2002: Army Concludes Analysis of risk assessment

Hermiston Herald
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 Governor's office waited five months, but eventually took Black's comments seriously enough to ask the Army to look into them, and the Army did that. In an August 1 letter from Aberdeen, Maryland, PMCD's Delbert Bunch thanked Governor John Kitzhaber for the "opportunity to address Dr. Jared Black's assessment."

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."

End
--------------------------

Appreciation: Article was preserved by iRazoo (http://www.irazoo.com/ViewSite.aspx?q=Hermiston+Herald&Page=1&irp=1&Site=http://www.cwwg.org/hh08.20.02b.html

Thank you iRazoo.

Chem Demil could lose $Millions (Columbia Basin Media article lifted from CWWG)

Author's note:  Chemical Weapons Working Group (CWWG) preserved this story on their web page at http://www.cwwg.org, on Dec. 19, 2005. Thank you to CWWG

-----------------------------

Story by F. Ellsworth Lockwood

The Pentagon has targeted new "alternative" chemical weapons programs for budget cuts, disappointing anti-incineration groups which view "alt-tech" as cleaner, safer, faster and cheaper than the present technologies.

Anti-incineration groups such as Chemical Weapons Working Group, GASP, Sierra Club and Oregon Wildlife Federation had hailed the new programs in Colorado and Kentucky as proof that the Army had now approved and accepted other methods of destruction besides so-called "baseline incineration" which they believe is dangerous to health and the environment. CWWG indicated the budget changes will eliminate disposal activities at sites important for demonstrating that alternative technologies are indeed viable.

The reports should be credible if the past is any indication: CWWG has at times been even better at projecting such things as cost overrides and scheduling changes than the Army's own press relations department. Pentagon documents showed that for 2006 the Pentagon is planning to allocate only $30 million for both Colorado and Kentucky, although those programs had been estimated to cost at $250 million or more. CWWG says completion of weapons disposal at Colorado and Kentucky would require $2 billion between 2006 and 2011, but that the Pentagon plans to cut funding for these programs down to a little more than $300 million for that time period.

Cuts of that size would likely halt alternative demolition of chemical weapons at storage sites in Richmond, Kentucky and Pueblo, Colorado. The Army apparently had the budget cutting plans before Christmas. Along with local, state and federal elected officials, the CWWG distributed a Pentagon decision document dated 21 December 2004, which referred to the possible delay of the program at both sites due to "external constraints the program must address." The same document is also being circulated in Colorado now. CWWG's Director, Craig Williams, denounced the planned cuts, calling them the Defense Department's “blatant disregard for the safety of tens of thousands of Americans due to extremely poor funding priorities.

The plans, if implemented, have international implications. "This funding approach makes compliance with the 2012 Chemical Weapons Convention deadline impossible, and is an admission by the United States that it is backing off its obligations regarding the Treaty," said Williams. Williams also questioned what he termed an Army “flip-flop” in regard to safety and security of communities living near the Kentucky stockpile. "Communities ... have been told for 20 years that the military will do whatever it takes to get rid of these weapons, because the risks (of continued storage) are so high,” Williams said, “And now that they (the Pentagon) are in a financial crunch we are being told that they have to let the weapons sit."

Williams also said that a 2002 classified report to Congress by the Secretary of the Army indicated Kentucky is considered to be the chemical weapons stockpile site at the highest risk for terrorism after 2007. Already, in 2004,the Pentagon pulled funds for chemical weapons disposal in Pueblo, Colorado, although Congress, fearing that the weapons sites could be terrorist targets, had requested the Army to accelerate the weapons disposal process, CWWG reported.

Pueblo resident and environmental activist Ross Vincent today said, "These funding cuts are a slap in the faces of our elected officials and the citizens of Colorado, who are working together for a safe disposal of these weapons. To the Pentagon we may be a number on a defense budget line item, but this is a real community facing real problems and risks."

Kentucky Senior Senator Mitch McConnell, in a prepared statement read by his representative at a press conference in Kentucky said, "The Department of Defense has an obligation to the citizens of Central Kentucky to dispose of chemical agents at the Blue Grass Army Depot in a safe and expeditious manner, and I will continue to devote my energy to ensuring that it lives up to that obligation."

Other presenters at Wednesday's press conference echoed the Senator's resolve, committing to fight for the funds necessary to move forward and not allow these weapons of mass destruction to languish in their community for another decade.

The cuts come twenty years after Congress ordered the U.S. Army to destroy its stockpile of obsolete chemical weapons, and at a time of concerns about terrorist threats. The Pentagon plans if implemented would cut funds for disposal of more than 3,134 tons of chemical weapons, according to CWWG, and this number represents 15 percent of the U.S. stockpile that remains to be destroyed.
.