Solution for Safe Chemical Weapons Disposal
Review and Recommendations on the U.S.
Chemical Demilitarization Program
on the Tenth Anniversary of the
Chemical Weapons Convention
April 29, 2007
On April 29, 1997 an historic milestone occurred in the U.S. chemical
demilitarization program: the U.S. ratified the Chemical Weapons
Convention (CWC). The CWC is an international treaty mandating
worldwide chemical weapons disposal within ten years (or fifteen, if
nations asked for a five-year extension). The CWC applies to all
"declared" chemical weapons which for the U.S. meant the stockpile of
weapons stored at in the Pacific and eight continental sites:
Anniston, Alabama; Pine Bluff, Arkansas; Pueblo, Colorado; Newport,
Indiana; Kalama Island (Johnston Atoll) in the Pacific; Richmond,
Kentucky; Aberdeen, Maryland; Umatilla, Oregon; and Tooele, Utah .
The Chemical Weapons Working Group (CWWG) is a coalition of citizens
living near the U.S. and Pacific chemical weapons stockpile
sites. The group formed in 1991 in order to coordinate opposition
to incineration as the U.S. Army's technology of choice for weapons
disposal, and to promote safer solutions for weapons disposal as well
as direct citizen involvement in the chemical demilitarization
program. We were concerned that the dioxins, furans, PCBs, heavy
metals, and trace amounts of nerve agent emitted from incinerators as
part of routine operations would harm the communities' health and
environment. Upset conditions at incinerators were less
predictable and could mean larger release of toxics into the
environment. In 1994, the CWWG wrote and released the Citizens Solution for Safe Chemical
Weapons Disposal, which recommended
the immediate disassembly of rockets and projectiles, neutralization of
all chemical agents, and secondary waste treatment with
To many people living in the shadow of chemical weapons stockpiles,
there is no real separation between concerns about international
disarmament and protection of our health and the environment. The
success of the chemical demilitarization program depended not merely on
destroying the weapons, but doing so without destroying our
In 1997, the CWWG achieved a major victory for safe weapons disposal
when Congress mandated a program to identify, demonstrate and implement
non-incineration alternatives for chemical weapons disposal. The
program, called the Assembled Chemical Weapons Assessment (ACWA)
program consisted not only of detailed technology review but a national
dialogue process through which all program decisions -- such as
technology criteria, assessments and reports -- were made by
consensus. The program recommended neutralization as a
safe, viable means of chemical weapons destruction, with follow-up
biological and Supercritical Water Oxidation technologies.
Indiana, Maryland, Colorado and Kentucky sites were selected for
neutralization technology and non-incineration secondary treatment,
with full support from local citizens, state and federal government.
The ACWA program was a clear indication that community members, the
military and contractors could come together and agree how to move
forward in a win-win scenario from the standpoints of protection of
public health and the environment, as well as compliance with the
treaty and wise use of taxpayer dollars. However this positive
and cooperative spirit has not been shared throughout the Chemical
Materials Agency (CMA). Unfortunately the Army moved forward with
incineration of chemical weapons in Alabama, Arkansas, Oregon and Utah
over the protest of the CWWG and hundreds of organizations all over the
country. Myriad technical problems plague the chemical weapons
incinerators, conflict follows secondary waste disposal shipments,
chemical agent monitors are failing, and citizens have little
information on facility operations. The results are skyrocketing
costs and a failure to meet CWC deadlines.
Ironically, CMA's scapegoats for the cost escalations and schedule
delays are the sites with non-incineration technologies; design changes
and Pentagon funding cuts to Kentucky and Colorado's chemical weapons
disposal facilities will stretch the timeline for weapons disposal to
2023 -- 11 years after the CWC extended deadline.
The good news is that for each problem in the chemical demilitarization
program, there is a solution that can bring this program on
track. This paper brings to light some of the major challenges in
the program since ratification of the CWC ten years ago, and gives
specific recommendations through which these challenges can be
overcome, for the health and safety of our communities, and for the
ability of our government to be a leader in international chemical
The Army has not provided 'maximum
protection' at incinerator sites.
Fortunately there have been no chemical agent emissions-related deaths
at any chemical weapons incinerators. However the number and wide
range of incidents at each of the incinerators mirror the concerns
originally expressed by the CWWG. Since the first chemical
weapons incinerator on Kalama Island began operations, a stream of
whistleblowers, including high-ranking safety managers at the Utah
incinerator, have alleged that Army and contractors were covering-up
safety flaws in the facilities. A few of the most troubling are:
- MC-1 bomb incident in Utah. In March 1998,
while processing MC-1 bombs there was an overfeed of GB into the Metal
Parts Furnace resulting in an agent monitor in the stack alarming at
more than 500 times the allowable stack concentration (asc) of the
- Toxic exposures of workers at the Oregon
incinerator. In September 1999, 34 construction workers were overcome
by toxic vapors, which they believe to be some kind of warfare agent.
They claimed the Army ignored their symptoms and was negligent in
- Releases of GB from the Utah incinerator. In May
2000 the Army confirmed that from 11:30 pm May 8 to 1:00 am May 9, GB
was released from the deactivation furnace and out into the atmosphere,
with the peak concentration being 3.6 times greater than the asc.
- Workers' exposure in Utah. In July 2002, four
workers were exposed to GB in the liquid incinerator room, with one
worker showing clear signs of acute agent exposure.
- Improper monitoring procedures in Utah. In
2003 there was sworn testimony before a circuit judge in Oregon that
improper procedures have been used at chemical weapons facilities in
Utah that makes it likely that agent alarms will be discounted as false
- Nerve agent exposures in Alabama. In February
two workers were exposed to GB and the Army was finally forced to admit
that agent alarms had gone off in the medical building as well as the
weapons disposal facility.
- Nerve agent detected outside Alabama incinerator.
On March 1, 2004, monitors at the perimeter of the Anniston depot
confirmed the presence of VX and the Army was unable to determine the
source of the nerve agent.
- Fires where they are not supposed to be. In
Utah, Arkansas and Oregon there have been several fires outside the
furnaces in chutes into which chopped rockets are dropped and then
start blazing for reasons that have still not been determined.
- At total of 18 chemical agent releases have
occurred that CWWG can document; it is likely there have been many
Many of these incidents resulted in shutdown of the incinerators for
months at a time.
Major components of the incineration complexes, and the operation of
the incinerators, have been drastically altered over the years.
For example the furnace designed to burn dunnage (chemical weapon
related wastes such as protective suits and other agent-contaminated
items) was included in the blueprints of each incinerator though after
that particular furnace failed in Utah, the furnace was abandoned at
all the other sites. In Alabama, the Army proposed running
chemical munitions through a metal parts furnace at a rate much higher
than originally approved, even though that particular furnace was not
designed to handle whole munitions still filled with chemical
agent. It should also be noted that the projected operational
life for incinerator equipment is six years -- though due to technical
delays at the facilities incinerator operations will last years longer
than this threshold.
Several new problems have come to light, and it is unclear how the Army
will be able to address them. For example, mustard agent contains
levels of mercury so high that the Army is not able to process the
waste as it did when burning the nerve agents. Changes in the
incineration process in Utah (and, subsequently at the other
incinerators) include building some type of neutralization process into
the incinerator in order to water down the mercury. This process
will do nothing to prevent more mercury from being released into the
environment; it merely spreads the mercury emissions out over a longer
period of time.
Neutralization has proven to be safe
and effective, yet the Army betrays communities on secondary waste
In 2000, Indiana and Maryland abandoned incineration and instead used
neutralization to safely destroy the chemical agents. Maryland
completed mustard agent disposal operations in 2005, and neutralization
of nerve agent in Indiana is ongoing. The communities were
supportive of neutralization and on-site treatment of the
neutralization hydrolysates with non-incineration technology.
However in 2002, in an emotional reaction to the September 11 terrorist
attacks, the Army decided -- with no cost or schedule data to back up
their decision -- that it would be faster to abandon the hydrolysate
treatment on-site and instead ship the waste to an off-site waste
disposal facility. It quickly made arrangements with DuPont to
treat Maryland's mustard agent hydrolysate in its biological waste
facility in New Jersey. Few community members knew about the
The CWWG advised the Army numerous times to adhere to the original
plan. High-profile military waste shipments have often been rejected by
targeted communities after years of wasted time and taxpayer
dollars. Four five years CMA management tried, but failed to ship
the Indiana waste off-site, first to PermaFix in Dayton, Ohio and then
to DuPont in Salem County, New Jersey. Then on April 16th 2007
the Army began shipping the VX hydrolysate to Port Arthur, Texas after
secretly contracting with a hazardous waste incineration company there
and without informing the general public.
Opposition in Indiana, Texas and elsewhere is growing, with local
elected officials, concerned citizens and environmental justice groups
speaking out against the shipment. Home to dozens of oil
refineries, industrial chemical plants and waste disposal facilities as
well as a population that is nearly 80% people of color and around 25%
living under the poverty line, Port Arthur has been described by local
residents as a "poster child for environmental racism and injustice."
Meanwhile, workers in Indiana allege that nerve agent concentrations in
the hydrolysate are much higher than what the Army is publicly
reporting. New insider information indicates that since shipment
to Texas commenced, changes are being made to the neutralization
process that results in hydrolysate with higher
flammability. Citizens on both ends of the waste shipment
feel that their trust has been betrayed.
In Kentucky and Colorado, ACWA program officials, contractors, local
elected officials and community representatives are working together on
plans to ensure that neutralization of chemical weapons moves forward
safely and efficiently. As in Indiana and Maryland, the
Army has suggested off-site shipment of hydrolysate.
However the agency's own studies indicate that off-site shipment is
likely to cost millions of dollars more, and take years longer than if
the waste were destroyed on-site as currently planned. Local
officials and community members are adamantly against the shipment for
reasons including maintaining higher local employment, environmental
justice, and transportation risk.
Secrecy and information withholding is
pervasive in the Chemical Materials Agency.
In 1996 the Army opened public outreach offices at each chemical
weapons stockpile site in an attempt to show an effort toward open
communication with the public. To many local residents the
offices represented a sales pitch, with glossy brochures and models of
the incinerator but no process to involve or consult with citizens on
important decisions, or to troubleshoot when problems arise. As
incinerators began to go on-line, it became clear that information was
going to be harder to come by. Numerous CWWG requests to the Army
for information on incinerator operations, secondary waste disposal,
and on specific incinerator incidents remain unanswered even after
years have gone by.
Whistleblowers frequently reveal information about unsafe or fraudulent
facility operations and monitoring that would otherwise not be
known. Yet instead of dealing effectively with the problems the
Army tries to stifle and marginalize the employees. In one
instance, the Army allowed a criminal case to be fabricated, using
false evidence against a Utah worker thereby effectively facilitating
criminal prosecution as a vehicle to punish whistleblowers.
Army refuses to address monitoring
The Army's current monitoring system is woefully inadequate,
particularly at its incinerator sites, where chemical agent can be
released along with massive amounts of gaseous emissions through
smokestacks daily. Chemical agents can also be released from
places other than incinerator smokestacks, including ash bins; from
rooms that are not sealed; and during movement of weapons from storage
igloos to the disposal facility. Smokestack alarms can only be
calibrated to monitor one type of chemical agent at a time, they do not
fully identify chemical emissions. The effectiveness of perimeter
monitoring tubes outside chemical weapons disposal facilities is
extremely limited. The sporadic placement of these monitoring stations
means that a plume of chemical agent could be missed. There are
no alarms associated with perimeter monitors, and the monitoring tubes
outside of the facilities are collected every 8 - 12 hours.
Chemical agent monitors are the first line of defense against chemical
agent exposures, for depot employees and for nearby communities.
Millions of dollars have been spent on emergency preparedness planning
-- even protective hoods for people living within the 'kill zone' of
Alabama weapons incinerator -- that depends on accurate data in the
event of a chemical agent release. Yet even faced with the shortcomings
of its current monitoring system, the Army has consistently dismissed
the need for advanced monitoring systems.
Pentagon funding cuts cripple progress
toward CWC compliance.
In 2005 the CWWG revealed Pentagon plans to cut funding in Kentucky and
Colorado's chemical weapons disposal funding to the extent that
activities would grind to a halt. Prompt response from Congress
restored much of that funding, but more cuts quickly followed.
Now in 2007 the struggle for adequate funding of these sites' work
This annual budget tug-of-war is itself costly and inefficient, as
government contractors are forced to slow weapons disposal facility
construction, and spend countless hours re-designing the facilities to
attempt to save funds. In the end, the time spent trying to save
money is costing more money that originally anticipated, and is
significantly delaying the program. The Army and State Department
have tried half-heartedly to pass these delays off as related to the
lack of maturity of the neutralization-based technologies, but this is
not the case.
The consistent lack of funding shows that the Department of Defense
itself is demoting the importance of chemical demilitarization here in
the U.S., at the same time it is responsible for deploying soldiers and
hiring civilians overseas due to the "threat of weapons of mass
On the tenth anniversary of CWC ratification, and thirteen years after
the CWWG first released the Citizens'
Solution, we are making the
following recommendations to Congress and the Army -- both CMA and ACWA
-- in order to redirect the U.S. chemical demilitarization to more
closely comply with the CWC while providing maximum protection to
citizens and workers.
of all mustard agent munitions in Alabama, Arkansas, Oregon and Utah.
To date, the Army has not produced to the public a plan for how
incinerators will be able to destroy mustard agents with high mercury
concentrations. And in April 2007 a circuit court judge in Oregon
ruled that the Oregon state Environmental Quality Commission must
reassess whether or not incineration is the "best available technology"
for mustard agent disposal.
In August 2006 the CWWG released a report titled the Incinerator
Retrofit/Stand-Alone Neutralization Feasibility Study, a
how a chemical weapons incinerator could either be retrofit with, or
have a stand-alone, neutralization system for safe disposal of mustard
The Army can act now to move forward with neutralization of mustard
agent in a safe, expeditious manner. To do so could shave years
off of the chemical demilitarization schedule and save millions of
dollars. As a logical next step, Congress should demand that the
Army fill data gaps on the CWWG???s proposal and be prepared to shift
a 'plan B' approach for mustard agent disposal. Congress should
also commit to providing adequate funds to put neutralization of
mustard agent on a fast track, recognizing that investment now in safe
disposal process will save money in the long run.
funding of chemical demilitarization program, particularly to address
cuts in Colorado and Kentucky. At a time when homeland
security and reducing the global threat of weapons of mass destruction,
it is unconscionable that the Pentagon would actually cut funding to
weapons disposal here in the U.S.
Congress must work with citizens, local government officials, ACWA
management and technology vendors to pinpoint annual funding needs now,
and adhere to funding needs that are tied to the CWC deadline.
This would prevent the Army from using the CWC deadlines as an excuse
to cut corners on worker safety and environmental and health impacts.
disposal of chemical agent hydrolysate with safe, publicly acceptable
technology. Supercritical Water Oxidation (SCWO) was
approved by citizens and government alike as an environmentally sound
technology for destruction of nerve agent wastes in Indiana and
Kentucky. Bioremediation was selected for mustard agent wastes,
and is also broadly supported by legislators and the Pueblo, Colorado
The CWWG recommends that the Army immediately halt shipment of VX
hydrolysate from Indiana, and invest in and deploy treatment units such
as SCWO at the Newport facility to destroy hydrolysate. These
same units can also be used in Kentucky to destroy nerve and mustard
agent hydrolysate there. We also recommend that CMA and ACWA look
to the Non-Stockpile Chemical Materiel Project for guidance on how
communities can provide input -- early and often -- on waste disposal
issues beyond the hydrolysate.
4. Use of
advanced monitoring systems. Adding advanced chemical
agent monitoring systems to existing monitors, a much-needed layer of
protection would be provided to depot workers and community members.
The National Research Council has for 10 years advised the Army to use
improved monitoring systems, specifically recommending that the Army
utilize "real time" monitoring such as the Open-Path Fourier
Infrared (FTIR) Spectrometer. In 2004 Kentucky Senator Jim
Bunning appropriated $2 million toward an advanced monitoring system
for Kentucky. In 2005 the Army agreed to host a one-day forum on
monitoring that involved some community representatives, but has not
followed through with any actions.
We restate our recommendation that the Army invest in advanced
monitoring systems at all chemical weapons sites, to include real-time
infrared monitors surrounding weapons storage igloos as well as between
the disposal facilities and the perimeter of the depots. This can
be accomplished quickly and without impact to the weapons disposal
accountability and transparency through public involvement in the
chemical demilitarization decision-making process.
The success of the chemical demilitarization program depends on
transparency and trust. Neither of these is present in the
Chemical Materials Agency. In order to increase the regular flow
of accurate information to communities, and involve local citizens in
decisions that will affect their families, neighbors and the
environment, we urge Congress to mandate a national dialogue on
chemical weapons disposal, in the spirit of the successful ACWA
dialogue, or the Non-Stockpile Core Group. The investment in time
and resources to bring stakeholders together to discuss disposal
technologies, monitoring, worker safety, security and impediments to
full CWC compliance will pay off in greater efficiency in the overall
The CWWG believes that where citizens are encouraged and empowered,
solutions will follow. We support the goals of the CWC and are
prepared to work collaboratively with the Army and other government
agencies in order to bring a safe end to our nation's chemical