Defense Environment Alert

an exclusive biweekly report on defense policies for cleanup, compliance and pollution prevention

Vol. 15, No. 14

July 10 , 2007

ACTIVISTS CHALLENGE INCINERATION METHODS AT UMATILLA, TOOELE

Environmentalists opposed to the Army's practice of incinerating chemical weapons stockpiles are questioning various aspects of the incineration program in both Utah and Oregon, amid accusations of numerous violations of operating permits by the Army and its contractors at a facility at Umatilla. OR.

At the Umatilla site, local activist group GASP is challenging a decision by the Army to switch from burning the nerve agent GB to incinerating another nerve gas. VX, without first replacing carbon filters in the smoke stack. The filters are designed to capture any agent that may not have combusted completely, preventing it from escaping into the atmosphere. The Army announced July 8 that it had destroyed the last of the Umatilla site's GB agent earlier that day.

On June 22 the Oregon Department of Environmental Quality (DEQ) approved a permit modification request (PMR) from the Army to delete a requirement under the Army's existing operating permit that would have forced the replacement of the carbon in the Pollution Abatement Carbon Filter System (PFS). GASP questions this decision in comments submitted to the DEQ, which state: "GASP et al is very concerned about the potential impacts that could result if the carbon filters are not replaced between different agent campaigns. What will result from mixing GB, VX, heavy metals, dioxins, furans . . . and then collecting them in the PFS carbon?" Relevant documents are available on !nsideEPA.com. Seepage 2 for details.

GASP worries about what might result should there be a fire or other catastrophic incident at the incinerator, the comments say. The group is already involved in a legal dispute with the Army over plans to incinerate mustard agent containing high levels of mercury, in which a state court ordered the state Environmental Quality Commission to look again at its determinations regarding the best available technology for addressing the mercury contamination, effectively freezing the destruction program (Defense Environment Alert, May I. 2007, p15.)

Comments submitted by Morrow County, which neighbors Umatilla county, also express concern with the Army's PMR. "Morrow County does not agree with the proposed changes in the PMR. There appears to be a lack of supporting information that ensures the carbon absorption in the units will not be adversely affected by these changes," says the county in a letter submitted with its technical comments.

A source with the Oregon DEQ denies there is any risk inherent in not changing the carbon, as agent detectors in the smoke stack have never found any agent in the waste stream. Since the carbon does not contain any agent, the source argues, there is no need to change it out. The source points out that another chemical agent incineration site at Anniston, AL, does not require changing the carbon between campaigns, while the Tooele, UT, site does not even use the filters at all.

However, the source reveals that there have been at least 17 violations of permit terms at the Umatilla site in recent months, to which the DEQ has responded by lining the Army $284,000. While most of the violations were minor and reported by Army contractors working on the site, $100,000 of the total penalty imposed was for a failure to have an important safety feature known as an Automatic Waste Feed Cut-off in operation while agent was being processed.

An activist with the Chemical Weapons Working Group (CWWG), which opposes incineration of chemical weapons material, says the the failure to have a waste-feed cut off in operation "is a major infraction." "That is a primary requirement within the permit," says the source. The group harbors serious doubts about the efficacy of the agent detectors used in smoke stacks, and would like to see carbon filters in use at all sites, even if they too are not 100% effective, says the source.

Meanwhile, CWWG has submitted fresh comments on the Army's plans to incinerate mustard agent at Tooele containing high mercury levels, calling for a full environmental impact statement (EIS) under the National Environmental Policy Act (NEPA), going beyond the environmental assessment (EA) conducted by the Army.

In a document submitted in conjunction with the Healthy Environment Alliance of Utah and the Wasatch Clean Air Coalition, two local campaign groups, CWWG questions the Army's methods and assumptions. For example, CWWG asks for more information on how the Army arrived at its assumption that Sulfur Impregnated Carbon (SIC) filters will remove 90% of mercury in the exhaust stream. The group also calls for alternatives to incineration to be assessed, such as Super Critical Water Oxidation, Wet Air Oxidation and Gas-Phase Chemical Reduction.

Army sources have previously rejected arguments in favor of such technologies on sites slated to dispose of large volumes of chemical agent on the grounds of cost. The CWWG source says that the outcome of the mustard incineration campaign will be critical as "it will, we believe, be a precedent for other sites." Tooele would be the first site to incinerate mustard agent containing high mercury levels, and Army sources say it may serve as a model for Anniston, Umatilla, and Pine Bluff, AR. (Defense Environment Alert, May 29, 2007, p24.)