August 20, 2002
Army concludes analysis of risk assessment
By Frank Lockwood
Staff writer
HERMISTON - The Army has finished a defense of the UMCDF Quantitative Risk Assessment Phase 1. Meanwhile, local emergency managers say they have yet to receive a copy of QRA Phase 2, which the Army says is secret.
The review was done at the request of the state in response to comments by Texas risk analyst Jared Black who had done an unfunded review of the document. It is hard to tell who is right in the matter, but emergency managers say the result is extra safety for residents and the environment. Black had first argued there were weaknesses in the Phase 1 study, when he wrote that:
- The Army's seismic (earthquake) risk is overstated
- The fault tree analysis gives no details on the processing risks
- No information is given on the relationship between the quantity of
- chemical agent release and public health risk.
The Army had hired Science Applications International Corporation (SAIC) to review some of Black's remarks. Black's initial assessment had reinforced the view that continued storage of the chemical agent presents the greatest risk to the community. Bunch wrote, "I wish to express my thanks to R.Black," and, "The public will gain a better understanding of the risk assessment process and the need to destroy these weapons as soon as possible."
Beneath the diplomatic language lurked basic differences in approach and a lack of communication between the major players. Black, in a July 30 e-mail correspondence with the Hermiston Herald, said SAIC had not consulted with him, and that neither the new nor the old toxicity standards were reliable.
"I've not been contacted by anyone other than (the activists) Craig Williams and Karyn Jones, and that was some time ago," he wrote. "I've reviewed the EPA AEGL reports on VX and the G series nerve agents and find them surprisingly weak."
Following Black's initial review of the Phase 1 QRA, Black investigated further, and ended up with more concerns, this time regarding the Acute Exposure Guideline Levels (AEGLs) proposed by the U.S. Environmental Protection Agency. The new guidelines are eventually expected to provide a common standard for organizations responding to chemical accidents. A technical review group, which includes Oregon and Washington officials, is now reviewing AEGL information.
SAIC's technical response puts off arguments about the AEGLs for later, on the one hand, and defends QRA Phase 1 on the other, citing alleged flaws in Black's study. "It is not possible to determine if Dr. Black's source data or analysis were completed with the same depth and rigor as that used in the UMCDF (Army documents)," the response states. SAIC further criticized some of Black's methods as "simplistic" and "without the degree of rigor" that the Army had used.
Seismic Events: Much of the SAIC report is technical, with terminology such as "ground motion attenuation relationships," and it includes complex mathematical formulas that are given to demonstrate that the Army was right, Black wrong, about seismic events. Other parts of the report seem clear enough for the lay reader: "What is critical is that the public understands that a severe earthquake, though very rare, could strike tomorrow."
Processing Risks risks not explicit in the report were assumed to be the same as those in Tooele, SAIC says. And for many "initiating events" there is no escape of agent to the environment. "Fault trees" are in the appendix. Agent type, release quantity, release duration, release type [spill, explosion, fire, etc.] and relevant consequence estimates for each sequence are include in the3 draft Phase 2 QRA.
Black was traveling at the time the SAIC report came out, but said he will look at the SAIC documents after he returns from his trip, which will be in September. An August 5 letter from Black to William Sanders, US EPA's Office Director, however, indicate Black's position at that time. He wrote, "The people living near the facility are concerned about the safety of the disposal process. ... Their concern is not misplaced."
While the Army's allowable toxicity levels, based on healthy male soldiers, were too high for the general public, Black says that the EPA's figures are biased in the other direction.
"I find the Public Draft reports provide very weak scientific support for the proposed AEGLs; the recommended thresholds are strongly, even unreasonably, biased toward low exposure levels. The result is that the exposure levels used in the Army's Phase 1 QRA are placed in question by equally questionable EPA results, leaving the public with no reliable way to assess their own safety."
And SAIC's analysis said, "Black takes the simplistic approach that any even involving a certain number of munitions results in an immediate and total release of the agent contents of those munitions."
Whether that is true, and regardless who is right, emergency managers say they are glad that, when in doubt, the EPA set lower exposure levels. In cases where there was uncertainty, the EPA simply built in a greater factor of safety, and that means more protection for the public, they say.
Morrow County Emergency Manager Casey Beard, however, told the Hermiston Herald earlier this month that he had yet to see a copy of Army's updated risk analysis, or QRA Phase 2, and that he needs that documentation in order to ensure the safety of the community. Beard said he can qualify for any level of security which the Army might require, but, "I need to see a copy of that information."
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