Defense Environment Alert
July 1, 2003

GROUP BLASTS ARMY REFUSAL TO WRITE CONTINGENCY PLAN FOR ANNISTON

A citizens activist coalition is rebuking the Army's decision not to develop a contingency plan in case the chemical weapons incinerator in Anniston, AL, experiences significant operational failures. County officials in Alabama had requested the plan, but the Army last month dismissed the idea as unnecessary.

Chemical Weapons Working Group (CWWG) Executive Director Craig Williams wrote Army Assistant Secretary for Acquisition, Logistics & Technology Claude Bolton June 12, saying the Army's stated reasons for rejecting the request are marked by false information about the chemical demilitarization program and hollow reassurances that past chemical incidents won't be repeated.

The Army's response "smacks of the arrogant posture" the program has exhibited for the past 19 years, but one which CWWG thought was out of favor under Bolton's new authority over the program and with the creation of the Chemical Materials Agency, Williams says. "That posture is one of misplaced optimism coupled with an emphasis on
exaggerated successes while ignoring the true track record of the program and in particular, the baseline incineration technology."

The Calhoun County Commission, which had made the request, last week was continuing to discuss with Army depot officials safety issuesrelated to the startup of the incinerator. A county official told DefenseEnvironment Alert before a June 25 meeting with depot officials that the commission expects to have regular meetings with local Army officials to discuss all aspects of the incinerator's operation, especially as the Army gets closer to actually beginning incineration.

In May, the county officials asked Bolton to develop a plan that identified alternative treatment options for the Anniston stockpile, as well as cost and schedule analysis for deploying these options. These methods could be looked to in case the incinerator experienced prolonged shut-downs, as has occurred at similar facilities on Johnston Atoll and in Tooele, UT. At the same time, the commissioners were not asking for a contingency plan as a precondition to startup of the incinerator, although they hoped it could be developed quickly (Defense Environment Alert, June 3, p5).

But Army headquarters last month shot down the idea, saying a contingency plan was completely unnecessary. In a June 4 letter from Nancy Ray, acting Army deputy assistant secretary for the elimination of chemical weapons, the Army says it recognizes the commissioners' concern and desire for a contingency plan. "However, it is our position that such contingency is unnecessary and will not enhance protection of human health or the environment in the unlikely case of a system upset at the chemical weapons disposal facility," the letter says. The letter is available on InsideEPA. com. See page 2 for details.

Ray says that while she appreciates the benefits of contingency planning, the Army favors "directing our efforts toward optimizing the existing facility for the earliest possible disposal of the chemical weapons at Anniston." The Army has safely incinerated more than 25 percent of the agent and more than 39 percent of the total number of munitions in the nation's stockpile over the past 13 years. She acknowledges that both anticipated and unanticipated technical challenges have occurred at some of the operating weapons destruction facilities. "However, I can assure you that each of these challenges has been met successfully, and none has resulted in harm to human health or the environment."

But Williams refutes this last statement, noting for example that at least one worker involved in a 2002 incident at the Tooele, UT, facility continues to suffer serious health effects.

Ray goes on to say that regardless of the technology used, operating a chemical demilitarization facility is extremely complex, and problems have occurred even at the Army's bulk agent neutralization plant in Aberdeen, MD. "Most of the technical problems experienced at destruction facilities are independent of the agent treatment technology," and alternative technology plants "have not been demonstrated to operate any more safely than our existing incineration facilities."

The Army's operational experience with its incinerators on Johnston Atoll in the Pacific and at Tooele, UT, "has greatly enhanced our ability to predict and resolve the types of challenges that may arise at Anniston," Ray says. While there have been three chemical events since 1990 that "resulted in releases of very minute levels of agent," the Department of Health and Human Services determined that none resulted in adverse effect on human health or the environment. "Additionally, all release events have been effectively addressed by equipment redesigns, process and procedural modifications, and work force retraining."

But Williams cites outside reports from both the General Accounting Office and National Research Council that say the Army failed to have a system in place for program-wide applications of lessons learned from past incidents. "Reassurances that lessons learned will ensure that 'these types of incidents do not occur again' are hollow and patronizing," he says.

He also notes that the Army has in fact confirmed 18 agent releases, including those at the Chemical Munitions Disposal System facility in Utah starting in 1985, not just three as Ray claims.

According to Ray, retrofitting the Anniston facility with a non-incineration technology would be time consuming and would increase the risk of a storage-related incident. "The most optimistic schedule for a retrofit of an alternative technology at Anniston would be three years to redesign the system, obtain all necessary state and federal permits, and convert the facility to a new technology," she writes. "Another two years would be needed to rehire and train the workforce to use the new technology, which would be followed by a period of progressive systemization before processing can continue at full rate."

The Army has shown that it can restart operations in a timely manner without impeding the progress at a site, Ray says.

Williams, however, says Ray "inaccurately depicts the Commission's request for a contingency plan as a request for technology retrofit." And he questions her basis for the projected retrofit schedule, saying he knows of no study on the matter.

"It is the intention of the Commission's request to create a sound factual basis upon which to identify, not only the applicability of deploying such a plan under necessary circumstances, but also to create a data base of information to address issues such as redesign, permitting and conversion should it become necessary," he says.

Further, he refutes Ray's claim that restarting operations can be quickly done, given that facilities have been shut down for months at a time after incidents.

Williams urges Bolton to reconsider the request for a contingency plan for Anniston and other incineration sites. If the risk of storing chemical weapons continues to be a concern, "it is owed to the workers, citizens and elected officials of the host communities to have a back-up to rid ourselves of this risk should any one approach fail."