Chemical Weapons Working Group
P.O. Box 467, Berea, Kentucky 40403
859-986-7565 859-986-2695 (F)
kefcwwg@cwwg.org
www.cwwg.org
September 7, 2005
Honorable Anthony J. Principi, Chairman
2005 Base Realignment and Closure Commission
2521 S. Clark St., Ste. 600
Arlington, VA 22202
Dear Chairman Principi and Commission Members:
Recently, the Base Realignment and Closure (BRAC) Commission announced its
recommendation that a study be conducted to assess a possible future for the
Deseret Chemical Depot if it were to remain open, which could allow the Tooele
incinerator to operate beyond its mission to destroy chemical weapons.
We are writing to oppose the use of chemical weapons incinerators for disposal
of any type of waste, including conventional munitions and other military
wastes.
When the U.S. Congress first directed the Army to destroy its stockpile
of chemical weapons, many residents at stockpile communities wanted the weapons
moved elsewhere for disposal. Soon, that option was rejected as impractical
and politically unfeasible.
Organizations such as the Chemical Weapons Working Group (CWWG) also felt
strongly that the solution to safe weapons elimination was to destroy the
weapons on-site where they were stored, with non-incineration technologies.
Our communities agreed to host weapons disposal facilities with the understanding
that these facilities would be dismantled after their mission was complete.
This is especially true for communities with incinerators, given the health
risks associated with ongoing emissions from burning chemical weapons and
other wastes.
Over the years, we were repeatedly told by the Army and Congress that the
facilities would be dismantled after demilitarization had been completed.
The 1994 Senate Defense Appropriations Committee Report states, "The Committee
continues its very strong opposition to any studies or exploration of the
possible future use of the chemical destruction facilities. This Committee
will not break faith with the communities that surround these sites by allowing
any study that may lead to any further use of these facilities."
In January 1991, the U.S. Army contracted with MITRE on a report titled
Engineering Analysis for Future Use of Chemical Agent Demilitarization Plants:
Feasibility and Desirability. In the report, MITRE concluded, “while
it is technically feasible to process most of the feedstocks considered in
the demilitarization facilities, in a majority of cases, it is undesirable
to do so.”
More recently, the promise given to our communities to tear down these plants
appears to have been forgotten by our government. In the2000 Defense
Authorization Act, Congress determined that state governments and the Army
could decide the fate or future use of chemical weapons disposal facilities.
Now, even though the endpoint of chemical weapons disposal is more than a
decade away, the BRAC Commission and a few Utah officials are entertaining
the idea of continuing operations at the Utah incinerator.
Burning chemical weapons is dangerous enough. Welcoming additional
waste into our state to be burned – as a direct or indirect result of BRAC
-- will add to the toxic threat we already face. Regardless of the specific
type of waste burned, future incinerator emissions would most certainly include
heavy metals, dioxins and other persistent, bioaccumulative toxics.
These toxins are harmful in minute amounts; there is no safe level of exposure.
To accept other wastes to these facilities would be to further sacrifice our
community’s health for short-lived economic gain.
In that regard, it is also important to realize that the Tooele incinerator
was designed with an operating life expectancy of five to seven years.
It has already been operating for nine years, with some officials predicting
it will last for seven more. Therefore, advocating for continued use
of this facility is not only risky from a public health standpoint, it is
a flawed business decision that could result in escalating costs.
Future use of chemical weapons incinerators for any type of military or
hazardous waste would further cement our state’s reputation as having a “dump
site” economy. We see when urban and rural communities become magnets
for toxic and waste industry, the health and vibrancy of those communities
suffers. Our state and local economies should be based on healthy,
sustainable industry and not that which continually depends on destruction
of hazardous weapons or wastes.
Elsewhere in the U.S. incinerators are being shut down and new ones rejected
in favor of better waste management and recycling techniques, and safer disposal
technologies that do not release uncontrolled amounts of toxics to the air,
water or land. Now is not the time for government to invest in incineration
for destruction of military and industrial waste; we should instead be investing
in technologies that can safely destroy existing wastes, and avoid creating
new waste streams.
Within the military, agencies such as the Non-Stockpile Chemical Materiel
Program are successfully using transportable non-incineration systems to destroy
explosive and non-explosive chemical munitions. These systems have
performed well, and are acceptable to state governments and local citizens
alike. The transportability features are particularly appealing to communities
who do not want to receive other wastes for destruction. Other non-incineration/non-combustion
technologies are available, or are in the research and demonstration phase,
to destroy explosives and conventional munitions that are not chemical-filled.
These are the types of systems and programs in which the government
should be investing. There is simply no need for future use of the
chemical weapons incinerators.
Those in chemical weapons stockpile communities who would accept extended
operations at chemical weapons incinerators do not represent citizens who
prioritize environmental protection or the health and safety of our future
generations. All over the world, citizens and governments are rejecting
incineration in favor of safe, protective, common sense approaches to waste
disposal. We ask that as you consider such impacts as part of BRAC decisions,
you reject options that would further endanger our communities, and instead
take opportunities to promote safe destruction of military wastes. Once
the chemical weapons stockpiles are destroyed, the plants should be shut
down, the site should be cleaned-up, and the promise made to us should be
kept.
Sincerely,
Jason Groenewold
HEAL Utah
Salt Lake City, Utah
Karyn Jones
GASP
Hermiston, Oregon
Rufus Kinney
Families Concerned About Nerve Gas Incineration
Anniston, Alabama
Evelyn Yates
Pine Bluff for Safe Disposal
Pine Bluff, Arkansas
Craig Williams
Chemical Weapons Working Group
Berea, Kentucky
