March 17, 2004

Mr. Kevin Flamm, Program Manager
Office for the Elimination of Chemical Weapons
Building E-4585 Parrish Road
Aberdeen Proving Ground, MD 21010-4005

Col. Jesse Barber, Program Manager
Alternative Technologies  and Approaches Project
Building E-4585 Parrish Road
Aberdeen Proving Ground, MD 21010-4005

Gentlemen,

As you know, the mission of the Chemical Weapons Working Group (CWWG) is to ensure the safe and expeditious disposal of the U.S. stockpile of chemical weapons, emphasizing direct involvement of citizens in the decision-making process.  We have, for the last decade, shown our ability to work with a wide range of community leaders, elected officials and many government agencies to identify and implement safe, efficient, and publicly acceptable solutions to the problem of how to destroy these lethal weapons.

Our scope and concerns also extend into the area of secondary waste treatment, and we are writing to make specific recommendations to you regarding the fate of the VX hydrolysate from Newport, Indiana.

Ever since the idea of off-site shipment of the VX hydrolysate was first raised, the CWWG has urged the Army to refrain from the ill-fated “Decide, Announce, Defend” approach, instead examining a range of treatment options and working with the public to identify the most acceptable path.  Unfortunately the Army has missed previous opportunities to address the VX hydrolysate disposal in this manner, and the issue continues to be mired in controversy.

The unfolding of events in Dayton, Ohio should have been a clear signal that the Army’s assumptions regarding commercial VX hydrolysate treatment were questionable.  Instead, you turned to the DuPont Chambersworks facility in New Jersey, and history seems to be repeating itself.  

In December 2003, more than a hundred citizens living near the Newport facility signed letters giving you clear, principled guidance on the issue of secondary waste disposal, highlighting the need for public involvement, serious consideration of on-site treatment, and prioritization of safety over schedule and cost.

Since then several CWWG leaders have reemphasized the need for the Army to “take a step back” and consider several options for treating the VX hydrolysate, and engage mechanisms for public involvement in technology and siting decisions.  Recently, the Keystone Center concisely summarized the sentiments of key environmental leaders in Delaware and New Jersey as a situation that is “non-negotiable”.  And, most notably, the citizens and a growing number of elected officials in Delaware, Pennsylvania and New Jersey have strong objections to commercial treatment of the hydrolysate there, including pending state legislation banning the shipment to New Jersey.  We respect and uphold the rights of these citizens and their elected officials to act in the best interests of their communities.

The following CWWG recommendations reflect our desire to carry out safe disposal of chemical weapons and public participation in the decision-making process; prevent unnecessary delays in the critical first-step VX neutralization process in Newport; and instill a precautionary approach regarding health and environmental impacts.

We recommend that the Army Alternative Technology and Approaches Project

1. develop a broader set of options for treatment of the VX hydrolysate, including the use of tank farms and on-site non-incineration treatment in Newport, as was originally planned and supported by local citizens, state regulators, and elected officials.  
2. provide for full technical review capability from experts agreed to by environmental leaders in any community where commercial treatment may be considered, before contracts are made.
3. convene an ad hoc dialogue on secondary waste treatment, fashioned after the ACWA model or the Non-Stockpile Core Group, as a means to establish open, transparent information exchange and credible communication with stakeholders.
4. re-shape the current public outreach program to one centered in public involvement in technology and transportation review, particularly if commercial treatment is to remain an option.

We believe these recommendations, will lead to safe, publicly acceptable solutions in a timely manner.  Without this “Plan B” approach, we believe that the Army’s credibility among communities will continue to erode, taxpayers dollars will be wasted, and the tremendous safety, cost and schedule advances made elsewhere under the CMA umbrella will be compromised.

The CWWG is willing to work cooperatively and pro actively with government and military decision makers and local citizens to identify these solutions.  We hope, in turn, that you will seriously consider these recommendations.  

 Sincerely,


Craig Williams
Chemical Weapons Working Group


attachments:
CWWG Statement on Secondary Waste
December 2003 letter to Col. Barber