NATIONAL RESEARCH COUNCIL COMMENTARY ON THE ARMY CHEMICAL STOCKPILE DISPOSAL PROGRAM
David S. Kosson, Ph.D.
Previous Chair of the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program
National Research Council
National Academy of Sciences
Chair of Department of Civil and Environmental Engineering
Professor of Civil and Environmental Engineering
Professor of Chemical Engineering
Subcommittee on Military Procurement
Committee on Armed Services
U.S. House of Representatives
September 21, 2000
Good morning, Mr. Chairman and members of the Subcommittee. Thank you for inviting me to speak with you today. I am Dr. David Kosson and am a Professor and Chairman of the Department of Civil and Environmental Engineering at Vanderbilt University. I am also a Professor of Chemical Engineering at Vanderbilt. From 1993 through July of this year, I served as a member of the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, known as the Stockpile Committee, for the National Research Council. The National Research Council is the operating arm of the National Academies, chartered by Congress in 1863 to advise the government on matters of science and technology. For the last two years, I served as chairman of the Stockpile Committee. In addition, I served on the NRC Committee on Alternative Chemical Demilitarization Technologies and the NRC Panel on Review and Evaluation of Alternative Chemical Disposal Technologies. I currently serve on the NRC Committee on Review and Evaluation of Alternative Technologies for Demilitarization of Assembled Chemical Weapons (known as the ACW committee). Throughout, I have served as a volunteer, without compensation, in the interest of service to this country.
Today, I come before you as a representative of the Stockpile Committee. The Stockpile Committee is an NRC standing committee that has been reporting on the Chemical Stockpile Disposal Program for some 13 years. Its statement of task calls for providing the Program Manager for Chemical Demilitarization scientific and technical advice and counsel on the disposal program. In doing so, the Stockpile Committee has produced 21 NRC reports since 1987. These reports include recommendations about the stockpile disposal program, the demilitarization systems incorporating incineration at several of the sites, and the alternative technologies under development for the Newport and Aberdeen sites. I would like to present an overview of committee recommendations and perspective relevant to the unfortunate accidental release of VX nerve agent from the exhaust stack of one of the incinerators at the Tooele chemical agent disposal facility in Utah, and its relationship to the potential for similar events at the Anniston chemical agent disposal facility in Alabama, as well as other demilitarization facilities in this country.
The Stockpile committee has always placed highest priority on the health and safety of the public and workers at chemical demilitarization facilities. To quote the committee’s report in 1994:
In view of the overriding public and committee concern for health and safety, the committee selected as its primary criterion, in formulating its recommendations, the minimization of the cumulative adverse consequences from all relevant risks over the full duration of the disposal program (Recommendations for the Disposal of Chemical Agents and Munitions)
To this day, protection of public and worker health and safety is of paramount importance to the Stockpile Committee.
The greatest threat to public and worker health and safety is the existence of the chemical weapons stockpile at each of the storage locations. Deterioration of the stockpile has resulted in many leaks of chemical agents and releases of chemical agent to the atmosphere during the storage of the obsolete weapons. These releases of chemical agent have been as much as one million times more than the release of chemical agent which occurred on May 8th and 9th in Tooele, Utah. In addition, the events most likely to lead to the release of a large quantity of agent, and potentially public fatalities, is an external event such as a lightning strike, earthquake or fire. Thus, the Stockpile committee has repeatedly recommended:
The Chemical Stockpile Disposal Program should proceed expeditiously and with technology that will minimize total risk to the public at each site (Recommendations for the Disposal of Chemical Agents and Munitions)
The Stockpile Committee has repeatedly endorsed incineration, with comprehensive air pollution control systems and safety systems, as a safe and effective method for destroying chemical agents and munitions. However, as we all know, no technology is perfect or without opportunities for improvement. In addition, technology is only one component of a chemical demilitarization system. And the incinerators are only a small component of the technology employed at these sites. The other critical component is the people -- the workers, training, procedures, safety systems, management, and oversight employed to make the chosen technology work in a safe and effective manner. Various reviews of the incident leading to these hearings indicate that shortcomings in both the technology and human systems resulted in the release of chemical agent.
Recognizing the important interplay between technology and people, the Stockpile Committee has made many recommendations for both improvements in technology and human systems to minimize both the potential for and the potential magnitude of accidents involving chemical agents. Several of the previous findings and recommendations are worthy of repeating today:
Recommendation: High quality, adequately staffed management systems must be completely implemented (including procedures for testing critical equipment; all necessary operating, maintenance, and emergency procedures; management of change procedures; training and cross-training programs; programmatic lessons learned activities; subject area reviews; and other safety oversight activities)(Review of Systemization of the Tooele Chemical Agent Disposal Facility, 1996)
Finding: No comprehensive, integrated program for managing risks or communicating them to workers and nearby residents has been established or implemented.
Recommendation: The Risk Management Program at stockpile storage and disposal facilities must be comprehensive and integrated to protect workers, the public and the environment ... The risk management program should be updated in response to experience and new information and should be a living, ongoing process that is integral to facility operations and adequately communicated....(TOCDF: Update on NRC Recommendations, 1999)
The Stockpile committee summarizes the need for additional emphasis on safety through the need for development of a "safety culture" at these facilities. That is, a culture where all employees are trained and cognizant of the full spectrum of safety issues, and make attention to safety highest priority. This requires visible commitment by management and appropriate accountability. The appropriate basis for comparison should be the best performance of related industries, not average performance.
Finding: ...The committee is concerned that the current reorganization of the Chemical Stockpile Emergency Preparedness Program, under which FEMA now has responsibility for off-site plans and activities, may fragment authority and interfere with a well coordinated emergency management program (TOCDF: Update on NRC Recommendations, 1999)
In addition, I note that emergency response at Tooele is split among at least two commands within the Army.
The Stockpile Committee has examined the appropriateness of carbon filtration of incinerator effluent gases prior to discharge to the atmosphere. In 1999, the committee completed the NRC report Carbon Filtration for Reducing Emissions from Chemical Agent Incineration (August 1999). Specifically, the purpose of the Carbon Filter report was to review the Army’s evaluation of carbon filters and its process for reaching decisions on their utilization. The committee gathered and assessed trial burn data from the two operating baseline incineration systems, the Johnston Atoll Chemical Agent Disposal System (JACADS) and the Tooele Chemical Agent Disposal Facility (TOCDF), acquired data and information regarding the design concepts for filter systems for the Anniston and Umatilla Chemical Agent Disposal Facilities, assessed the pollution abatement system carbon filter simulation model, assessed the Army’s quantitative risk and health risk assessments evaluating the addition of carbon filters, and traveled to the site where the Umatilla Chemical Agent Disposal Facility is under construction to observe the Army's change management process in action with respect to the application of carbon filters.
A review of the emissions data from trial burns at JACADS and the TOCDF indicated that emissions from the incinerators at these chemical agent disposal facilities have been either the lowest, or among the lowest for several regulated compounds, of all incinerators monitored by the USEPA. Thus, while the addition of carbon filters to the facilities at Anniston and Umatilla would reduce already low emissions, there would not be a significant reduction in public risk because these risks were already substantially below the thresholds of regulatory concern.
The presence of carbon filters at Anniston would most likely prevent release of chemical agent in the event of similar circumstances as that which occurred at Tooele. On the other hand, the addition of carbon filters would likely result in small increases in worker risk, and these risks had not been sufficiently addressed. The increases in worker risks were a consequence of the increased complexity of the facility from the addition of the filters. In addition, the delay associated with adding carbon filters at Tooele presented a greater threat to public and worker safety because of delay than the benefit that would be gained by the addition of the filters.
The Carbon Filter report recommended that to minimize increased risks to off-site populations and on-site workers from delays in stockpile destruction the Army should proceed with the current configurations, which already included carbon filtration systems at Anniston and Umatilla, and where no carbon filtration system was required at Tooele.
The report further recommended that the Army clarify to the public and to facility workers the risk management actions that would be taken if increased worker risks and hazards were identified, and that the Army also clarify the decision basis for balancing reductions in public risk against increases in worker risk.
No NRC committee has yet studied the TOCDF incident. Based on my personal experience, I would like to offer some comments. Looking forward, from my perspective, it is important to derive as many lessons as possible from these events. Investigations into chemical events to date at Johnson Island and Tooele have focused primarily on the single triggering event. There may be considerable benefit in examining the set of chemical events that have occurred to date to look for commonalties in causes and to seek effective responses to reduce the potential for future chemical events. Such a study could
• review process technology, operational activities (including training, operations and maintenance), and management by both the Army and its contractors to identify the causes of chemical eventsreview applicable risk management and safety programs
• review emergency response activities that have occurred as a result of each chemical event, including information dissemination
• review actions and changes that have occurred in response to each chemical event and evaluate the impact and adequacy of these actions and changes
• involve visits to JACADS and the TOCDF to review facility configurations and to meet with personnel involved with operational activities, facility management, and emergency response
• make recommendations regarding improvements in operational activities, facility management, and emergency response
• review and recommend the needs to enable credible and more rapid investigation and corrective actions in response to future chemical events at chemical demilitarization sites, including consideration of needs of external stakeholders (e.g., regulators and concerned public).
On a closing note, it is also important to recognize a very positive track record on behalf of the chemical stockpile disposal program -- To date more than 6,500 tons of chemical agent from more than 950,000 munitions and containers have been destroyed.
Thank you Mr. Chairman. I am happy to answer any questions.