending in February of 1996. In August of 1993, former Secretary of Defense Les Aspin certified prove out of equipment and facility at JACADS. This opened the door for start up and construction of JACADS-like incinerator facilities in the continental US. Just eight months later, in April of 1994, the Army presented to Congress a revised schedule which showed operations at JACADS starting in January of 1994 and ending in January of 1999. In other words, the Army has redefined its operating schedule (changing startup from July of 1990 to January of 1994) at an optimum time (after certification), and thereby has misrepresented the true record of schedule slippage and cost overruns at JACADS. Responsible representation, stating that operational verification took four years longer than expected and will cost $640 million more than estimated, could have interfered with certification and, therefore, start-up operations and construction at continental US. sites.
Congress should heed its own skepticism. Operational Verification Testing(OVT) began in 1990, and by 1992 Congress had serious reservations about the viability of the Army's technology. In the 1992 Department of Defense Appropriations bill, Congress reported that "last year, the Committee warned the Army that the success or failure of the baseline (incineration) technology must be determined not on the basis of whether it works, but how well it works. The experience in Phase One of OVT at JACADS leads one to question the Army's confidence in the baseline technology." Upon completion of OVT in 1994, the Congress still had serious questions about JACADS' performance, as reflected in the House Defense Appropriations Committee Report on Johnston Atoll (JACADS) Testing Results, which stated:
The Army has stated that it is satisfied with the results. The baseline (incineration) technology still seems to be the Army's preferred approach to chemical weapons destruction. The Committee points out, however, that OVT was not the success it was advertised to be. In Phase I of OVT, destruction of rockets filled with GB agent was tested. The test encountered numerous engineering and other problems and never achieved the goals of the facility...The OVT IV Report states that "...the projectile demilitarization system did not operate in a sustained, full production mode for a
sufficient period to evaluate its long term capability to process projectiles." Problems included projectiles entering the incinerator before being drained of agent, burster removal machines that failed continuously, munitions tracking problems, and (perhaps most serious) the need for virtually continuous presence of "fully suited" personnel in contaminated processing areas. 5
Both Congress and the Army recognize the problems. It is time to admit that the problems are due to the choice of an inadequate technology and stop throwing good money after bad.
Incineration of chemical weapons presents an imminent hazard and largely avoidable risk to public health, the environment, and the economic viability of local communities. The US. stockpile consists of weapons filled with the nerve agents GB and VX and with blister agents - also known as mustard. These chemicals are among the most lethal on the planet. Release of small amounts of agent can be catastrophic. Incineration of chemical weapons releases live agent, heavy metals, and other toxic chemicals into the atmosphere, through the smokestack. Dioxin is just one of more than 1,000 chemicals to be emitted during the chemical weapons incineration process. Current EPA studies link incinerator-produced dioxin emissions to cancer, sterility, endometriosis, reduced glucose tolerance, birth defects, immune system suppression, and decreased testis size. 6
Among the known and quantifiable chemical weapons smokestack emissions are acetone, arsenic, benzene, chromium, cadmium, chloride, chloroform, chloromethane, copper, lead, mercury, nickel, toluene, vinyl chloride, and zinc, just to name a few. 7 However, many more of the products of incomplete combustion (PICs) have neither been identified nor analyzed, even though they still pose a threat to public health. The Army refuses to acknowledge this threat, or to take it seriously. "The EPA has not even established standards for all PICs," said former Director of the US. Army Chemical Material Destruction General Walter Busbee, implying that the Army does not have to be concerned about them.8 According to Charles Baronian, Former Program Manager for Chemical Weapons Disposal, "The technology to look for one thousand possible compounds or to quantify 100 percent of the emission contents simply does not exist...Therefore, an element of uncertainty will always remain as far as the nature and quantity of what is coming out of the smokestack." 9 That is true; but there is no uncertainty that what is coming out of the smokestack is a health threat.
The EPA has found that the greatest public health threat related to incineration is not direct exposure to the chemicals released, but food chain exposure. Smokestack emissions, such as dioxin, are now known to travel hundreds of miles and bioaccumulate in the food chain, causing a risk to public health 1,000-10,000 times greater than through direct exposure.10 This could have economic implications for the agricultural sector of many rural communities which surround the proposed incinerator sites. Moreover, such emissions would potentially put hundreds of thousands of American citizens who rely on these food products at risk.
The JACADS incineration experience has demonstrated that accidental releases of live chemical warfare agents into the environment can be expected with this technology. On March 2, 1995, a "small" amount of nerve agent was detected outside of the JACADS facility. This is the third publicly known release of lethal warfare agent at the facility. Chemical and Biological Defense Agency spokeswoman Suzanne Fournier responded to this release by saying, "There is such a (small) trace that quite frankly I have problems with this information getting out ."11
The public health effects of low level exposure to chemical warfare agent can be of significant consequence. Therefore, release of agent into the atmosphere, no matter how small the amount, is a public concern. Experts agree that there are long term effects of exposure, but do not agree on what those effects are. According to the National Research Council (NRC ), "These long-term public health effects are much more difficult to evaluate than the effects of accidental releases, and they suffer from incomplete, variably interpretable data for effects that may have a latency of 20 to 30 years." 12
The experts contradict themselves about the effects of low level agent exposure. The NRC reports, "No long-term effects of any of these acute, symptomatic exposures have been documented," and "There is little information about the neurotoxic effects" of low level exposure to warfare agents. However, in the same report, the NRC also reports that "increased cancer rates have been documented from exposure during work-related activities at mustard production facilities." 13
Such experts should request access to the Army's data regarding the long term health effects of exposure to chemical warfare agents. The Army's own behavior has created a wealth of information on this subject. The most well known chemical weapons accident in the US. occurred in 1968 during a test of the effects of VX. During testing, the Army sprayed VX out of an F-4 Phantom jet at Dugway Proving Ground. Army documents estimate that up to 20 pounds of lethal agent may have blown off the proving ground. The next day 6,000 sheep within twenty five miles downwind of the depot were dead. Soil and vegetation were tested for nerve agent and only the faintest of possible traces of nerve agent were found. Residents downwind in the town of Skull Valley have suffered severe headaches, nausea, paranoia, and an increase in miscarriages and problem pregnancies, symptoms similar to low level nerve agent poisoning. To date, the Army has conducted no follow up studies on the health of residents, nor on the long term effects of this poisoning. In fact, despite the fact that the Army settled a lawsuit out of court with residents to cover damages, it still refuses to acknowledge responsibility for this incident which suggests a pattern of negligence and refusal to accept responsibility for the public health consequences of chemical warfare operations.14 Such reckless behavior presents a whole new set of dangers to worker and public health and safety as the disposal program moves forward.
The Army's way of dealing with justifiable concern about these most lethal substances is to deny citizens information. At a public meeting in Alabama March 14, 1995, a member of the Citizen's Advisory Commission, appointed by the Governor of Alabama, questioned Army representatives about lack of public notification of the number of low level live chemical weapons agent releases at JACADS, such as the one mentioned above. Kathy Gibbs, Public Affairs representative for the Army's Chemical Demilitarization program, responded that if the cause of the release and the corrective action is unknown, the public is not notified of the release. Upon further questioning concerning the number of occurrences of this type of release which have not been reported to Congress and the public, Ms. Gibbs responded, "I don't know."15
The Army has already wasted enough public money in attempts to design a monitoring system for a technology which has proven itself unable to be monitored. Experts agree that the monitoring system at JACADS is inadequate. The MITRE Corporation has documented a high number of alarms during the OVT tests: 82 alarms during the GB Campaign, 56 during the HD projectile test, 76 during the VX Campaign, and 5 during the HD ton container test. 16 According to International Union of Pure and Applied Chemistry (IUPAC), "several detection systems have been developed, but they are less than ideal. Needed is a superior continuous, real-time monitoring system able to detect chemical weapons agents in the gas phase at very low concentrations, determining both the presence and the specific identity of the detected agent, with rare false alarms."17 The National Research Council reported in their 1994 review that "the major finding of the committee is that the monitoring system currently in use at JACADS should be improved prior to employment at sites in the continental United States." 18
Communities living near the Army's chemical weapons stockpiles are not prepared for a chemical disaster despite the Army's six year old, multi-million dollar Chemical Stockpile Emergency Preparedness Program (CSEPP). Disposal methods which are open-ended, such as incineration, which allow the accidental release into the atmosphere of nerve agent and high concentrations of toxic PICs like dioxin, are inherently less safe than closed-loop systems which contain and control the by-products of disposal. Given JACADS' record of poor performance, the incidence of live chemical warfare agent releases, and CSEPP's ineffectiveness, local communities are not confident that they will be able to prevent scenarios of chaos and tragedy that could occur at stockpile sites once the incinerators are on line.
The Defense Authorization Act of 1986 (P.L. 99-145) mandates that in destroying chemical weapons, maximum protection be provided to the general public. In response to concerns over health and safety of chemical weapons storage and disposal the Army, in 1988, initiated the Chemical Stockpile Emergency Preparedness Program (CSEPP). The initial budget was $144 million through 1994, the originally projected completion date of disposal. In 1994 the Army again revised its cost estimates to $696 million for on-going operations of CSEPP through 2003, an increase of 383%. In spite of money spent this program is riddled with problems, leaving communities not much safer than when it started seven years ago. 19
Testifying before the House Subcommittee on Environment, Energy, and Natural Resources, David R. Warren, Associate Director of Defense Management and NASA Issues of the GAO, echoes some of the concerns long held by the residents living near chemical weapons stockpile sites. In his testimony, Mr. Warren said CSEPP's lack of progress is due to program management weaknesses, including fragmented authorities and responsibilities, and weak controls over funds, which have resulted in cost overruns, lack of accountability, over expenditures and delays in issuing guidance. Communities, as a result, cannot quickly and effectively notify residents of a chemical accident nor provide instructions on how residents should respond. They cannot evacuate nor shelter-in-place those residents who would be immediately affected by a chemical accident. They cannot provide protective equipment to those emergency responders who would be expected to assist in evacuation, render aid and conduct decontamination, re-entry, and restoration operations. Finally, communities cannot provide the medical response needed to handle and treat chemical casualties. 20
More recently in their February 1994 report, GAO again gives a critical assessment of CSEPP's lack of progress. Foremost from their point of view is an unwieldy committee-based management structure which lacks accountability and does not adequately support program coordination and execution. Responsibility for program decision-making and operational guidance is dispersed among the Joint Steering Committee and its six subcommittees, each of which is co-chaired by Army and FEMA representatives. According to the report this leads to delays in CSEPP's ability to provide medical readiness training, automation, and procurement. 21
Furthermore, communities who are attempting to develop appropriate emergency response plans are unable to due to the lack critical information and guidance needed from the Army and FEMA. These include a reliable dispersion model which calculates the rate of chemical release and standards for re-entry and recovery after the emergency. 22
Another major area of weakness documented by the GAO report is the lack of accountability for funds. FEMA, the agency responsible for administrating 70% ($130 million) of CSEPP's funds, can not accurately account for how the funds were spent.
As with the overall chemical weapons disposal program, there has been a serious lack of involvement of citizens in CSEPP's decision-making and planning process, and little effort to reach out to the broad spectrum of the community that will be impacted by the program. Despite the amount of money that has been spent on public awareness, CSEPP evacuation plans are largely unknown in most chemical weapons stockpile communities. In an unofficial poll taken by a concerned citizen in Pine Bluff, Arkansas, 78% of citizens polled did not know what to do in case of an emergency at the Arsenal. 23 In this same community of predominantly Afro-Americans (53%), the poverty rate is twenty percent and the literacy rate averages at the eighth grade level, yet CSEPP has produced public information that is so technical its residents complain that it cannot be understood. Furthermore, town meetings regarding emergency preparedness are held at White Hall, another community of almost all Caucasians (94%). Had CSEPP consulted with the poorer residents of Pine Buff regarding in-place-sheltering during chemical emergencies, they would have been informed that due to the conditions of the homes duck taping windows, doors and other openings to prevent nerve gas poisoning would not make them impervious to nerve gas.
There is the potential risk that a panic reaction alone could very easily trigger accidents. A glaring weakness with CSEPP evacuation plans is that they assume people will act in a predicable manner, which is not always the case during emergencies or even equipment testing. Already in Calhoun County, Alabama, for example, when the monthly alarms go off, it causes a panic reaction with the elderly and general confusion with others. In addition, people outdoors can hear these alarms miles away while others inside buildings with the windows closed only a few hundred yards away may not hear them at all. Residents in Richmond, Kentucky, question whether or not people in Zone 1A, for an example, will stay put while their next door neighbor in another zone is evacuating under CSEPP instructions. How many people, they ask, would be willing to go to a shelter without their children despite CSEPP's reassurances that provisions have been made for school children?
Where alarms are in place in communities like Jacksonville, Alabama, there is a lack of confidence that CSEPP will be responsive in actual emergencies. Jacksonville residents point to the fact that CSEPP headquarters is unmanned sixteen hours a day on weekdays and totally unmanned on weekends.
Other complicating factors in CSEPP planning include the lack of adequate escape routes. In Anniston, Alabama, for example, there is only one major escape route for a community of 70,000 people living within 12 miles downwind of the proposed incinerator. One can only imagine the chaos that would result in a rural community like Parke County Indiana located only a few miles from the Newport stockpile site if a chemical accident occurred during the two weeks of October when the County hosts the Covered Bridge Festival, an event which draws over a million people every year from around the country. A similar horror show could occur if there were an accident during a football game at Jacksonville State University, which routinely draws crowds of 15,000 on Saturday afternoons in the fall.
Experience with the JACADS incineration program demonstrates that alarms, false or real, occur with regularity, and it takes fifteen to twenty minutes to verify whether an actual agent release has taken place.24 Therefore, to protect citizens, CSEPP would have to initiate an emergency response every time the alarms sounded, not knowing whether the emergency response was absolutely necessary or even whether their actions were sufficient and appropriate at the time. Too many false alarms may make citizens less cautious and more reluctant to act in accordance with CSEPP's instructions.
CSEPP planners have not taken into account the effect that low level exposure to warfare agent could have upon emergency preparedness. The Health Sciences Research Division of Oak Ridge National Laboratory reports: "The implications for an exposed civilian population include possible confusion, inability to follow directions provided in conjunction with public warnings from emergency personnel, inability or enhanced unwillingness to cooperate with authorities in the event of an evacuation notice (e.g., inability to drive), and limited ability to cooperate during decontamination and treatment procedures. Thus, early warning systems are of singular importance, as well as prior education of the public in adequate response
measures." 25
The key issue for citizens is not whether the Army's disposal program involves risk. Any disposal technology will involve some risk to public health. Given the difficulty of protecting people in a chemical agent emergency, it is imperative that the Army choose a method of chemical weapons disposal with the greatest number of safeguards for the protection of human life. Incineration clearly does not qualify.
The Army and their contractor, EG&G, in Tooele, Utah, have been charged with using "fear and intimidation" to threaten workers who attempt to raise concerns about safety at the chemical weapons incineration facility. Mr. Steve Jones, former Chief of Safety at the Tooele Chemical Disposal Facility (TOCDF), has recently filed suit with the Department of Labor under federal environmental whistle blower laws. According to Henry Silvestri, general manager for EG&G, Jones' "by-the-book" style had become a problem. 26 Before coming to EG&G to work at their chemical weapons incinerator, Mr. Jones had a promising career as a result of his twenty years experience in military safety matters. He received the US. Navy's top unit safety award twice.
The safety of the workers and the public is mandated by law to be the number one priority of the Army's demilitarization program. The Army has a history of "covering up" safety problems with regards to its chemical weapons testing, storage, and disposal programs and this cover up continues today. The evidence suggests that the Army is more concerned about the appearance of accomplishing its "mission" of destroying chemical weapons, than in protecting the public health.
Just two days after he was hired, Jones shut down the plant's laboratory for allowing 1,500 test tubes of diluted agents to vent directly into an unfiltered building, jeopardizing both facility staff and the public. Jones was verbally reprimanded for his action. Likewise, on other occasions, in return for his high regard for worker safety and public health, Jones' supervisors stated that he was "not a team player" and did not "keep the customer [the Army] happy." 27
In preparation for a Department of the Army Inspector General (Army IG ) plant inspection scheduled for the month of August 1994, Jones conducted an internal audit of the EG&G Safety program. He summarized his findings in a memo to his supervisor, indicating that the plant would receive poor ratings in fifteen broad safety programs. His supervisor responded by telling him never to put anything negative about the plant in writing.
In late August, the Army IG conducted its review of the facility's safety operation. Based on its inspection, the Army IG generated a report that confirmed the safety deficiencies Jones had enumerated as a result of his internal audit. The IG report also revealed numerous additional safety and noncompliance problems.
In early September, Jones received an independent audit entitled "Safety Assessment Report for the Tooele Facility," dated May 27, 1994. The report, prepared by the MITRE Corporation for the Army, identified 3,016 hazards at the plant relating to the design and operation of the incinerator.28 It is important to note that over 1,000 of the listed concerns were designated as presenting "imminent, catastrophic risk" of explosions or warfare agent releases. After a thorough examination of the report, Jones determined that the most serious hazards noted in the report had never been addressed by either EG&G or the Army. Jones recommended that additional hazard analyses be undertaken by both EG&G and the Army. Problems included the following:
Soon thereafter, Jones was asked to sign a document stating that no corrective action was needed to address the risks identified by MITRE. Jones notified his supervisors that it would be illegal for him to sign off on such a document. He felt certain that without intervention the conditions at the facility, documented by MITRE, indicated a high chance of fatalities and release of nerve agents
The day after Jones made this refusal, and only eight days after the Army IG inspection team submitted its report to Army officials verifying Jones' evaluation, Jones was fired by EG&G. For his professional ethics, he was branded an alarmist, an hysteric. EG&G cited a "difference in philosophy" and the "convenience of the company" as the reasons for his dismissal. Jones has filed a suit with the Department of Labor, under whistle blower protection laws, for wrongful termination. 29
In response to Jones' allegations of imminent and catastrophic risk of an accident, Congress directed that investigations be undertaken. Unfortunately, it allowed two of the most important of these investigations to be conducted by the Army itself. Jones alleged 119 specific complaints in safety training, operations and management, but most importantly he charges that the design is unsafe. "They can't make this plant work. It's just an unsafe design," said Jones in both the Tooele Transcript Bulletin and The New York Times.30 The Army Safety Center conducted an investigation, and in its report31 confirmed 58 of 119 specific complaints in safety training, operations and management. In the press release accompanying the report, Brigadier General Thomas Garrett, Director of Army Safety, said, "The team found no indication that the health or safety of any person was compromised while working with hazardous materials or toxic chemical materials."32
The fact that the Army team did not find that the safety and health of employees was jeopardized is hardly reassuring. The 58 violations that the Army identified indicate a pattern of neglect which may well cause a serious threat to workers and the public when the facility begins full scale operations. There is no room for error when dealing with chemical warfare agents.
Garrett acknowledged the allegation of design flaws, but passed off the responsibility for investigating design to the Corps of Engineers.33 Unfortunately, the Corps did not do a comprehensive evaluation of the overall design of the plant. Instead they limited their investigation to 12 specific allegations made by Jones in the context of worker safety problems. The press release on design-related safety issues sent out by the Army Corps of Engineers concluded that "none of the allegations indicate a flawed or inadequate design...and that a professional program is in place that insures construction conforms to the permitted design." That avoids the issue; the basic allegation is of a design flaw. The Corps simply confirmed that the facility was constructed according to the original design, and passed responsibility for design flaws to the permitting agency. Jones' basic design flaw allegation, i.e. "the real problem is that this facility can't support the technology," was not investigated. Clearly an independent and in depth review of Mr. Jones' allegation has been avoided. The Army did not address the primary question: can this facility, as designed, support the technology?
The EPA has implemented a new combustion strategy for hazardous waste incinerators which requires comprehensive risk assessments prior to permitting hazardous waste incinerators or renewing permits. Such risk assessments are explicitly required to address dioxin-like compounds emitted. Such a risk assessment, if conducted with integrity according to valid risk assessment protocols using current science, would show the Army incineration program poses an unacceptable risk of cancer and non-cancer adverse health effects.
Despite being required, such risk assessments have not been performed regarding the Army incineration program at each site.
Therefore, the Army has not complied with EPA's hazardous waste combustion strategy policy. Neither the EPA nor any other party has performed the required risk assessment, although the Army in its December 1994 report to Congress has acknowledged these requirements.34
EPA's emissions testing at hazardous waste incinerators and EPA deposition modeling of incinerator emissions support the conclusion that prohibited ocean disposal has occurred at JACADS and will continue to occur if JACADS is allowed to continue incineration operations. This is sufficient basis in itself to support denial of the Army's requested permit modification and future requests to extend incineration operations at JACADS.
The Resource Conservation and Recovery Act (RCRA) requires that the Army incineration program permits be denied/revoked because the Army programs at JACADS and TOCDF have been found to be in noncompliance. For example:
Furthermore, the National Research Council has noted that the RCRA permit allows the JACADS Metal Parts Furnace to process parts having only 5% or less of the agent originally in the projectile. However, the Army engaged in the practice of feeding agent-filled projectiles into the metal parts furnace on several occasions, which is a major incident of noncompliance and illustrates the lack of character and competence of the Army as a permittee. 35
JACADS and TOCDF are in violation of federal statutes and regulations implemented by EPA and OSHA that require that workers at hazardous waste facilities be protected from dangerous exposures and injuries.
It also appears that the Army is either not respecting the whistle blower rights of its chemical weapons destruction project employees or is failing to select, train, and oversee its contractors in this regard. Whistle blower Steve Jones has presented highly credible testimony that the Army and its contractor have attempted to rush operations -- disregarding environmental, worker and public safety violations and requirements in the process. He has brought an environmental statute employee protection complaint before the US. Department of Labor, making these allegations and alleging that he was retaliated against because of federally protected activities, in violation of RCRA (42 U.S.C. § 6971).
There is no room for error or noncompliance when dealing with ultra hazardous-chemical weapons and nerve agent. Even if EPA had discretion to ignore the Army's noncompliance, which is partially summarized above, to do so in this case would not only be ill-advised, it would be reckless. Because the evidence indicates a pattern of noncompliance and an unacceptable danger to public health and the environment, RCRA requires that EPA deny the Army incineration program permits pursuant to 42 U.S.C. § 6925.
In summary, the Army's chemical weapons incineration program is in violation of laws set up to protect public health, safety, and the environment. The US. Army has a responsibility to abide by these laws. It is our observation that chemical weapons incineration can not comply with these laws because it is a dangerous and unpredictable technology. In self-defense, citizens will litigate these violations, which will lead to further delays and cost overruns.36
The public has a vested interest in the safe disposal of the chemical weapons stored in their communities. The decision to burn these most lethal weapons in communities surrounded by homes, schools, and hospitals was made by the Army ten years ago without citizen input. Citizens became involved in this program out of concern for the public health and safety of their communities. As illustrated throughout this paper, citizens are informed, tenacious, and angry at having been excluded from decisions that affect them. Throughout the history of this program, citizens have been denied important information regarding the viability of this technology and its effects upon public health and safety.
The Army can not afford for the truth to be known about its incineration program and may have violated the Freedom of Information Act (FOIA) in "cover up" attempts. Despite repeated FOIA requests for the Inspector General's report which confirms Steve Jones' allegations of worker safety problems at TOCDF, the Army refused to release this information to the public, stating that the document was an "internal pre-decisional document" and irrelevant to Jones' allegations. When this document was finally released through unofficial channels, it confirmed Jones' allegations. According to Joanne Royce, an attorney with the Government Accountability Project which represents Steve Jones, "the only thing sensitive about the document is that it is embarrassing to the Army." 37
The Army's chemical weapons disposal program is out of step with citizens' demands nationwide for an increased role in the environmental decision-making process. In response to these demands, the EPA issued rules in May of 1994 which mandated increased public involvement requirements for trial burn plans and risk assessments. In response to notification of these provisions, Daryl Palmer, of the US. Army Chemical Materials Disposal Agency, requested that these public involvement requirements be waived for the Army.38
In response to citizen demands for greater inclusion in the decision-making process, the Congress legislated the establishment of Governor-appointed Citizens Advisory Commissions (CACs) to serve as conduits of citizens' concerns to decision makers. CACs have performed their duty well, holding public meetings, developing risk analysis criteria and monitoring the disposal program with limited resources. CAC's have been allocated $25,000 each for Administrative purposes. This money has been used by the groups for public outreach and administration so that they can perform their duty. However, to bridge the current chasm between the citizens, decision-makers, and the Army, these bodies need financial assistance to pay for technical assistance. Exemplifying the Army's disdain for public involvement, special Assistant to the Army's Chemical Demilitarization Program Manager, Mark Evans, said that "if the CAC's are reformed and given more authority, the Army would need more oversight in the selection process." 39 In other words, if the public wants to participate in the decision-making process, the Army wants to pick which members of the public participate.
As part of a taxpayer-funded $2 million public relations program for its chemical weapons destruction program, the Army hired Batelle Corporation to conduct a study on how to improve public relations in our communities. Batelle conducted a site-by-site study and concluded that " Public resistance and opposition (to chemical weapons incineration) is likely to continue and become increasingly organized across sites, making it even harder in the future than in the past for the Army to implement its current plans." 40
Furthermore, Batelle concluded, "The Army needs to consider both how the local residents will be involved in the process of choosing the technology by which the nearby stockpile will be destroyed...and how the local communities will be involved in decisions about program implementation. In today's political and social context, program managers must take the initiative in engaging their stockholders in a mutual, cooperative problem solving process." 41
Similar conclusions were made in 1992 by the Office of Technology Assessment (OTA): " A successful program is likely to require the active participation of all interested parties, including the Army, states, regulators, contractors, community organizations and environmental groups. The process must involve the public early and continuously and must provide for meaningful public input to the decisions made." 42
Albert Einstein once said: "The significant problems we face can not be solved at the same level of thinking we were at when we created them." The preparations for war have left our country saddled with a toxic time bomb. Clean up and safe disposal of this nation's chemical weapons stockpile demand an unprecedented level of cooperation between all parties: the Army, Congress, and those with the most at stake, the citizens who live near these lethal stockpiles. An acceptable solution would satisfy the need of all parties, be safe, protective of public health, cost effective and expedient. Now is the time to move decisively towards an acceptable solution.
As previously noted, one of Batelle's recommendations to the Army is to "modify the decision- making process to provide more direct involvement by the interested and affected publics. Given the nature of public concerns, this would require a willingness to revisit the early steps in the decision-making process, problem definition, identification of alternatives, and establishment of evaluation criteria, which were not previously open to the public."43
There is a window of opportunity in this issue relative to safe, cost effective solutions. The incineration program for disposal is grossly over budget and woefully behind schedule with no relief in sight. The desire of Congress to cut wasteful programs, and the existence of a safer, potentially more cost effective solution to chemical weapons disposal make this an opportune moment for Congress to redirect this program.
Citizens who live near these dangerous chemical weapons stockpiles are willing to cooperate. They have a vested interest in a cost effective and timely solution: they are paying the bill and they are most at risk. But they will not support a dangerous, unhealthy, and wasteful solution, especially since there are safer solutions which may be more cost effective. Over the past ten years, citizens have shown a commitment to understanding this complex problem. They rejected the approach of "not in my backyard" for a more unified and responsible position: "Let's develop acceptable technologies for the disposal of these weapons." They have turned out by the thousands to attend Army meetings on chemical weapons disposal. Tens of thousands of letters have been written to Congressional decision makers on this issue. Citizens have attended Citizens' Advisory Commission (CAC) meetings and worked with these Governor-appointed bodies to come up with their own criteria for safe disposal of these weapons. They have joined together as a unified coalition to make the democratic process work for a safe, cost effective solution.
At a recent CAC meeting in Maryland, citizens who are opposed to an incinerator "in their backyard" showed strong support for the use of the Aberdeen Proving Ground as a pilot plant for testing neutralization as an alternative to incineration. 44 Such a willingness to cooperate is evidence that concerned citizens are interested in working with Congress and the Army to find acceptable methods of disposal.
Citizens ask Congress to invite both the concerned public and the Army to the decision-making table in search of a compromise solution which would meet both the citizens' criteria for public health protection and fiscal responsibility, and the Army's criteria to complete their mission to dispose of these weapons.
Citizens ask that Congress hold public hearings in order to completely reevaluate the chemical weapons disposal program. Further, citizens ask to be invited to any Congressional hearings related to chemical weapons disposal. Specifically, citizens ask the House and Senate Defense Appropriations committees to analyze the cost and schedules of the chemical weapons disposal program based on the program performance, and they ask that citizens' criteria and solutions be included in the comparative studies. They ask the Senate Armed Services Subcommittee on Readiness to evaluate continued authorization of funds for the present program, given its cost overruns, schedule slippages, and unsafe performance.
"There is still time to do...research (of alternative technologies). It is insurance against future trouble, and is a rock-bottom necessity," according to IUPAC's Task Force on the Scientific Aspects of the Destruction of Chemical Warfare Agents.45 Given the history of the Army's incineration program, citizens who live near these lethal weapons conclude that the development of alternative technologies is the only responsible way forward, and they are not alone.
More and more researchers focused on chemical weapons disposal recognize the viability of alternative approaches. The prevailing view, summarized by the National Research Council's Committee on Alternative Chemical Demilitarization Technologies in its 1993 report is: "There are many possible destruction processes. The scope of possible modifications ranges from simply replacing one component, such as the agent combustion process, to replacing all current combustion-based processes." They go on to say, "There are a number of promising chemical processes for agent detoxification or oxidation;" and "there are technologies to replace the baseline metal parts furnace."46
Cornell University Noble Prize-winning Chemist Dr. Roald Hoffmann calls for a "two year moratorium on incineration construction," while advocating "$60 million for alternative technology development." 47
Georgetown University Law Professor David Koplow, who is a Board Member of the Lawyers Alliance for World Security and an expert on the Chemical Weapons Convention, says that "the Army's current eight-site plan for constructing chemical weapons incinerators should be abandoned."48
There are safer alternatives, which appear to be more cost effective, some of which could be ready for use on chemical weapons within 2-5 years. The Chemical Weapons Working Group recommends a phased approach, as outlined in the "Citizens Solution for Safe Disposal" of March 1994, including the following:
Citizens request that Congress ask the GAO to compare the cost of reconfiguration, partial neutralization, and remediation of the by-products with the cost of the current incineration technology; and that reconfiguration and partial neutralization be included in risk assessments.
The evidence presented within this document shows that the program to incinerate chemical weapons is in trouble due to :
For all these reasons, and more, citizens call for a halt to the incineration of chemical weapons. The investments made at JACADS and TOCDF are not completely lost if incineration is halted. The support buildings, infrastructure, munitions reconfiguration equipment, containment buildings, and labs are easily adaptable to solutions proposed in the citizens' approach. Much of the incinerator equipment may be salvageable for other industrial uses.
The Office of Technology Assessment recommended in 1992: "One approach to an alternative program could be to try and find mid-term corrections for the Army's current system, e.g., replacing one or more of the incinerators themselves with some other method of destruction but keeping the rest of the system."49 This approach is sound and supported by citizen's groups on all of the affected communities.
Reconfiguration followed by partial neutralization has received support from stockpile communities because it does not randomly and routinely release warfare agent, dioxins, and other chemicals into the environment as incineration does. According to leading researchers, neutralization would be more cost effective than incineration.50
Reconfiguration followed by partial neutralization would satisfy treaty requirements. Arms control expert David Koplow of the Lawyers Alliance for World Security states, "The substantive arms control interests would...be amply satisfied if the United States were, in a reliable and verifiable fashion, to: (1) separate the lethal agent from the ordnance; (2) cut, crush, or puncture any operational delivery systems, such as shells, bombs, or mines; (3) chemically denature the toxic agents, so they were, although perhaps still terribly hazardous, no longer suitable for warfare purposes, such as forcing an irreversible chemical reaction, adding impurities or otherwise; and (4) store the resulting toxic waste products, under international safeguards, pending the evolution of acceptable technologies...."51
The first step in any chemical weapons disposal technology is to drain the agent from the rockets, artillery shells and mines. Drained agent should then be neutralized to a level appropriate for handling and storage. This first step should be done as soon as possible. It would greatly reduce the risk at stockpile sites, particularly those which store M55 rockets, meet treaty requirements sooner, reduce regulatory complexity and shorten the time that extensive national and international weapons-related structures would have to be maintained.
Reconfiguration without delay will eliminate risk of exposure to agent due to explosion of the munition, which thus eliminates the worst-case scenario in the risk assessments. This approach would reduce such risks more expeditiously than the Army's current incineration proposal. A reconfiguration technique was presented in a report submitted to the Army by A. D. Little Corporation as early as 1985.52
Great Britain, Canada, the former Soviet Union, and France have already used neutralization to reconfigure their chemical weapons stockpiles. France in particular uses a relatively simple process of submersing the munition in a pool of sodium hydroxide, punching it, draining agent, washing munition, and storing all of it.
This approach has received strong endorsements within the scientific community. According to the National Research Council, it would "eliminate the risks of continued storage." 53
Senator Pryor, in questions submitted to the Army as part of the 1994 Senate Hearings on chemical weapons disposal, stated that the disposal time frame for the Chemical Weapons Convention "would allow for the reconfiguration of the stockpile, neutralization of the agents, and follow-up treatment of the by-products of the neutralization process." 54
3. Fund pilot testing of promising alternative technologies for complete and final disposal of the chemical weapons stockpile and non-stockpiled materials.
There are closed loop technologies which do not have smokestacks to emit poisons into the atmosphere, which could be ready for final disposal within 2-5 years at less than half the cost of the Army's $11 billion incineration program. Many of these technologies, unlike the Army's proposed incineration project, could be portable. This would allow for the technology to be transported and reused from site to site, eliminating the necessity and risks of transporting lethal chemical weapons through communities. Examples of such closed-loop technologies, currently in use by the private sector, are:
Chemical Neutralization: requires mixing chemicals with agent to break agent down into less toxic substances.
Researched and Developed by:
* Edgewood Research;
* Dr. Yu-Chu Yang at The US. Army Development and Engineering Center at Aberdeen Proving Ground (Maryland);
* Dr. Joseph Bunnett at the International Union of Pure and Applied Chemistry.
Cost: As a final disposal method, neutralization would be more cost effective than incineration. Researchers at Aberdeen roughly estimate that the Aberdeen stockpile could be neutralized at 20% of the cost of incineration.55
Implementation: A system could be demonstrated within two years, and in full operation within five years.
There is tremendous promise in areas of neutralization, and neutralization and biodegradation for all agents in the US stockpile.56 According to researchers at Edgewood, recent developments in chemical weapons neutralization show significant progress toward an alternative closed-loop solution. At Edgewood, a process as simple as mixing water 20 percent by volume with VX agent has been shown in bench scale experiments to neutralize the agent into a by-product with extremely low toxicity.57 This kind of work contradicts the Army's decade old argument that low technology, low temperature, and low pressure methods of disposal are inefficient and produce large volumes of hazardous waste by-products. With this method, for instance, 1,000 pounds of agent would produce 1,200 pounds of waste by-product. At JACADS, 1,000 pounds of agent incinerated is producing 6,100 pounds of waste by-product.58
Biodegradation: incubates chemical agent with bacteria or enzymes until it has been broken down biologically or chemically.
Research and developed by:
* University of Oregon Institute for a Sustainable Environment;
* Environmental Systems and Technologies (California);
* US. Army Chemical Research Developing and Engineering Center, Biotechnology Division (Maryland);
* Total Waste Management (Colorado).
Cost: 1990 estimates are that biodegradation costs are much less than costs for incineration. Dr. James Wild, Biology Professor at Texas A&M and National Research Council Chemical Weapons Stockpile Committee Member, is quoted in the Christian Science Monitoras saying, "We've calculated that the cost for a facility to degrade pollutants biologically is about $100,000. This is in sharp contrast to the $500 million to $800 million cost for state-of-the-art incinerators."59
Implementation: Currently being demonstrated at Edgewood.
Supercritical Water Oxidation: breaks down toxic chemicals by using moderate temperature water under high pressure.
Researched and developed by:
* Eco Waste Technologies (Texas);
* University of Texas, Austin;
* MODAR Modell Environmental (Massachusetts);
* US. Navy;
* Sandia Laboratories (New Mexico);
* General Atomics;
* Massachusetts Institute of Technology.
General Atomics estimates $1 million for a pilot facility, which is currently under construction. Total cost estimates are not yet available.
Implementation: Could be demonstrated within 2-4 years.
Molten Metals/Molten Salts : agent is passed into a large vessel containing a "bath" of molten irons/salts. As chemicals are fed through this "bath" chemical compounds are broken down to their basic elements. Gases are captured, reprocessed through the system and then recycled.
Researched and developed by:
* Hymelt (Ashland Petroleum Corp., Kentucky);
* Edgewood Arsenal (Maryland);
* Rockwell International;
* Molten Metal Technology (Massachusetts).
Cost: Estimates are significantly less than incineration. Envires, Inc., for instance, using the Hymelt technology, estimates that it would cost $50 million to clean up the residuals of reconfiguration at the
Bluegrass Army Depot in Kentucky.60
Implementation: This technology has over a twenty year history. Experimental units are already up and running.
Wet Air Oxidation: oxidizes chemical agent by air or oxygen under increased temperature and pressure.
Researched and developed by: Zimpro Passavant Environmental Systems, Inc.
Cost : The process has been described as "economical", but CWWG has not obtained any specific cost information.
Implementation: Research stretches back to 1981. Systems have been used to destroy pesticides and chemicals generated by the petrochemical and refinery industries. Demonstrable within 2-4 years.
Steam Gasification : evaporates and detoxifies chemical agent by mixing with steam.
Researched and developed by:
* Synthetica Technologies, Inc.;
* Sandia National Laboratories (New Mexico).
Cost : Synthetica projects the cost of destruction of the entire US. stockpile at $5 billion.
Implementation: Able to be completed in five years (1992 figures). An accelerated program could complete testing in three years.
Electrochemical Oxidation: uses nitric acid and silver solution in an electrochemical cell to oxidize and completely destroy chemical agent.
Researched and developed by:
* SubSea Offshore, Ltd. (Dounreay, Scotland);
* EO Systems, Inc., San Jose California.
Cost Approximate cost for US. stockpile is $4.5 billion.
Implementation: Proof-of-principle experiments have already been conducted on chemical agent in England by the British
Ministry of Defense. Demonstrable within 3 years.
1 Donna Heivilin. Letter to Togo West, Secretary
of the Army. General Accounting Office, National Security and
International Affairs Division, GAO/B-259497. January, 12, 1995
2 Ibid.
3 Ibid
4 Department of the Army, U. S. Chemical Demilitarization and Remediation Activity, Aberdeen Proving Ground, Maryland. Public Notice of Permit Modification for the JACADS Facility, January 3, 1995, p. 4.
5 US. House of Representatives, Defense Appropriations Committee. Report on Johnston Atoll
6 U. S. Environmental Protection Agency, Estimating Exposure to Dioxin-like Compounds [EPA/600/6-88/005B] Workshop Review Draft. EPA: Washington, DC. September 13, 1994.
7 United Engineers and Constructors. Results
of the Demonstration Test Burn for Thermal Destruction of Agent HD in
the Johnston Atoll Chemical Agent Disposal System Liquid Incinerator. United Engineers and Constructors Inc., Philadelphia, PA. February 1993, pp. 2-7 through 2-14.
8 Amy E. Smithson, The US. Chemical Weapons Destruction Program, Views, Analysis and Recommendations. Washington, DC: Henry L. Stimson Center. September, 1994.
9 Ibid.
10 Memo from William McFarland, Director of EPA's
Office of Health and Environmental Assessment, to Brian Grant, U. S.
Department of Justice, "WTI Screening Level Analysis," dated Feb. 8,
1993, attaching a 21-page risk assessment called "Screening Level
Analysis of Impacts From WTI Facility," dated Feb. 5, 1993.
11 "Army Confident of Safety. Small Amount of Nerve Agent Detected Outside Johnston Incinerator." Inside the Pentagon's Inside the Army. Vol. 7, No. 10, March 13, 1995.
12 National Research Council, Recommendations for the Disposal of Chemical Agents and Munitions. Washington, DC: National Academy Press. 1994.
13 Ibid.
14 Lee Davidson, "Like Sheep to the Slaughter?" Deseret News, May 30, 1993, p. B1.
15 Citizens Advisory Commission Meeting. March 14, 1995. East Alabama Regional Planning Commission Office, Anniston, Alabama.
16 Ibid.
17 Task Force on Scientific Aspects of the Destruction of Chemical Warfare Agents, Summary of Recommendations Adopted in Meetings Sept. 6-9, 1994, and the Problems They Address, Rome, Italy: International Union of Pure and Applied Chemistry, Sept. 1994, p. 4.
18 Ibid.
19 U. S. General Accounting Office. Chemical Weapon Stockpile: Army's Emergency Preparedness Program Has Been Slow to Achieve Results GAO/NSIAD-94-91. Washington, DC: General Accounting Office, February, 1994.
20 David R. Warren is the Associate Director,
Defense Management and NASA Issues, National Security and International
Affairs Division, Government Accounting Office. This statement is from
testimony, "Chemical Weapons Storage: Communities Are Not Prepared to
Respond to Emergencies," given before the Subcommittee on Environment,
Energy, and Natural Resources, Committee on Government Operations,
House of Representatives, July 16, 1993
21 General Accounting Office. Chemical Weapons Stockpile: Army's Emergency Preparedness Program has Been Slow to Achieve Results. GAO/NSIAD-94-91 Chemical Weapons Stockpile. Washington, DC: General Accounting Office, February 1994.
22 Ibid. p. 17.
23 The survey was conducted by Evelyn Yates, Director of Pine Bluff For Safe Disposal.
24 Siebenaler, et al. Evaluation of the JACADS Operational Verification Testing. National Research Council. Washington DC: National Academy Press. 1994. p. 55
25 Munro, Nancy B., et al., "Toxicity of the
Organophosphate Chemical Warfare Agents GA, GB, and VX; Implications
forPublic Protection." Journal of the National Institute of Environmental Health Studies.January, 1994. Volume 102, number 1.26 Dick Cockerel. "Chemical Weapons Plan Scares Some." Oregonian. October 23, 1994.
27 Memo by the Author to the Chemical Weapons Working Group, October 9, 1994.
28 The Mitre Corporation. Safety Assessment Report for the Tooele Facility. McLean, VA: Mitre, May 27, 1994.
29 Chronology of Jones events provided by his attorneys, Joanne Royce and Jeff Ruch of the Government Accountability Project.
30 John Thompson, "Safety Manager Blows Whistle on Chemical Burner," Tooele Transcript Bulletin, September 20, 1994, p. 1. See also Keith Schneider, "Inspector Cites Safety Issues, and Loses Job," The New York Times, September 27, 1994, p. 1.
31 U. S. Army. Safety Evaluation Report, Tooele Chemical Demilitarization Facility. Washington, DC: Army Safety Center. November 3, 1994.
32 Keith Schnieder, "Army Says Nerve Gas Incinerator in Utah is Safe," The New York Times. November 24, 1994.
33 Thomas W. Garrett, Memorandum for the
Assistant Secretary for the Environment, Safety and Occupational
Health, November 3, 1994, p. 3.
34 U. S. Army. Annual Status Report on the disposal of Lethal Chemical Weapons and Materiel. December, 1994, p. 12.
35 Macrae, Scott R., et al. Evaluation of the HD
Projectile Test: Johnston Atoll chemical Agent Disposal System
Operation Verification Testing. MTR-93W0000060. McLean, VA: Mitre, May
1993.
36 Excerpts from Memorandum to Chemical Weapons
Working Group from attorneys Mick Harrison and Richard Condit of
GreenLaw. March, 1995.
37 Government Accountability Project. "Army
Denies Access to Tooele Nerve Gas Incinerator Report; Whistle blower
Appeals to Make Inspector General's Findings Public." Press Release.
November 14, 1994.
38 EPA/Army Chemical Demilitarization meeting, Summary, April 12-13, 1994.
39 Tooele Transcript Bulletin. October 9, 1994.
40 J. A. Bradbury et. al, Community Viewpoints of the Chemical Stockpile Disposal Program.
Prepared for Science Applications International Corporation.
Washington, DC: Batelle Pacific Northwest Laboratories. November 1994.
Summary.
41 Ibid.
42 Office of Technology Assessment. Disposal of Chemical Weapons, Alternative Technologies. Washington, DC: Office of Technology Assessment. June, 1992.
43 Batelle, Op. cit.
44 "Incinerator Foes Favor Aberdeen Pilot Plant", Baltimore Sun, January 8, 1995.
45 Task Force on Scientific Aspects of the Destruction of Chemical Warfare Agents, Op. cit., Summary.
46 National Research Council. Alternative Technologies For the Destruction of Chemical Agents and Munitions. Washington, DC.: National Academy Press, 1993. pp.19-21.
47 Letter by the author to Charles R. Schindler, Board Member of the Kentucky Environmental Foundation, dated November 18, 1994.
48 David A. Koplow, "How Do We Get Rid of These Things?: Dismantling Excess Weapons While Protecting the Environment", Northwestern University Law Review. Northwestern University, School of Law. Vol. 89, No. 2 (Winter 1995), p 549.
49 Office of Technology Assessment, op. cit.
50 Joseph Bunnet was the chairman of the Task
Force on the Scientific Aspects of the Destruction of Chemical Warfare
Agents of the International Union of Pure and Applied Chemistry. He is
professor emeritus of chemistry at the University of California, Santa
Cruz. These remarks were made in a phone conversation March 19, 1995.
51Koplow, op. cit., p. 549.
52 B. A. Kuryk, et al.,M55 Rocket Separation Study, (M55-OD-8), Cambridge, MA: Arthur D. Little, Inc., November, 1985.
53 Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, National Research Council. Recommendations For the Disposal of Chemical Agents and Munitions. Washington, DC.: National Academy Press, 1994.
54 Senator Pryor, "Testimony before the Hearings for the Department of Defense Authorization for Fiscal Year 1995 (S. 2182)," Committee on Armed Services, United States Senate. Washington, DC: U. S. Government Printing Office, (S. Hrg. 103-765, Part 7), April 26, 1994, p. 186..
55 Steven P. Harvey and Joseph J. DeFrank.
Biodegradation of Chemical Warfare Agents: Demilitarization
Applications. Aberdeen Proving Ground, MD.: US. Army Edgewood Chemical
Research, Development and Engineering Center. 1994.
56 Bunnett, IUPAC, phone conversation, March19,1995.
57 Ibid.
58 Ibid. Confirmed by Matthew Methelsen, member
of the National Research Council's Alternatives Committee on the Jack
Anderson Radio talk show, March 22, 1995.
59Christian Science Monitor. February 2, 1995.
60 Phone conversation with Donald Malone, Chief Research Engineer, Ashland Petroleum Corporation, Kentucky, September, 1994.