Program Manager for Chemical Demilitarization
ATTN: SFAE-CD-P
Building E-4585
Aberdeen Proving Ground, MD 21010-4005
November 10, 2000
To Whom it May Concern,
On behalf of the Non-Stockpile Chemical Weapons Citizens Coalition
(Coalition) and the Chemical Weapons Working Group (CWWG), I am
submitting the following comments on the Mitretek Systems report,
Assessment of Using Stockpile Facilities to Process Selected
Non-Stockpile Chemical Materiel: Initial Screening. The Coalition
includes more than 47 grassroots organizations and individuals
in 22 states. The CWWG includes 32 U.S. and Pacific member groups
among the nine chemical weapons stockpile sites, and over 100
groups across the country who endorse our position on chemical
weapons disposal.
General Comments
1. The narrow scope of this report does not allow for any meaningful
discussion on the issue of future use of chemical weapons stockpile
facilities. It is unreasonable to expect community members to
separate the question of using the facilities for non-stockpile
materiel from use of the facilities for a wide range of other
military or industrial wastes. Therefore, these comments are not
limited to the scope of the report.
2. To the extent that Congress' intent with this report is to
identify cost savings, this proposal is not likely to save money.
Year after year, Congress, the General Accounting Office and other
consultants have raised concerns about the cost overruns which
plague the chemical demilitarization program. These concerns are
legitimate, and a number of suggestions have been offered on how
to manage costs, now including the suggestion to use stockpile
facilities for non-stockpile materiel disposal. As taxpayers,
we are in favor of cost efficiency in the chemical demilitarization
program. However, extending the life of facilities which are facing
skyrocketing expenses does not seem cost effective, particularly
for sites which house a significant and diverse number of non-stockpile
items.
We encourage Congress and the Army to heed the recommendations
laid out in the February 2000 Jefferson Solutions report and other
government agency reports, to seek cost savings by streamlining
Program Manager for Chemical Demilitarization (PMCD) management
and increase the level of transparency and public involvement
in the program.
Lastly, we offer that worker safety and protection of human health
and the environment, not cutting costs, should remain the priorities
of the chemical demilitarization program.
3. The issue of future use of stockpile facilities, as raised
in this report, provides an excellent opportunity for PMCD to
implement suggestions from the February 2000 Jefferson Solutions
report, which states that "greater public involvement and
dialogue could go a long way ....The Department of Defense and
the Congress, as appropriate...should take action to improve stakeholder
involvement and program transparency through use of an ACWA [Assembled
Chemical Weapons Assessment]-type public outreach model across
the chemical demilitarization program."
Specific Comments
1. The decision on whether or not to destroy non-stockpile materiel
at a chemical weapons stockpile disposal facility should be site-specific.
A programmatic decision could not reasonably take into account
the variance in non-stockpile materiel and public acceptance levels
that exist at each stockpile site. The viewpoints of the public
and state regulatory agencies at one site should not be assumed
true for others.
2. Incineration of chemical warfare materiel is unacceptable.
Incineration allows the release of toxic chemicals, including
live chemical warfare agents, out of the smokestack. In 1994 the
Army determined that burning the chemical agent lewisite - present
in some non-stockpile items - was too dangerous because of its
byproduct arsenic. This fact alone supports the argument that
incineration of non-stockpile materiel is unsafe.
The Mitretek report states that some non-stockpile materiel was
disposed through the Johnston Island incinerator (JACADS), implying
that this was done in a safe manner. No data is included in the
report to support this implication. Even if the incineration of
non-stockpile materiel in JACADS took place within EPA regulatory
limits, the process is still not safe, as these regulations allow
the release of known carcinogenic chemicals.
3. The Army should not assume that changes allowing for treatment
of non-stockpile materiel can safely be made through plant modifications.
In fact, experiences with plant modifications at the Army's Utah
incinerator show just the opposite. This plant has seen more than
500 permit modifications and 300 engineering changes since 1996.
The consequences of so many plant modifications may be an increase
in occupational risks to workers. A May 2000 report by incinerator
contractor EG&G stated that plant corrective actions and Engineering
Change Proposals can take up to a year to close out, if they are
closed out at all. A September 1999 Army review team noted that
standard operating procedures for the Utah incinerator are changed
so quickly and frequently (over 350 changes had been processed
at the writing of that report) that workers cannot keep up.
In addition, the May EG&G report and numerous plant whistleblowers
allege that the Army's "lessons learned" program is
not being implemented as intended; that lessons learned at one
incinerator are not necessarily being passed on, or implemented,
at other incinerators that are either operating or under construction.
Therefore, we are forced to assume that the problems experienced
at one incinerator will likely be experienced in others. Worker
safety and environmental protection should in no way be taken
for granted at these facilities, in their current or future forms.
4. Some stockpile community members may support disposal
of compatible non-stockpile items in a non-incineration disposal
facility. Public acceptability should also be measured for disposal
of items in a non-incineration facility, even for sites where
stockpile incinerators are in operation or under construction.
5. Allowing chemical weapons stockpile disposal facilities to
destroy a "small" amount of non-stockpile materiel now
could mean that larger amounts will be transported in later. Even
if the scope of this report is limited to destruction of non-stockpile
materiel that exists only at that site and even if the Army and
Congress' current intent is not to transport non-stockpile materiel
to stockpile facilities, community members and elected officials
at stockpile sites are fully aware that once a facility is permitted
to destroy non-stockpile materiel, keeping the gates shut to importation
will be difficult.
6. Public outreach and involvement relative to this report were
grossly inadequate. First, the "availability sessions"
on the report were poorly publicized, and offered no opportunity
for dialogue with Army decision makers. Community members at some
sites had only a few days' notice prior to the sessions. A briefing
to the Maryland Restoration Advisory Board was not publicly advertised.
Scheduling the Pine Bluff, Arkansas session was delayed so far
as to have been announced at the same time as the comment period
extension -- one day before the original comment period ended.
There is, reportedly, no public session scheduled for Newport,
Indiana. It appears that local outreach office staff had very
little, if any, control over logistical arrangements for the sessions.
Such a haphazard approach to gaining public feedback sends a message
to the public that their comments are not welcome at all. It is
this kind of public involvement facade which widens the gap of
mistrust between citizens and the Army.
To its credit, the Army's Non-Stockpile Chemical Materiel Program
made early efforts to inform citizens of this report, and lay
out an agreeable schedule to accept public input. Unfortunately
PMCD management did not follow through in good faith. For its
millions of dollars spent annually on public relations, PMCD has
in this case succeeded only in further marginalizing and confusing
the public.
7. This report should not in any way be interpreted as a disincentive
to development of safe, transportable technologies for non-stockpile
disposal. Development and use of transportable technologies are
inevitable, given the fact that non-stockpile materiel will continue
to be recovered for decades to come, and that few if any communities
with a "fixed facility" would support receiving and
disposing of chemical warfare materiel for that length of time.
Even if some stockpile sites agree to destroy their non-stockpile
waste in the stockpile disposal facility, putting time and resources
into transportable technologies now is a sound investment in future
waste non-stockpile materiel disposal efforts.
Thank you for your attention. We look forward to reviewing Phase
Two of the report, and welcome the opportunity to provide comments.
Sincerely,
[signed]
Elizabeth Crowe
Non-Stockpile Chemical Weapons Citizens Coalition
