Witness testifies about alternative technologies

Hermiston Herald
Nov. 15, 2002
By Frank Lockwood (F. Ellsworth Lockwood)
Staff writer


An Army letter to Oregon's governor indicated the state could have saved four years by using alternative technologies to dispose of bulk mustard agent stored at Umatilla Chemical Depot, according to expert witness Daniel Cassidy.

Cassidy testified in the case brought by groups and individuals seeking to have UMCDF's permits revoked for allegedly covering up information or blocking available information which might have led the Army to select a different technology than incineration to destroy chemical weapons stored at Umatilla.

Bulk mustard makes up approximately 63 percent of the stockpile of chemical weapons stored at the Umatilla Chemical Depot. Umatilla Chemical Agent Disposal Facility is permitted to incinerate the bulk agent as well as assembled chemical weapons such as rockets and mines, but G.A.S.P., Sierra Club, Oregon Wildlife Federation, and 23 individuals, have sued the Department of Environmental Quality and the Environmental Quality Commission in an attempt to stop some or all incineration here.

Individuals involved in the suit have indicated that they believe their depositions will show that, in order to push incineration through, the state ignored available evidence of "best available technologies" and kept the public in the dark concerning dangers of incineration, by neither allowing them to cross examine experts under oath nor to formally challenge evidence offered to the DEQ during the permitting process.

Cassidy explained to the court the alternative technologies, including four which made it through the ACWA (Assembled Chemical Weapons Assessment) screening process as possible alternatives to the baseline, incineration, process which is planned for Umatilla Chemical Agent Disposal Facility.

Asked to describe Exhibit 42, Cassidy called it a proposal from the Army to the governor of Oregon, proposing to destroy the bulk mustard part of the stockpile at Umatilla by using neutralization, with the idea that neutralization would be four years quicker than incineration. Neutralization, Cassidy explained, does not mean, chemically, what some may infer.

Neutralization in chemistry takes place when one combines an acid and a base - they neutralize. The product has a neutral Ph factor, because the acid and base counteract one another. But the hydrolysis of agents, chemically, does not refer to that kind of neutralization. When Army experts speak of neutralizing chemical agent, they may mean instead that they are neutralizing the agent's immediate danger, or reducing the agent's immediate toxicity, often by using water and oxygen to break the compounds down into smaller, individual parts.

Although Cassidy testified for those suing the DEQ and the EQC, during the testimony several hurdles were mentioned for implementation of alternatives, some of which are as follows:

• Permitting, with the state could take as long as two to three years, although some argue it could be done more quickly.
• A NEPA, Environmental Protection Act, process would be required.
• Contracts would have to be let, which would take time.
• A "reactor" decomposition building for mustard would have to be built.
• A facility investigation would have to be done on the land where the facility would be sited.
• A Health Risk Assessment is required.
• Costs, and the length of time to put the system in place, must be considered.
• Reliability, proven track record, and long-term maintenance should be considered.
• There might be another group come along, worried about the risks of the new technologies.
• Additional questions have arisen about one of the alternative technologies, that of EcoLogic at the Blue Grass facility, due to problems in their demonstrations, problems indicated by "spikes" of carbon monoxide and hydrocarbons.
• New problems are likely to show up during "scale up," when the technology moves from a small, demonstration model, to a full scale project.
• According to National Research Council documents, no evidence shows that hold-test-release provides a higher level of safety than current continuous monitoring methods used by incineration for gaseous streams with low levels of contamination.

Advantages of Alternatives
On the other hand, Cassidy says, the above NRC statement about test-hold-release only holds true "under normal conditions." If something goes wrong in an incinerator, even with monitoring, emissions may escape through the stack.

Cassidy testified of many advantages of alternative technologies, some of which are the following:

•  Although both systems have stacks and vents for emissions, Cassidy said, "There is a big difference between a vent for a boiler ... and a vent for an incinerator ... the question is, what's coming out of those vents and stacks."
• Surprisingly, plans for plants at other sites have indicated that neutralization is likely to use five times less water than incineration.
• With alternative technologies, you can hold, test, and release effluents, whereas, with incineration, emissions may already be out the stack before operators realize something has gone wrong.
• Companies developing alternative technologies were able to analyze problem areas with incineration and ask themselves how they could find solutions in those areas.
• Four alternative technologies were able to meet the same "six nines" criterion as incineration (99.9999 percent destruction of the agent).
• With alternative technologies, dealing with gelled "heels" in mustard is said to be easy, whereas that created problems with incineration.
• The waste stream, the bi-product of neutralization is said to be no more or less toxic than many industrial waste streams.

Cassidy, an environmental engineer and a teacher of graduate classes at Western Michigan University, testified Nov. 1 before the Multnomah Circuit Court of the State of Oregon. The trial may go longer than was expected. Some participants had reported they hoped the trial would be over by Nov. 27, but apparently that may not happen, proponents from both sides in the case now say. After Nov. 27, the hearings will discontinue for a time, but will resume in March, 2003.

Frank Lockwood may be reached at 567-6457 or by e-mail at flockwood@hermistonherald.com.


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Top demilitarization officials visit Hermiston

Hermiston Herald
June 26, 2001
By Frank Lockwood (F. Ellsworth Lockwood)
Staff writer

HERMISTON - Top Army demilitarization officials met with local citizens and leaders at the PMCD Army Outreach Office Wednesday morning to give an update and answer questions on chemical weapons demilitarization.

Army representatives included: James Bacon, the nation's program manager for chemical demilitarization; Henry "Hank" Dubin, acting deputy assistant secretary of the Army; and Christopher Lesniak, program manager for chemical stockpile disposal. The Army officials had come to review the demilitarization project at Umatilla Chemical Depot and to meet with National Research Council representatives who held a quarterly meeting here last week.

Bacon said he felt good about the progress here, Lesniak praised the Oregon DEQ as a "tough task master" ("But that's okay. I'm glad they are."), and Dubin promised to work within state environmental laws and to observe all state safety standards. Dubin assumed his present position in 1999. He holds a number of degrees including a Ph.D. in Chemical Physics. His technical background is too long to include in this article, but includes teaching Symbolic Logic, developing experimental and mathematical simulation methods for evaluating small arms and fragmenting munition effects, and testing and evaluating target acquisition systems. He has served as chief of Intelligence and and Electronic Warfare Branch of the Army Materiel Systems Analysis Activity, and as technical director for Operational Test and Evaluation Command. Internationally, Dubin led the US Joint War-games for bilateral studies with Germany on mine combat and was a leader in a ten-nation NATO anti-artillery study.

To the communities near chemical demilitarization sites, the Army is required to provide maximum protection. Dubin defined maximum protection as "striving for no impact." "Maximum protection means we do the best we can do," he said. On the other hand, the Army standards are much higher than other countries and, "If we leave that stuff out there, that's not maximum protection," he said. "The standard that has been stated for countries is no more than one out of a one-hundred-thousand chance that someone would die, in a year, from being around the chemical destruction process. "In our country we have a much higher standard, and ... with the numbers that we are working to, it is less than one out of a million chance that someone would be affected by it health wise."

Mayor Linda Fox of Irrigon asked how they could protect a farmer out in the field on a tractor. "We are struggling with that as well," Dubin said, "but (maximum protection) doesn't mean you aren't going to take any chances." The Army's "very structured process" will eliminate things in the project that do not work, he said, but destroying the rockets is a first priority. "The strategy is to get rid of the munitions and agents that are the most dangerous first," he said. "We have got to take care of the rockets first. That's part of the national strategy. We really want to maximize public safety and minimize risk to health and the environment."

Before the meeting, Chuck Norris, a former depot commander and former state representative, reminisced with Lesniak about the days when the depot's monitoring system consisted of placing rabbits in the storage units. If the rabbits died, gas was presumed present. "Maybe we should go back to that system," Norris quipped. A strong supporter of incineration, Norris asked, "How many laws can the state throw in the way (of incineration)?" How long before the federal government stands up to the state, he asked. "Do you have the jurisdiction and, if so, when will the federal government exercise it?" he asked.

Dubin answered, "We have the authority but we are not willing to exercise it." Instead, he said, the Army officials have enjoyed the cooperation and support of communities and want to continue working with them. The Army is not going to try to "bulldoze over" the state, he added.

According to Bacon, the PMCD has three chemical demilitarization goals:

1. Protect public health and safeguard the environment
2. Eliminate the chemical weapons stored here rapidly and safely
3. Fulfill a larger, national goal to eliminate all chemical weapons and our ability to produce them

Utah has already destroyed 5,100 tons of chemical weapons, he said. "That's more than are stored here," he noted. Furthermore, Bacon said he had seen no indications in Congress of a change in attitudes toward funding for chemical demilitarization. Though spending a million dollars a year always requires justification, the Army will have "plenty of opportunity" to prove the necessity, he said. Barring unforeseen events, Bacon told the Hermiston Herald, incineration will take four years, once started.

That, in spite of testimony to the contrary, when Craig Williams testified before a senate appropriations subcommittee, predicting that the Army would run years behind schedule. On the contrary, lessons learned at Johnston Atoll and in Tooele, Utah, would help achieve the goal, Bacon said. "We don't expect to leave any chemical weapons behind," Bacon said.

Wearing Hermiston's signature lapel pin, which depicts a slice of watermelon, Bacon noted that he enjoyed coming to Hermiston but hoped next time it could be during watermelon season.


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Panel doesn't want incineration held up

Hermiston Herald

06/19/01

By Frank (F. Ellsworth) Lockwood
Staff writer

HERMISTON -- The Governor's Executive Review panel Tuesday discussed redefining or eliminating tough "showstopper" standards, rather than risking the delay of incineration of chemical weapons at Umatilla Chemical Agent Disposal Facility.

Showstoppers are issues that the ERP says absolutely must be resolved before incineration can begin. Most showstoppers have been resolved, but two remain: monitoring, and tactical radio communications.

The Governor's Executive Review Panel met at the National Guard Armory where they reviewed the "Second Interim Report on the Status of Protection for Communities Surrounding the Umatilla Chemical Depot (UMCD)." In a May 8 CSEPP exercise designed to evaluate emergency preparedness, the surrounding communities had passed seven performance measures but failed another eight. Five of the failures were due to the lack of monitoring equipment. The measures failed by default. Others were caused by "minor" issues, panel members said.

The two "key components" of having an adequate emergency program were showstoppers and performance measures. Now some panel members are questioning both of those. Performance measures were a tough, "all or nothing" evaluation. If one evaluator raised an issue at one location, the measure was assessed as failing at the entire exercise.

An "all or nothing, pass/fail scheme" might be inappropriate to use for deciding what is an "adequate program," the panel concluded. "Showstoppers" were questioned as well. According to earlier ERP agreements, emergency preparedness showstoppers, if not resolved, would hold up incineration of chemical weapons.

Umatilla County Commissioner Dennis Doherty suggested a more flexible standard at Tuesday's meeting, but not all agreed. Doherty is the Chemical Stockpile Emergency Preparedness Governing Board's president.

Panel History
The Hazardous Waste Storage and Treatment Permit for the Umatilla Chemical Agent Disposal Facility states that the governor of Oregon must decide that an adequate emergency response program is in place before incineration of chemical weapons can begin.

Gov. John Kitzhaber appointed the 20 representatives to the Executive Review Panel in May 2000 to advise him when an adequate emergency preparedness program is in place and fully operational at UMCD. The panel reported in December that progress was being made.

To track emergency preparedness progress, the panel created a "Master List of Deficiencies." They also rated some elements of readiness as "critical." However, items can be on the critical list without becoming showstoppers. Incineration might go ahead even with unresolved items on the critical list. Not so with showstoppers. The panel had agreed that showstoppers, were essential elements and, if not resolved, would nix a good report.

Most showstoppers have been resolved, but the two remaining unresolved showstoppers were: 1) a tactical radio systems and 2) chemical agent monitoring. Radio tactical communications is in early stages of negotiation for contracting. And monitoring is not in place. Although some equipment purchases have been approved, the agent monitoring concept and equipment have yet to be put in place. Because it provides early warning of agent, monitoring is considered a necessary component of decontamination, evacuation assistance, and reentry into restricted areas.

The review panel goal was to be able to tell the governor in November that emergency preparedness is adequate, but members now worry the showstopper standards will upset their timetable.

Showstoppers Disputed
As the emergency preparedness target date draws nearer, the panel is asking, "Who came up with that list of showstoppers in the first place?" They discussed whether a showstopper really must stop the show, with Doherty suggesting they forget about using the word or the concept of "showstoppers," altogether.

Doherty argued instead for a continuum of desirable readiness indicators, which would allow them to make a positive report to the governor, even if not all showstoppers are resolved. Others questioned whether they could redefine the term, showstopper.

But Wanda Munn, from the state of Washington, said the term "showstoppers" means just that. You stop everything if those issues are not resolved. If items are not really showstoppers, they should be removed from the showstopper list, she said.

DEQ's Wayne Thomas suggested taking a vote on whether or not to have showstoppers, but Armand Minthorn, representing the Confederated Tribes of the Umatilla Indian Reservation, cautioned against that. The panel decided to continue the discussion at the Aug. 23 meeting.

Target Date Doubted
Panel member Robert Flournoy said the panel would not be able to make a positive recommendation in November, based on the standards the panel had developed. A volley of exchanges over the issue took place between Flournoy and the moderator Wayne Thomas of the DEQ.

Thomas: Is there a possibility that we can be ready in November?
Flournoy: No. There are certain elements that are not going to be ready.
Thomas: Do we know that right now?
Flournoy: Do we know what?
Thomas: Do we know that we are not going to be ready in November.
Flournoy: From everything that I have been told absolutely we will not be ready.
Thomas: Is there a possibility that we could be ready in November?
Flournoy: Not when you take into consideration all of the elements ... (unintelligible) there are certain elements, no, we will not be ready. And I
think the governor should know. The community should have to know.
Thomas then told Flournoy, "We are facing it optimistically."
"I will be optimistic then," Flournoy said.

Munn, looking at a calendar, expressed doubts similar to Flournoy's. "I am a little concerned," she noted, about the "enormous achievements" that needed to be accomplished in order to give the governor a positive report in November.

Doherty compared the desired new tactical radio system to a new Cadillac. If the old system works, he said, it can serve for a while if necessary, rather than hold up incineration, just as the old Chevrolet gets one to and from work while waiting for the Cadillac to be delivered.

A recent $500,000 upgrade was done on the existing communications system, and Doherty says that system is adequate until a better one, using a 450 megahertz design, can be put in place. Doherty says CSEPP has its list of priorities on which they are working, so does the Army. When the Army is ready to burn, he says, he hopes the Executive Review Panel will agree that preparation is adequate. The real danger is from continued storage, not from incineration, Doherty said.