May 21, 2002
Governor John Kitzhaber
254 State Capitol
Salem OR 973 10

RE: Umatilla Chemical Weapons Incinerator

Dear Governor Kitzhaber,

With test bums at the Umatilla Chemical Weapons Depot scheduled to begin very soon, we are writing you today to share our concerns about this matter. As you well know, this is an enormously complex issue and you have some very important decisions before you in the coming days. We urge you to make the protection of Oregon's citizens and environment your highest priority in the decisions you make.

Based on the information we have received, we believe that incineration of these chemical weapons is not an advisable course of action and we are instead advocating that an alternative method of disposal be used. We recognize that, though it is potentially dangerous, incineration was chosen as the disposal method when these decisions were made several years ago because there may not have been workable alternative technologies. However, we believe that such technologies do now exist and are preferable for disposal of the stockpile at Umatilla, so the alternatives should now be revisited.

We will set out some of our specific reasons for that position below and in the enclosed document, but the shorthand version is that incineration is dangerous to both public health and to the environment. Alternatives, such as neutralization, would have fewer environmental impacts and would be less of a risk to workers and to surrounding communities. Furthermore, the Umatilla facility could easily be reconfigured for these safer alternatives and could even do the job quicker and cheaper. For these reasons, we can discern no good reason to proceed with incineration until all options have been considered.

You likely know that OSPIRG's Maureen Kirk and Rhett Lawrence met with Chris Dearth a few weeks ago to discuss Umatilla issues. Rhett provided Chris with documentation at that time that addresses many of the concerns we have about this matter and we trust Chris has shared some of that information with you. We are also enclosing for you a copy of a "Q&A" document prepared by one of our coalition partners on this issue, which addresses many of our concerns about incineration and illustrates the benefits of the alternative methods.

And even since OSPIRG's meeting with Chris, there have been daily news articles raising yet further flags, as you yourself have certainly seen (we are also enclosing copies of them for you). For instance, on May 16, we learn from the Tri-City Herald that the company that built and operates the Umatilla incinerator has been fined by federal regulators for serious violations of worker safety laws. This news is doubly disturbing given the stories out of Utah earlier this month concerning a whistleblower's allegations that workers and the local environment are being jeopardized by management practices at the Tooele facility (which served as the model for the Umatilla operation). On May 11, we read that FEMA and the Army are sniping at each other in front of Congressional committees, each raising doubts about the other's emergency response plans for chemical weapons stockpiles.

All of this new information simply serves to give us greater cause for concern and we hope they give you pause as you deliberate your decisions in this matter. It has become abundantly clear to us from recent events and from the new information available that incineration is not the safest way to dispose of these chemicals, and so we must look very closely at the alternatives.

You have probably been briefed or provided information on the major alternatives to incineration that the Army has identified, so we will not go into too many of those details here (though those details are explicated in the Q&A enclosure). Suffice it to say that the primary advantage the alternatives offer over the incineration approach is that they treat the chemical agents and other materials at a low temperature and low pressure and have the capability to analyze any material within the process prior to its being either further processed or released to the environment. Other advantages include the elimination of specific categories of air emissions (e.g., dioxins), the capability to manage by-products responsibly, reduced water consumption, and increased recycling capabilities.

The alternative technologies all have the capability to neutralize the chemical agents prior to treating of the byproducts. These by-products can then be treated onsite in a variety of environmentally sound ways, depending on which technology is used. The neutralization process is not "new" or "experimental." Indeed, the United States neutralized more chemical and mustard agent in a four-year period (10,000 tons between 1972-1976) than it has incinerated in a 12 year period (7,500 tons between 1990-2002). Neutralization is a well-understood and widely used process within the commercial sector that has a long history within the military of being applied to the materials stored in Umatilla.

Incineration, on the other hand, relies on a number of variables (temperature, pressure, mixture of waste and air, air flow, etc.) that eliminate any control over the agents once they are fed into the furnace. If any of these elements fail, an "upset condition" is created. During such conditions control over the agents is lost, resulting in the possible release directly to the environment via the smokestack. This is particularly problematic as the Environmental Protection Agency and the Centers for Disease Control have recently announced, based on new scientific studies, that the toxicity/lethality of the nerve agents GB and VX are considerably higher than previously thought when incineration is the chemical weapons disposal method (see Q&A Question 5). In addition, it is during upset conditions that the other extremely toxic by-products are released at significantly higher levels than during normal conditions.

These problems with incineration have led to at least 16 incidents during which actual chemical warfare agent has been released via the smokestack directly into the environment. In addition, significant complaints from dozens of whistleblowers have come forward since incineration began in 1990, raising safety and environmental issues, and indicating the Army's efforts to cover up these problems. Workers have been and continue to be exposed to chemical agents while the number of agent alarms per month at the Utah incinerator continues to increase.

Technical problems also continue to plague this technology, leading to an inability to process the number of weapons expected from the original design. When the Utah incinerator began operations in August of 1996, the Army predicted a six-month period to destroy the GB-filled rockets stored there, but that work wound up taking more than four years. Because of these types of problems, the incineration program at Umatilla, which was originally predicted to complete operations in approximately three years, is now predicted to take at least eight years to finish the job.

As you know, one of the major issues concerning the neutralization technology revolves around the amount of water it would require. However, it is a myth that incineration uses less water during processing than the alternative technologies. The Umatilla incinerator will use 260,000 gallons of process water per day to operate and none of this water will be recovered or recycled. The alternative technologies, on the other hand, use between 3,000 and 64,000 gallons per day with a recycling capability of between 50 and 95%, drastically reducing the water consumption over the operational period when compared to incineration. Specifically, according to leading Army chemists and the National Research Council, it would take 6.59 million gallons of water to neutralize all the mustard agent stored at Umatilla. To incinerate the same amount of mustard would take 84.2 Million gallons of water, or about 12 times as much as neutralization (see Q&A Questions 7 and 8).

No matter which method is used to destroy the Umatilla stockpile there will be material that is either released during processing (e.g., air emissions with incineration) or will have to be landfilled. The question then is how much of these end products are produced and how hazardous are they? The Q&A compares these factors between technologies, but the bottom line is that the alternative technologies measure up as superior in both categories. One alternative (Parsons) creates higher quantities of solid and air effluents than incineration, but this is a result of the biological secondary treatment process whose by-products are the least hazardous-of all the options. All other alternatives, when measured against incineration, produce less volume of "leftovers" with less toxicity than does incineration.

We also recognize that there is a risk to continuing to store the nation's stockpile of chemical weapons and we concur that the stockpile should be destroyed as quickly as possible. However, we disagree with the concept that continued storage is more dangerous than incineration of the stockpile. We also disagree that incineration is the fastest way to get rid of the risk. Studies show the stockpile is stable and the largest risk factor in the Umatilla stockpile was mitigated years ago.

The Army continues to tell stockpile communities that storage risk is much greater than the risk from incineration. However, we believe the risk assessment upon which the Army bases its defense of incineration is flawed and was crafted in such a way as to convince citizens that incineration was necessary due to the stockpile's rapidly deteriorating condition. In fact, the risk assessment cited by the Army does not include actual operational accidents during incineration in the analysis. Furthermore, the analysis does not include any health impacts as a result of operations (these are found only in the health risk assessment, which is not factored into the overall risk assessment). And unfortunately, the Army has declined repeated requests by citizen groups to do a risk assessment which compares incineration to the alternative technologies.

All of the alternative technologies are designed to fit into the "footprint" at the Umatilla facility. Permitting and retrofitting construction is projected to take 12-18 months and the cost of retrofitting would be expected to be between $40 and $50 Million. It is estimated that by using an alternative technology, operations at Umatilla could be shortened by about 3 years, saving taxpayers approximately $325 Million.

In sum, the advantages of using an alternative to incineration are: reducing potential agent releases, reducing toxic emissions, reducing water consumption, reducing landfill material, reducing operation time and cost, and putting an end to ongoing legal challenges. These are compelling reasons indeed to give meaningful consideration to the alternative technologies and we urge you to take a hard look at them as you make your decisions in the coming days.

In the short term, however, we also ask you to consider whether the emergency preparedness plans at Umatilla truly are adequate. Given the uncertainties coming out of D.C. in the last few weeks and all the other news breaking as we speak, we wonder if it is really possible to conclude that the Umatilla safety plans are sufficient. Again, it is important that the protection of Oregonians is the highest priority in these decisions, so we must proceed with extreme caution.

Thank you for your attention to this crucial issue and we look forward to continuing our conversations with you as this matter progresses. Please do not hesitate to contact us with any questions or concerns you may have.

Sincerely,

Rhett Lawrence
OSPIRG
[Oregon State Public Interest Research Group]

Jeff Allen
Oregon Environmental Council