Hrmiston Herald
Dec. 6, 2002

NRC report draws mixed responses

By Frank Lockwood
Staff writer

HERMISTON - The the National Research Council's latest report evaluating
chemical weapons incineration brought swift disapproval from incineration
opponents, but was received well by local incineration proponents.

The NRC, as it has in several previous studies, concluded that incineration
of chemical weapons could be done safely, however, the scope of the study
was too narrow for some folks. The NRC refused to consider 10 incidents

Alabama's Calhoun County Commission had asked to have reviewed, and excluded
most of the items Chemical Weapons Working Group requested to have looked
into.

The report, titled Evaluating Chemical Events at Army Chemical Agent
Facilities, was motivated by Congressional concern that incidents at
chemical weapons incinerators at Johnston Island (JACADS) and Tooele, Utah
(TOCDF) might indicate "systemic" problems with safety, management, and
operations at those facilities, with implications for the weapons
incinerators in Umatilla and elsewhere.

Steve Meyers with the PMCD Outreach Office said, "I don't think there's
anything else out there that is so comprehensive and current." He added that
the study was "extremely interesting and relevant; one of the best NRC
reports I've ever read."

Not everyone was similarly pleased. Craig Williams of Chemical Weapons
Working Group denounced the study as a review of "carefully selected
information on the Army's incineration program which in no way represents
the real-life risks of the technology to workers and the public."

In part, Williams denounced the report because the NRC did not address most
of the 118 issues Williams had submitted for the NRC to consider. Fifty-five
were said to be "site masking alarms," most or all of which were probably
false positive ACAMS (Automatic Continuous Air Monitoring System) alarms.

Thirty of Williams items "bore no relationship to the committee's task," the
report said. Examples cited were "August 1, 1977 - Former Chief Safety
Officer Steve Jones is ruled for in his Department of Labor wrongful
termination action; Judge awards Jones his job back and $500,000 or no
rehiring and $1 million; Judge calls EG&G (the contractors) liars. Four of
Williams items related to storage and not to chemical demilitarization
operations, NRC determined.

Of the 118 items on the CWWG list, 17 were identifiable as being related to
incidents or events included on the PMCD list, and those 17 were considered
by the committee. Otherwise, the committee concluded that the majority of
the CWWG items were not germane to the task and that evaluation them would
not materially influence the findings.

Prominent among those findings was the conclusion, found in the Executive
Summary statement, that "Safe chemical weapons operations are feasible at
the new facilities (which are) scheduled to begin operating at Anniston,
Alabama; Umatilla, Oregon; and Pine Bluff, Ark."

But that conclusion was not without provisions. The underlying negative
implications were made explicit: Safe operations were said to be feasible if
certain other things happen.

• If management is diligent in setting and enforcing rigorous operational
  procedures.
  
• If management is diligent in providing comprehensive training.
  
• If management is in establishing a strong safety culture encompassing all
  plant personnel. Such a culture was not adequately established at UMCDF in
  September, as noted by an Army investigation of permit violations.
  
• If management is diligent in absorbing absorbing programmatic lessons
  learned from the first two operational facilities.

The report was not a comparison of incineration versus other methods, and
the study noted that many of its recommendations are applicable to all
demilitarization facilities, including those that may not use incineration.

Recommendation 1 (reduce the risk by eliminating the stockpile): The
destruction of aging chemical weapons should proceed as quickly as possible.

Recommendation 2 (defining chemical event): The Army should establish a
consistent set of criteria to be used by all chemical agent processing
facilities to ensure uniformity in the classification of events and to
facilitate event analysis and comparison.

The Army's local depot commander has the responsibility to decide whether an
upset or incident within the storage yard or at the demilitarization
facility is classified as a "chemical event," which suggests, the report
said, that some incidents which are classified as chemical events by one
commander might not be considered chemical events by another. Whatever the
commander does deem to be a chemical event is subject to strict reporting
procedures detailed in Army regulations.

Recommendation 3 (an informed public): The Army should continue its practice
of making available to the public the results of its quantitative risk
assessments for each demilitarization site. Without adequate risk
information available to the public, it will be difficult to develop or
maintain the level of public trust necessary for PMCD to accomplish its
mission.

Recommendation 4 (verifying the QRA in real life): The quantitative risk
assessment for each chemical demilitarization site should be "iterative,"
which was defined, in part, as using actual chemical events to test the
completeness of the quantitative risk assessments.

Recommendation 5 (false alarms): The Army should maintain conservative
chemical demilitarization stack and in-plant airborne agent exposure levels,
which was explained in part this way:

"The Army should not further reduce existing monitoring thresholds unless
chemical agent monitors can be made both more sensitive and more specific so
that lower thresholds can be instituted without significant increases in
false positive alarm rates or unless health risk assessments demonstrate
that lower thresholds are necessary to protect workers or the public."

The high rate of false positive alarms seems to be causing a "crying wolf"
mentality whereby some operational personnel tend to discount alarms until
they have been confirmed by laboratory analyses. PMCD must make it clear
that responding to alarms is more important than production.

Recommendation 6 (monitoring): The departments/agencies responsible should
make a coordinated effort to develop chemical agent monitors with improved
sensitivity, specificity, and time response, in order to reduce the rate of
false positive alarms.

Recommendation 7: Incident investigation teams should use modern
methodologies, employ experts in human performance, look for patterns in
failures, apply that information in lessons learned.
Recommendation 8: Utilize a programmatic lessons learned database that makes
information easier for the non-expert to find and use.

Recommendation 9: Program wide, use updated computer modeling such as the
D2-Puff (which is used at UMCDF).

Other recommendations: Other recommendations included making changes in
chemical event reporting processes, involving stakeholders in investigation
teams, establishing a "safety culture," and allowing a generous allotment of
time to training and retraining.

Frank Lockwood may be reached at 567-6457 or by e-mail at
flockwood@hermistonherald.com.