Hermiston Herald
August 20, 2002

Army concludes analysis of risk assessment

By Frank Lockwood
Staff writer

HERMISTON - The Army has finished a defense of the UMCDF Quantitative Risk
Assessment Phase 1. Meanwhile, local emergency managers say they have yet to
receive a copy of QRA Phase 2, which the Army says is secret.

The review was done at the request of the state and in response to comments
by Texas risk analyst Jared Black, who had done an unfunded review of the
document. It is hard to tell who is right in the matter, but emergency
managers say the result is extra safety for residents and the environment.

Black had first argued there were weaknesses in the Phase 1 study, when he
wrote that:
· The Army's seismic (earthquake) risk is overstated
· The fault tree analysis gives no details on the processing risks
· No information is given on the relationship between the quantity of
chemical agent release and public health risk.

The Governor's office waited five months, but eventually took Black's
comments seriously enough to ask the Army to look into them, and the Army
did that. In an August 1 letter from Aberdeen, Maryland, PMCD's Delbert
Bunch thanked Governor John Kitzhaber for the "opportunity to address Dr.
Jared Black's assessment."

The Army had hired Science Applications International Corporation (SAIC) to
review some of Black's remarks. Black's initial assessment had reinforced
the view that continued storage of the chemical agent presents the greatest
risk to the community. Bunch wrote, "I wish to express my thanks to R.
Black," and, "The public will gain a better understanding of the risk
assessment process and the need to destroy these weapons as soon as
possible."

But beneath the diplomatic language lurked basic differences in approach,
and, a lack of communication between the major players. Black, in a July 30
e-mail correspondence with the Hermiston Herald, said SAIC had not consulted
with him, and that neither the new nor the old toxicity standards were
reliable.

"I've not been contacted by anyone other than (the activists) Craig Williams
and Karyn Jones, and that was some time ago," he wrote. "I've reviewed the
EPA AEGL reports on VX and the G series nerve agents and find them
surprisingly weak."

Following Black's initial review of the Phase 1 QRA, Black investigated
further, and ended up with more concerns, this time regarding the Acute
Exposure Guideline Levels (AEGLs) proposed by the U.S. Environmental
Protection Agency. The new guidelines are eventually expected to provide a
common standard for organizations responding to chemical accidents.

A technical review group, which includes Oregon and Washington officials, is
now reviewing AEGL information.

SAIC's technical response puts off arguments about the AEGLs for later, on
the one hand, and defends QRA Phase 1 on the other, citing alleged flaws in
Black's study. "It is not possible to determine if Dr. Black's source data
or analysis were completed with the same depth and rigor as that used in the
UMCDF (Army documents)," the response states. SAIC further criticized some
of Black's methods as "simplistic" and "without the degree of rigor" that
the Army had used.

Seismic Events: Much of the SAIC report is technical, with terminology such
as "ground motion attenuation relationships," and it includes complex
mathematical formulas that are given to demonstrate that the Army was right,
Black wrong, about seismic events. Other parts of the report seem clear
enough for the lay reader: "What is critical is that the public understands
that a severe earthquake, though very rare, could strike tomorrow."

Processing Risks risks not explicit in the report were assumed to be the
same as those in Tooele, SAIC says. And for many "initiating events" there
is no escape of agent to the environment. "Fault trees" are in the appendix.
Agent type, release quantity, release duration, release type [spill,
explosion, fire, etc.] and relevant consequence estimates for each sequence
are include in the3 draft Phase 2 QRA.

Black was traveling at the time the SAIC report came out, but said he will
look at the SAIC documents after he returns from his trip, which will be in
September. An August 5 letter from Black to William Sanders, US EPA's Office
Director, however, indicate Black's position at that time. He wrote, "The
people living near the facility are concerned about the safety of the
disposal process. ... Their concern is not misplaced."

While the Army's allowable toxicity levels, based on healthy male soldiers,
were too high for the general public, Black says that the EPA's figures are
biased in the other direction.

"I find the Public Draft reports provide very weak scientific support for
the proposed AEGLs; the recommended thresholds are strongly, even
unreasonably, biased toward low exposure levels. The result is that the
exposure levels used in the Army's Phase 1 QRA are placed in question by
equally questionable EPA results, leaving the public with no reliable way to
assess their own safety."

And SAIC's analysis said, "Black takes the simplistic approach that any even
involving a certain number of munitions results in an immediate and total
release of the agent contents of those munitions."

Whether that is true, and regardless who is right, emergency managers say
they are glad that, when in doubt, the EPA set lower exposure levels. In
cases where there was uncertainty, the EPA simply built in a greater factor
of safety, and that means more protection for the public, they say.

Morrow County Emergency Manager Casey Beard, however, told the Hermiston
Herald earlier this month that he had yet to see a copy of Army's updated
risk analysis, or QRA Phase 2, and that he needs that documentation in order
to ensure the safety of the community. Beard said he can qualify for any
level of security which the Army might require, but, "I need to see a copy
of that information."

[Frank Lockwood may be reached by telephone at (541) 567-6457, by
e-mail at flockwood@hermistonherald.com, or by U.S. mail at the Hermiston
Herald, P.O. Box 46, Hermiston, Oregon, 97838.]