Chemical Weapons Working Group
P.O. Box 467, Berea, Kentucky 40403
Phone: (859) 986-7565 Fax: (859)
986-2695
e-mail: craig@cwwg.org
web: www.cwwg.org
February 15, 2004
The Honorable Michael W. Wynne
Principle Deputy Undersecretary of Defense/
Acquisition, Technology and Logistics
3010 Defense Pentagon
Room 3E933
Washington, D. C. 20301-3010
Dear Mr. Secretary,
We, the undersigned, call upon you to order an immediate halt on operations
at the Anniston Chemical Demilitarization Facility (ANCDF), in light of the
serious pattern of events that have occurred since operations began on August
9, 2003. We are calling for initiation of a thorough investigation
on facility operations, and ask that steps be taken to correct identified
safety deficiencies before operations are resumed.
We also note a deplorable lack of consistent communication and flow of information
from ANCDF on incinerator operations, and we assert the need for an open,
transparent process for public involvement and dialogue on these issues.
Since the Anniston incinerator began burning chemical weapons last Summer,
there have been numerous unanticipated shut downs, technical problems, system
malfunctions and hundreds of chemical agent alarms. Plant managers have
inappropriately prioritized schedule considerations over safety. Their
decisions have resulted in increased worker risks, including the incident
on February 4, in which at least two workers were exposed to GB nerve agent
(sarin).
We are aware of multiple technical problems, process malfunctions, and “near
miss” incidents at the incinerator including, but not limited to:
heated discharge conveyor (HDC) breakdowns;
deactivation feed chute (DFS) jams;
buildup at the DFS kicker plate;
numerous agent alarms in areas not anticipated
to have agent present;
liquid incinerator (LIC) feed gun plugging;
inadequate training of workers;
blockage in agent lines leading to the agent
holding tank (AHT);
inadequate decontamination procedures for workers
after they leave “hot” areas;
workers being exposed to agents;
alarms triggered in the clinic after decontamination
procedures should have rendered workers “clean”; and
delayed notification of chemical events to the
Anniston Depot Emergency Operations Centers.
Many of these problems are not unique to the Anniston incinerator; the Army
has experienced identical problems at its first and second generation incinerators
in the Pacific and in Utah. Unfortunately, the Army routinely “cherry-picks”
safety and procedural recommendations rather than use its Lessons Learned
Program to address these chronic problems and systemic design flaws.
One prime example of this misguided approach to chemical weapons disposal
is the Army’s effort to increase throughput of “gelled” M55 rockets at the
Anniston incinerator. Management routinely places workers at additional
risk by violating the cardinal rule of limiting “hot” entries -- that is,
times when workers must perform activities in areas where chemical agent is
present -- to an absolute minimum during operations. The Army
has represented its incinerator as one designed to limit such dangerous activities.
However, procedures being used at the Anniston facility -- such as the one
resulting in the worker exposures on February 4 -- demonstrate the inability
of the technology to function safely, as advertised. The incinerators
were never designed to handle gelled rockets, and when management tries to
force the technology to function in this manner, workers are put at unnecessary,
unacceptable risk.
In its September 2003 report Assessment of Processing Gelled GB M55 Rockets
at Anniston, the National Research Council (NRC) cautiously endorsed the Army’s
plan to increase throughput rates of gelled M55 rockets. However, the
report also included specific recommendations critical to moving forward with
this activity. Many of these recommendations have been completely ignored
by the ANCDF management and the Army.
For example, the NRC recommended that during such operations, “The Army
is urged to analyze the stack gases for key metals and SOPC’s (Substances
of Potential Concern) more frequently than now is the practice.” This
has been ignored.
The NRC recommended that, “the full range of lessons learned from [the Army’s
Pacific and Utah chemical weapons incinerators’] experience should be carefully
communicated and incorporated into the design and operations...[at Anniston].”
Obviously this has not occurred, since many of the technical shortcomings
identified above were experienced at both the Pacific and Utah incinerators.
The NRC report further recommended that the Army should proceed with the
modified gelled rocket disposal plan, “with proactive attention to public
input.” In fact, just the opposite has occurred. There exists
no venue for such input in the Anniston community other than an occasional
public “briefing” sponsored by the Army at which ANCDF officials often do
not respond to specific and detailed questions about incinerator operations.
Another example of the Army “cherry-picking” is revealed in examining recommendations
from the General Accounting Office (GAO) in its September 2002 report
Lessons Learned Program Generally Effective but Could Be Improved and Expanded
(GAO-02-890). The report states that the “Lessons Learned Program does
not have formal procedures to test or validate whether a corrective action
has been effective in resolving a deficiency” and recommends that the Army
“develop procedures to validate, monitor, and prioritize the lessons learned
to ensure corrective actions fully address deficiencies identified as the
most significant.” Again, based on operational incidents at ANCDF, this has
yet to be implemented.
We believe there is a direct link between incidents at the Anniston incinerator
as described above, and the steadily decreasing flow of information on incinerator
operations to the community and the media. What information does come
from the facility has been later proven -- by community members and/or the
media -- to be incomplete and misleading, or a blatant fabrication.
For example, on February 4, 2004, the date of the most recent worker exposure
incident, the Army issued a press release which stated that “the situation
was limited within the confines of the ANCDF Munitions Demilitarization Building
(MDB)...the building that houses the facility’s three furnaces.” Only
after unnamed sources communicated to the media that alarms had also sounded
at the clinic, a completely separate building from the MDB, did citizens find
out the Army’s press release statement was false.
The next day, February 5, the Army issued another press release stating
that the “agent reading was not the result of rocket disposal operations.”
However, a week later it was reported -- only after repeated inquires
of ANCDF management from local media -- that the workers were indeed performing
activities directly associated with processing “gelled” rockets at the incinerator.
That same press release also stated that “employees were never ‘threatened,’”
but after a week of investigation by and repeated inquires from local media,
and confronted by information from anonymous sources, the Army finally admitted
that at least two workers had been contaminated with GB nerve agent.
The language used by ANCDF management in describing events at the incinerator
are inconsistent and misleading, and significantly downplay the serious nature
of incidents. For example, they use terms such as “maintenance”
inferring anticipated and/or routine activities when in fact this “maintenance”
relates directly to unanticipated malfunctions and unplanned worker “hot”
entries. These are not merely “maintenance” activities - they are breakdowns
of a serious nature, and indicate serious chronic problems at the facility.
In using such language to describe incinerator incidents, we believe ANCDF
management is far more interested in maintaining a positive image of plant
operations than it is representing the truth about the reliability and capability
of the facility to operate safely. This kind of “spin” further undermines
what faith community members had in the Army to tell them the truth about
the problems at the incinerator, and the risks to their families and workers
at the facility.
According to a professional survey conducted in 2002 under contract by the
Army, over 40% of the population surrounding the ANCDF felt it unlikely that
the Army would inform the public about problems with the disposal effort.
In light of the recent events at ANCDF, and the fact that more accurate information
only surfaces after extensive investigative efforts by the media or citizens
and/or is brought to light by anonymous sources within the facility, that
percentage is almost certainly on the rise.
To sum, the operational history at ANCDF, although brief when measured against
its 10+ years of anticipated operations, indicates serious technical problems
which, if left unaddressed, will likely lead to serious consequences for the
workers and the community. Comparing ANCDF operations thus far with
the Congressional mandate for the Army to provide “maximum protection” to
workers and the surrounding community, we believe the Army has fallen far
short of the mark.
Therefore, we urge you to act immediately, in accordance with your authority,
to direct that operations at the ANCDF cease until such time as: the technical
issues raised herein are investigated and corrected; the recommendations raised
herein be implemented; and, until processes are put in place to allow the
public an opportunity for open, consistent dialogue with the Army on these
issues.
Sincerely, on behalf of himself and those listed, with their permission,
Craig Williams
Executive Director
Chemical Weapons Working Group
Berea, Kentucky
Rufus Kinney
Director
Families Concerned About Nerve Gas Incineration
Anniston, Alabama
David Christian,
Director
Serving Alabama's Future Environment
Anniston, Alabama
Dr. N.Q. Reynolds
President
Calhoun County Chapter
Southern Christian Leadership Conference
Anniston, Alabama
Rev. Henry Sterling
Alabama Chapter
Southern Christian Leadership Conference
Anniston, Alabama
Jeanette Champion,
President
Citizens for Environmental Justice
Jacksonville, Alabama
Neil Milligan
Chapter Chair
Alabama Chapter of the Sierra Club
Montgomery, Alabama
Lamar Marshall
President
Wild South, Inc.
Moulton, Alabama
Bryan Burgess
Executive Director
Friends of Rural Alabama, Inc.
Ashville, Alabama
Michael Smith
Chairman
Friends of Terrapin Creek
Piedmont, Alabama
Jayme Hill
Executive Director
Alabama Environmental Council
Birmingham, Alabama
Ms. Bobbie Paul
Women's Actions for New Directions
Atlanta, Georgia
Matt Reid
Executive Director
Coosa River Basin Initiative
Rome, Georgia
Robert K. Musil, PhD., M.P.H.
Executive Director and CEO
Physicians for Social Responsibility
Washington, D.C.
Robert O. Muller,
President
Vietnam Veterans of America Foundation
Washington, D.C.
Louis Clark, Esq.
Executive Director
Government Accountability Project
Washington, D.C.
Peter Montague, PhD
Executive Director
Environmental Research Foundation
New Brunswick, New Jersey
David Ludder, Esq.
Lead Counsel
Legal Environmental Assistance Foundation
Tallahassee, Florida
Rev. Pamela Cheney
United Church of Christ
Justice and Peace Action Network
Cleveland, Ohio
Tara Thornton
Chief Executive Officer
Military Toxics Project
Lewiston, Maine
cc:
Dale Klein, ASD (NC&B)
Patrick Wakefield DASD ( CD&TR)
Claude Bolton, ASA (A&T)
Mike Parker, Director, CMA
Kevin Flamm, PM, ECW
Sentaor Richard Shelby
Senator Jeff Sessions
Senator John Warner
Senator Carl Levin
Senator Ted Stevens
Representative Mike Rogers
Representative Duncan Hunter
Representative Ike Skelton
Representative Jim Saxton
Representative Martin Meehan
Representative Jerry Lewis
Representative John Murtha
Tim Garrett, PM/ANCDF
