“Do As I Say – Not As I Do”
Comments to the NRC’s Briefing on Secondary Waste Issues Associated with the Chemical Weapons Demilitarization Program
July 26, 2007
by
Craig Williams, Director
Chemical Weapons Working Group

For over a decade the National Research Council (NRC) has, with little tangible result, urged the Army's Chemical Demilitarization Program to adopt a more proactive public involvement element in their mission. Some of the NRC's recommendations regarding public involvement -- in numerous publications over the years -- are noted at the end of my comments.

Interestingly enough, over that same period, citizen stakeholders from affected communities have requested a more active role in the undertakings of the Stockpile Committee and its various sub-committees.

When asked at a 2005 briefing on the NRC's monitoring report why there was no outreach for input during that project, the answer was that the communities were “notified” that such a study was going to take place.

Unfortunately, that is more than was provided by this present Committee regarding Secondary Waste issues associated with the de-mil program.

Over four years ago, the Chemical Weapons Working Group requested information from the Chemical Materials Agency regarding the quantity and type of secondary waste being shipped off site, in addition to the location of the reception sites and treatment processes being used to deal with this activity.  In spite of repeated requests and modified approaches of appealing for such information, none was forthcoming.

Now we discover that the current study has been underway for approximately 14 months and, with the exception of the Chairs of the Utah and Oregon CACs and the CTUIR, the general public was not even notified.

Interesting too is the fact that each time issues surrounding specific Army activities are raised by the public to a certain level of pressure and/or controversy, the NRC is tasked by the Army to have a look.  Almost without exception, the NRC then conducts its 'closed' meeting and has briefings provided almost exclusively to them by the Army or their contractors and generates a report endorsing the Army's actions.  A few examples are: the original preferred disposal technology (1984); Events Report (2001); Gelled Rocket Processing at ANCDF Report (2003); and Monitoring Report (2005)

Occasionally the NRC will make findings mildly critical of one aspect or another of the de-mil program, but more often than not the Army simply ignores these, cherry-picking those that approve of their overall operation, and go their merry way. 

By excluding citizen involvement almost entirely from their work (with the notable exception of the ACWA and Non-stockpile Programs) the NRC has diminished its credibility and is seen as a shill for the Army program.  This not only does a disservice to the citizens of this country, but to the National Academies and the NRC itself.
    

NRC Quotes on Public Involvement from Their Publications

Recommendations for the Disposal of Chemical Agents and Munitions, 1994:

• “The final selection of a technology or process should be made by considering the recommendations of the local citizenry as well as those of this committee. Effective mechanisms must be established to develop and communicate citizens’ concerns throughout the selection process, and thereafter in the operation of the facilities.” – p.83
• “[T]he Army should proactively seek out greater community involvement in decisions regarding the technology selection process, oversight of operations, and plans for decommissioning facilities.” – p.123
• “There must be a firmer and more visible commitment to engaging the public and addressing its concerns in the program” – p.124

Review of Systemization of the Tooele Chemical Agent Disposal Facility, 1996:

• “There must be a firmer and more visible commitment to engaging the public and addressing its concerns in the program” – p.101

Public Involvement and the Army Chemical Stockpile Disposal Program: Letter Report, 1996:

• “Public outreach is defined as a proactive approach for determining specific concerns in the communities at each stockpile location and for providing information in direct response to the concerns of individuals and groups.” – p.2
• “Public involvement is the process through which people who will be affected by or interested in a decision, and who have a stake in the outcome, get a chance to influence its content before it is made.” (emphasis added) --  p.2

Review and Evaluation of Alternative Technologies for Demilitarization of Assembled Chemical Weapons, 1999:

• “If the affected communities do not trust the Army or its contractors, even the best monitoring and testing technology will not allay public fears or generate public acceptance.” – p.290.

Assessment of Processing Gelled GB M55 Rockets at Anniston, 2003:

• “Over the course of the developments within the CSDP in the ensuing years, the importance of communicating with the public, and where possible, involving interested stakeholders in decision making on matters of local concern regarding the CSDP has been apparent.” – p.47

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