• List of Attachments
• List of Acronyms

Comments on the Draft Programmatic Environmental Impact Statement
for Non-Stockpile Chemical Materiel Disposal

Introduction

The Non-Stockpile Chemical Weapons Citizens Coalition (NSCWCC , or Coalition) is a grassroots network of citizens living near non-stockpile chemical materiel sites, and local, state and national organizations promoting environmental justice and military accountability in waste clean- up. Coalition member and affiliate groups themselves have memberships of hundreds and thousands of citizens, and consist of networks of groups concerned with public health, veterans rights, and environmental justice.

In March 1998, comments to the Statement of Scope for the Programmatic Environmental Impact Statement (PEIS ) were submitted on behalf of the Chemical Weapons Working Group to the Non- Stockpile Chemical Materiel Program (NSCMP ). Key points made in our comments include: 1) that the reliance on incineration as a disposal technology is irrational; 2) that the PEIS would not provide any meaningful analysis of technologies, as required by law; 3) that the discussion of secondary waste treatment is inadequate. We also recommended that NSCMP use the PEIS to compare NSCMP's own disposal systems with other non-incineration technologies, as is required by the National Environmental Policy Act (NEPA ).

Now two years later we submit comments on the draft PEIS itself. The core recommendations in these comments are almost identical to those made to the PEIS Statement of Scope, and the Coalition has raised these issues consistently to NSCMP and government agencies since then.

We wholeheartedly support the safe remediation, storage and disposal of non-stockpile chemical materiel and to these ends, we advocate the involvement of affected communities in decisions regarding disposal of this materiel. We are committed to not only provide comment on what is contained in the PEIS, but also to propose a path forward which is acceptable to citizens who are informed on the non-stockpile issue. In this spirit, the "Citizens Alternative" to those disposal options stated in the PEIS is as follows:

1. Move forward with testing of the transportable disposal systems (the Rapid Response System (RRS ), Emergency Destruction System (EDS), and Munitions Management Device - 1 (MMD- 1)) provided that residual wastes from these systems are treated with a non-incineration, publicly acceptable technology. If such a technology is not currently available, store residual wastes until such a technology is available.

2. At the same time you test the transportable systems, continue to identify and assess the capability of other non-incineration technologies to treat non-stockpile materiel. Compare the transportable systems to these other technologies. Consider using systems which generate a lesser amount of waste.

3. Complete design work of "second generation" MMD and EDS systems, then compare these systems to other non-incineration technologies.

4. Ensure that communities affected by non-stockpile chemical materiel -- including those slated to process residual wastes -- are informed and involved in making decisions regarding weapons disposal.

5. To the extent you reject this alternative approach, we support the alternative set out in Section 3.3.1.1. of the PEIS ("Use of transportable treatment systems with the condition of storing neutralent and other wastes that require thermal treatment.").

General Comments

1. The Draft Programmatic Environmental Impact Statement (DPEIS ) is not really an evaluation of alternatives. The DPEIS only compares using the current treatment systems versus doing nothing until other treatment systems are developed. Of course, this is based on the incorrect assumption that there are no alternative treatment systems available.
   
   NEPA's regulations require that no action shall be taken before a Record of Decision is signed that may limit the choice or reasonable alternatives or have an adverse environmental impact (40 CFR 1506.1(a)). Despite this requirement, the PEIS is still a draft and NSCMP has spent millions of dollars building treatment systems which will soon begin live operations. If the Army had done a NEPA analysis before it committed millions of dollars on its treatment technologies in violation of NEPA, the Army would have had to compare all of the technologies on a level playing field. As it is, the Army has created a situation where it can only get one result, the one it wanted which is to go forward with its chosen treatment technologies .

2. The goals of NSCMP, as stated in the DPEIS, need to be reframed to reflect waste prevention. The Army states that "the purpose of the proposed Army action is to make available safe and cost- effective transportable treatment capability that can treat or repackage chemicals in non-stockpile chemical materiel items and produce waste products that can be handled and disposed of within the existing commercial hazardous waste treatment and disposal system in the United States." DPEIS at ES-2; 1-4. However, this purpose is contrary to a direct order from Congress. Congress has ordered the Army to, wherever feasible, reduce or eliminate the generation of hazardous waste (42 U.S.C. § 6902(b)). Therefore, the Army must redefine its purpose as making available transportable treatment capability that generates as little hazardous waste as possible. Furthermore, Congress has ordered that when the Army generates waste, it be treated, stored or disposed so as to minimize the present and future threat to the human health and the environment upon which it depends (42 U.S.C. § 6902(b)) . This Congressional mandated goal is completely different than the Army's stated goal of generating waste that can be treated and disposed of in existing commercial waste facilities, regardless of the danger those facilities pose.

Specific Comments

1. Because the DPEIS is programmatic and states in multiple places that site-specific information will be determined, NSCMP must prepare a site specific EA or EIS for Dugway Proving Ground and Deseret Chemical Depot, Utah, before beginning testing of the RRS and MMD-1.

2. NSCMP currently plans to incinerate "neutralent" from the RRS and MMD-1 -- neutralent which will contain the Lewisite by-product arsenic. In the Army's September 9, 1994 Environmental Assessment (EA) for Testing the Destruction of GA and Lewisite at Utah's Chemical Agent Munitions Disposal System, the Army concluded that it was too dangerous to burn Lewisite because a by-product of the burning would be the "highly toxic arsenic trioxide." The DPEIS acknowledges that "some of the lewisite combustion products (arsenic trichloride, arsenic trioxide, and vinyl chloride) are known to be human carcinogens" (p. ES-4). NSCMP's decision to burn arsenic seems contrary to protective public health measures.

3. The DPEIS should acknowledge that U.S. non-stockpile materiel is stored or was disposed of outside of the U.S. and its territories. (p. ES-3) Note that the NSCWCC supports the grassroots international movement for clean-up of wastes on U.S. military bases overseas. See Attachment 1.

4. The DPEIS completely fails to consider the environmental impacts of the disposal of the neutralent in the "Preferred Alternative" (see e.g. p. ES-8). These impacts must be considered regardless of what technology will be used to destroy neutralent.

5. The DPEIS states that no hazardous air pollutants would be emitted from the operating systems because of the filter systems incorporated into the design of the treatment system p. ES-8; Section 5.3.1.1). However, according to the RRS's Resource Conservation and Recovery Act (RCRA) permit, the MINICAMS only monitor for 70 percent of the Time Weighted Average (TWA) (RCRA permit at Att. 8, p. 18). Therefore, the PEIS should make the appropriate conservative assumption that the RRS will release 70 percent of the TWA of the chemical agents and industrial chemicals. The DPEIS should also look at the groundwater, ecological, terrestrial wetlands and aquatic impacts these air emissions will have.

6. The "effects on the natural environment" from the Preferred Alternative (p. ES-9) downplays the potential long-term effects from residual chemicals. This sentiment is repeated throughout the document. In fact, the long-term health effects of many chemical agents and industrial chemicals are unknown. Similarly, page ES-11 states "chemical warfare agents...are unlikely to represent chronic threats." However, a large body of literature regarding Gulf War veterans' exposure to chemical agents shows that even small amounts of chemical agents may have caused debilitating illnesses. NSCMP should, at the very least, acknowledge that chemical warfare agents may result in long-term/chronic health effects. See Attachment 2 .

7. The symbol for "upper risk group" appears to be missing in Table ES-3 on p. ES-10.

8. The DPEIS states on p. ES-12, and elsewhere in the document that in the event of a release of chemical agent, "the probability of exposure would still be small because of...contingency plans developed by the Army." NSCMP should state what kind of "plans" they are referring to, and how this would result in a lower risk probability.

9. In comparing the hazardous waste generated by the Preferred Alternative to the No-Action Alternative, the DPEIS fails to acknowledge that the Preferred Alternative will generate exponentially more hazardous waste than the No-Action Alternative (ES-18).

10. The DPEIS says that "[o]n a national basis, the quantity of hazardous waste estimated to be generated annually would represent a small to insignificant increase in the quantity of waste managed annually at commercial hazardous waste [Toxic Substance Disposal Facilities]" (ES-19). This statement, while true, is insulting. It is analogous to saying that it is acceptable for someone to commit murder because nationally thousands of people are murdered each year. Many citizens exposed to toxic emissions from hazardous waste and municipal waste incinerators all over the country suffer ill health as a possible result from these emissions. NSCMP should not assume that community members see any increase in waste shipped in to their communities as "insignificant." This statement should be removed from this page and anywhere else it appears in the document.

11. On p. 1-1, the DPEIS states that "[r]esearch and development on four such treatment systems has reached the point of maturity that compels the Army to decide whether it wants to complete development and make the systems available for deployment in the field" (p.1-1) . This statement is not true. The RRS and MMD-1 are built and permitted by the State of Utah. The RRS is supposedly scheduled to begin operations shortly. In fact, but for schedule delays, the RRS and MMD-1 would have both completed their first site before NSCMP released its DPEIS.

12. Recommend that information on the tent and foam system, being used at Aberdeen Proving Ground, be included in Section 1.9.2.

13. Section 1.10.3 should be changed to reflect the fact that the Program Manager for Chemical Demilitarization has signed contracts for the full operations of the Edgewood, MD and Newport, IN neutralization facilities for destruction of bulk mustard and nerve agents. That section should also reflect the fact that NSCMP is working with the Assembled Chemical Weapons Assessment (ACWA) program to evaluate the ACWA technologies applicability to NSCMP. Specifically the PEIS should discuss the Mitretek report and the Stone and Webster analysis of non-incineration disposal technologies.

14. Section 1.10.4 (p. 1-39) states there are no known technical limitations that prevent the effective destruction of unpackaged Chemical Agent Identification Sets (CAIS ) materials in commercial facilities (i.e. incinerators). However, as noted in comment #2, the Army in 1994 noted that burning arsenic would produce a "highly toxic" by-product.

15. Also in Section 1.10.4, note that the National Research Council (NRC ) report on treatment of Chemical Agent Identification Sets has been released.

16. On p. 2-33 the DPEIS states that MINICAMS monitors would be configured to detect numerous chemical agents and industrial chemicals. Does NSCMP mean to imply that these chemicals can be monitored simultaneously? That sentence should be clarified, and more detailed information on the monitoring system should be included in the document.
    
    NSCMP is strongly encouraged to use the most up-to-date, effective monitoring systems available. Note that the 1998 Annual Status Report for the Chemical Stockpile Disposal Program outlined several "advanced" monitoring systems such as an improved ACAMS systems, and an Atomic Emission Detector. In addition, community groups concerned with the chemical weapons incinerator in Tooele, Utah have approached the Army on the subject of installing infrared monitors for chemical agent detection. The U.S. government is currently using this advanced monitoring system to identify emissions from a waste incinerator located near a U.S. military base in Japan. See Attachment 3 .

17. The DPEIS states on p. 3-9 that "the on-site emergency operations centers would have access to computerized dispersion modeling systems." Note that the "D2PC" system used by the Chemical Stockpile Disposal Program to determine downwind plume pathways for chemical agents is old, inaccurate and has never been approved by the U.S. Environmental Protection Agency (EPA). If NSCMP intends to use D2PC for downwind plume modeling, it is strongly encouraged to use a more up to date, EPA approved system.

18. Table 3-3 on p. 3-22, and elsewhere in the document, states that trash and similar solid waste from site personnel's daily activities will be sent to a permitted solid waste landfill or municipal solid waste incinerator. NSCMP should require recycling of uncontaminated materials.

19. Regarding the disposal of wastes from the RRS, MMD and EDS as outlined in Tables 3-4 to 3-7 and elsewhere in the document, the disposal of hazardous wastes in commercial hazardous waste incinerators is unacceptable. As noted in comment #10, we believe that any amount of waste sent to an incinerator is too much, particularly when safer disposal methods are, or will soon be, available.
    
    The fact that a hazardous waste incinerator is permitted for operations is not proof that it is operating safely, or within state or federal guidelines. See Attachment 4. And, even if emissions from that particular facility are within "acceptable" limits, the cumulative emissions from other waste industry must be considered. For example, Federal Toxic Release Inventory (TRI) and Hazardous Air Pollution data for 1997 -- the most recent available -- shows that communities nearby commercial hazardous waste incinerators which may be contracted by NSCMP to receive wastes are already overburdened with toxic emissions. Total production-related wastes (including air and water emissions; cancer and non-cancer related chemicals) for Deer Park, Texas reached 1,246,938,188 pounds for that year. Tooele County, Utah's total was 284,695,885 pounds. Citizens in Sauget, Illinois were exposed to 65,480,752 pounds. The Environmental Defense Fund has calculated that each of these communities is in the top 10% of the most polluted counties in the U.S. Note that these figures only represent those industries which reported to the TRI, and only for the chemicals required. Needless to say, this already grim picture is incomplete; the pollution levels are likely much worse.
    
    Public opposition to waste incinerators of all kinds is well-documented, and continues to grow. Due to public opposition and inherent failures in the incineration technology, the incineration industry has suffered permit denials, shutdowns, and lawsuits. Citizens are demanding tighter, more stringent regulations and compliance laws. This applies not only to incinerators but to cement kilns and other combustion technologies. NSCMP is advised not to rely on this antiquated technology. See Attachment 4.
    
    NSCMP is not responsible for transforming the nation's hazardous waste industry, but it is responsible for protecting public health within the scope of its mission. Although NSCMP will have dispersed legal liability with this approach, given that incineration of non-stockpile related hazardous wastes would add to the level of hazardous emissions in communities already overburdened with harmful toxics, this approach is not protective of public health. A better solution to the waste problems is for NSCMP to decontaminate and reuse materials like protective suits; to reuse and recycle materials and industrial chemicals; and to dispose of neutralent wastes through a technology treatibility study or by non-incineration technologies.

20. Regarding Table 3-8, note a, a RCRA characterization of the waste should be done after the Utah tests with the full scale RRS and MMD-1.

21. Regarding Table 3-9, considering the stability of DIMP, has the Army done any study of a commercial hazardous waste incinerator's ability to achieve an acceptable destruction removal efficiency on this substance? Also reference previous comments on the incineration of arsenic.

22. Regarding Table 3-11, is the Army claiming that the lowest it can get its detection level for VX is 1 part per million?

23. Regarding Table 3-13, using an advanced technology to re-generate carbon filters rather than dispose of them could avoid 100 pounds of hazardous waste a day. Over the 40 year life span of the NSCMP, this could be quiet significant in terms of protection of human health and cost savings.

24. Section 3.2.1 (p. 3-45) regarding the No-Action Alternative, states that "Decisions to leave materiel buried or to exhume the materiel would continue to be made...with public comment and input." Note that on a site-specific level, based on the Precautionary Principle, informed community membersmay determine that the safest course of action in the short-term is to leave materiel in place. However, under no circumstances should such a recommendation be taken to support lack of clean-up efforts.

25. Regarding "Continued Storage of Currently Stored Materiel," (p. 3-45), NSCMP should be aware that former Army employee Anthony Flippo has alleged that non-stockpile chemical materiel currently stored at the Pine Bluff Arsenal poses a threat to workers and the public. See Attachment 5.

26. The argument in section 3.3.1.1. is devoid of merit. To begin with, there is no reason to believe that the neutralent would need to be stored for more than a year. A treatability study using non-incineration technologies, particularly those being evaluated in the Assembled Chemical Weapons Assessment, could easily be set up in a year.
    
    The NSCWCC is not aware of the Utah Department of Environmental Quality (DEQ) ever denying NSCMP a permit modification. There is no reason to think that DEQ would deny the storage permit in this case. What is the quantity of wastes currently being stored in Utah from the chemical weapons stockpile incinerator? The EPA would not be issuing this permit so the statement that USEPA might not grant the RCRA waiver is irrelevant.
    
    The NSCWCC does not advocate long-term, indefinite storage of hazardous wastes. However, operation of the RRS or MMD-1 outside of Utah will not happen until 2001, at the earliest. By that time, a commercial non-incineration facility could be fully permitted and operational.
    
    The DPEIS states on p. 3-49 that "Provisions of the Chemical Weapons Convention (CWC) also restrict the ability to store treatment wastes for a long period." As noted above, the wastes need not be stored for a "long period." While we fully acknowledge that the CWC imposes guidelines on NSCMP, short- to mid-term storage of neutralent wastes would be feasible as long as NSCMP states its intentions clearly to the Organization for the Prohibition of Chemical Weapons. The excuse that the storage sites would have to undergo inspection by the "Convention regime," and that these inspections "would be expensive to implement" is pointless. Each chemical weapons stockpile site -- including the Utah site, where wastes from RRS and MMD testing would be stored -- is already subject to CWC inspections. Additionally, the U.S. Congress ratified the CWC understanding that it would be responsible for the cost of treaty compliance. Unless the CWC mandates that NSCMP consider the cost of CWC compliance when evaluating alternatives in the PEIS, that statement should be removed from the document.
    
    Rather than making excuses, the PEIS should contain a detailed discussion about the advanced non-incineration technologies available to destroy the neutralent. The PEIS should contain the Mitretek evaluation of the ACWA technologies applicability to NSCMP neutralent and include the Mitretek evaluation in the appendix. The PEIS should go on to discuss data and findings from the current Stone and Webster technology evaluation. The PEIS should go on to compare these and other known non-incineration technologies to commercial incineration (40 C.F.R. 1502.14). The basis of this and any technology evaluation should be performance standards, rather than technology maturity.

27. In regards to Section 3.3.2.1, "Using Stockpile Disposal Facilities," note that the law prohibiting non-stockpile chemical materiel from being destroyed in stockpile facilities has been modified to allow such disposal with approval from affected states.
    
    Citizens living in chemical weapons stockpile sites, particularly those sites where incinerators are being constructed, have expressed considerable concern over this approach. The NSCWCC has consistently advised NSCMP to base technology decisions on performance standards. In the event that NSCMP considers using chemical stockpile incinerators for disposal of non-stockpile materiel, a comparison should be made between these incinerators and non- incineration technologies, using real performance from the Pacific and Utah incinerators (as opposed to trial burn data with surrogate chemicals), including data on hazardous waste generation and management. The Chemical Stockpile Disposal Program and its incinerator contractors should also be evaluated on plant operations and management.

28. In that same Section, the statement "Although the alternative technologies being considered by the Assembled Chemical Weapons Assessment Program may offer greater flexibility, the evaluation of the technologies does not include the potential processing and treatment of non- stockpile [chemical materiel]," should be removed in light of the aforementioned Mitretek and Stone & Webster evaluations/reports.

29. Concerning Section 3.3.2.3, "Commercial Treatment Facilities," refer to comment #19. Also refer to the 1999 National Research Council report on CAIS disposal, where it addresses commercial disposal options. Significant in the NRC report is the mention that some commercial disposal facilities approached by NSCMP have stated their reluctance to process CAIS if they would have to submit to a public outreach/involvement process. This does not speak well for the integrity of the management of these facilities.
    
    Also note that while the NSCWCC is opposed to commercial incineration, we have consistently stated that commercial non-incineration may be a viable option provided that thecommunity directly affected by such a facility was informed and involved in the decision-making process. Environmental Justice principles and the Precautionary Principle should be applied no matter what technology is being evaluated.

30. Section 4.6.1.2. states on p. 4-21 that NSCMP, when choosing commercial hazardous waste disposal facilities, considers factors including compliance history of the facility. An NSCMP audit should include information on the health of the community surrounding the facility, and cumulative emissions data for that area. If the affected community is determined to be primarily people of color or of low-income, NSCMP should apply Environmental Justice principles. Also note comments #19 and #29.

31. Section 4.14 refers to emergency planning committees. NSCMP is advised that local citizens are more inclined to have confidence in the effectiveness of a local emergency plan if they have been involved in the decision-making process early and often.

32. Sections 5-7 are so general in nature that making specific comments is difficult.

33. Regarding Section 5.3.6, beginning on p. 5-39, NSCMP is encouraged to reuse and recycle as much waste as possible.

34. The last paragraph on p. 5-46, concerning incineration of toxic organic compounds is misleading at best. Incineration is less a destruction technology than a dispersion technology. Incinerators can release dioxins, furans, PCBs, heavy metals and other products of incomplete combustion. A vast majority of incinerator emissions have not been identified, and therefore no health effects for these substances have been determined. Chemical weapons incinerators in Utah and the Pacific, touted as the "Rolls Royce" of incinerators, have released small amounts of chemical agent through the smokestack. See Attachment 6 .

35. In Section 5.3.12.3 and elsewhere in the document, regarding "Health and Safety Effects on Children," the DPEIS assumes that children are unlikely to be exposed to disproportionate risk from non-stockpile materiel disposal, and that NSCMP would "verify" this with site-specific analysis. The Executive Order on Children's Environmental Health and Safety calls on agencies to "identify and assess" health and safety risks to children, and to ensure that its policies address disproportionate risks. Rather than assuming, then defending the belief that children won't be disproportionately affected, NSCMP should follow the intent of the Order and simply state that it will seek to identify risk and prevent disproportionate health or safety impacts on children.

36. The Sections titled "Relationship Between Short-Term Uses of Man's Environment and the Maintenance and Enhancement of Long-Term Productivity" are unnecessary. The Sections contain information found several other places in the DPEIS.
    
    Furthermore, the tone of these sections is arrogant. In Section 5.8, NSCMP states that "short-term use of land and the occurrence of impacts" would "eliminate" future risks to public health and the environment from the materiel processed at that site. Section 7.8 states that the risk of long-term storage of materiel would "only end at some time in the future when the item would be treated...." This DPEIS does little to eliminate risks; rather risks are passed on from one community to another.
    
    Interestingly, these sections exemplify the major difference in the way the military/government and affected community members perceive clean-up issues. Risk is viewed by the military and regulators as something to be "managed" rather than reduced or removed. Terms such as 'safety' and 'maximum protection' are often defined by government and the military to reinforce their preferred course of action, often with little or no public input or involvement in decision-making. Facilities are permitted and regulated in isolation as if there are no other emission sources. Toxic chemicals with known health impacts are released at "acceptable" levels. Chemicals of which the health effects are unknown are treated as innocent unless proven guilty. The burden of proof of harm from toxic exposures rests with those suffering the health consequences.
    
    In compartmentalizing the issues of 'risk' and 'safety,' and fulfilling the low-bar legal and regulatory requirements, regarding non-stockpile materiel, NSCMP adopts quick-fix thinking to materiel disposal. It is that short-sightedness that resulted in the inappropriate "disposal" of non- stockpile materiel in the first place, and the fact that installation personnel, the Corps of Engineers, NSCMP and other agencies are now tasked with cleaning up the problem nationally.
    
    Many citizens in the U.S., including those members and affiliates of the NSCWCC, realize that the clean-up actions taken in one community, however small, affect countless others. The wastes exhumed and stored in one community may be neutralized in another, with residuals burned in another, with toxic liquid and ash residuals from that incinerator being landfilled or injected into the ground of another. The persistence and bioaccumulative nature of so many heavy metals and chemicals is such that people living far from a particular pollution source will feel its impact. Indigenous populations in the Arctic region, virtually isolated from commercial or industrial development, have high levels of PCBs and dioxins in their bodies. Pesticides in food grown on one coast of the U.S. are ingested by families thousands of miles away. Mothers exposed to persistent chemicals pass on the contaminants to their unborn fetuses, and infant children through breastmilk; another generation is unwillingly exposed to toxic contaminants.
    
    Solutions to non-stockpile materiel clean-up will not be found so long as NSCMP continues to play the hazardous waste shell game; transferring risks associated with hazardous waste from one community to another. Solutions are more likely to be found when the public is involved in making decisions which will affect their lives and livelihood, and when the military and government agencies implement plans focusing on reuse and recycling of materials and waste prevention, and choose technologies based on the Precautionary Principle and principles of Environmental Justice.

37. Appendix G is extremely hard to read. To begin with, it needs to be proofread as it has several grammatical errors and places where words are missing. In addition, its widespread use of the passive voice and long compound sentences make it difficult to understand. A professional writer should review Appendix G.

38. Table G-6 also has several inaccuracies. Gas Phase Chemical Reduction has done explosives treatment pursuant to DOE Contract No. DE-AR21-96MC33091. Gas Phase Chemical Reduction has also established that it is a transportable system as it has a commercial unit operating in Australia that was shipped there.

List of Attachments

Attachment 1:
Environmental Bill of Rights for Persons, Indigenous Peoples, Communities and Nations Hosting Foreign and Colonial Military Bases. October 1999.

Attachment 2:
Excerpts from Gulf War Veterans' Illness: VA, DoD Continue to Resist Strong Evidence Linking Toxic Causes to Chronic Health Effects. House Committee on Government Reform and Oversight. October 1997.

Excerpts from DoD Does Not Have a Strategy to Address Low-Level Exposures. General Accounting Office. September 1998.

Attachment 3 :
"U.S. raising ante on incineration issue," and "Navy official: Lawsuit may be needed at Atsugi." Pacific Stripes. Sunday, January 23, 2000 and Tuesday, January 25, 2000.

Attachment 4:
Memorandum from William Sanjour to David Bussard, "EPA's Regulation of Commercial Hazardous Waste Incinerators." October 8, 1992.

Rachel's Environment and Health Weekly issue 341,"Incineration: New Evidence of Danger." June 10, 1993.

Rachel's Environment and Health Weekly issues 206 ("Citizens Slow Growth of Incineration," November 7, 1990), 351 ("'Wall St. Journal' Warns Its Readers: Incinerators Are Financial Disasters," August 19, 1993) and 592 ("Incineration News," April 2, 1998).

Letter from Dow Chemical Company's Brian Delaney on recognizing "the trend away from incineration." May 18, 1999.

Attachment 5:
Affidavit of Anthony Flippo. (Supporting documents available upon request).

Attachment 6:
Technical Criteria for the Destruction of Stockpiled Persistent Organic Pollutants. Pat Costner. October 1998. (Chapter 1 and references only)

American People's Dioxin Report. Center for Health, Environment and Justice. November 4, 1999. (Technical Support Document available upon request)

Rachel's Environment and Health Weekly issue 560 "A New U.S. Waste Strategy Emerges." August 21, 1997.

Public Health and Chemical Weapons Incineration. Kentucky Environmental Foundation. March 1998.

"Tooele, Utah chemical weapons incinerator shutdowns, incidents and key developments, August 1996 - November 1999." Compiled by the Chemical Weapons Working Group.

List of Acronyms

ACWA - Assembled Chemical Weapons Assessment. Federal program to identify and demonstrate non-incineration technologies for the disposal of assembled chemical weapons.

CAIS - Chemical Agent Identification Sets. Used to train soldiers in chemical warfare.

CWC - Chemical Weapons Convention. International treaty calling for the disposal of the world's stockpile of chemical weapons. U.S. ratification of the CWC occurred in April 1997.

CWWG - Chemical Weapons Working Group. National grassroots network of citizens living near chemical weapons stockpile sites in the U.S. and Pacific.

DEQ - Department of Environmental Quality (i.e. the Utah Department of Environmental Quality). EDS - Emergency Destruction System. Technology developed by the Army and its contractors for destruction of small explosives non-stockpile chemical munitions.

EPA - Environmental Protection Agency

MMD-1 - Munitions Management Device-1. Technology developed by the Army and its contractors for destruction of small, unexplosive non-stockpile chemical weapons.

NEPA - National Environmental Policy Act

NSCMP - Non-Stockpile Chemical Materiel Program. U.S. Army program responsible for clean- up of non-stockpile chemical materiel.

NSCWCC - Non-Stockpile Chemical Weapons Citizens Coalition. National grassroots network of citizens living near non-stockpile sites, and organizations concerned with environmental justice and government/military accountability in the chemical weapons disposal program.

NRC - National Research Council

PEIS - Programmatic Environmental Impact Statement

RCRA - Resource Conservation and Recovery Act

RRS - Rapid Response System. Technology developed by the Army and its contractors for destruction of chemical agent identification sets.

TRI - Toxic Release Inventory

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