[CPEO-MEF] Communities and Chemical Warfare Materiel Disposal

[Lenny Siegel <lennysiegel@gmail.com>]

[For a 2.2 MB, 19-page formatted version of the full report, complete 
with photos, go to http://www.cpeo.org/pubs/C&CWMD.pdf. - LS



Communities and Chemical Warfare Materiel Disposal

By Lenny Siegel
May, 2007

Prepared for the
U.S. Army Engineering & Support Center, Huntsville

The views, opinions, and/or findings contained in this report are those 
of the author and should not be construed as an official Department of 
the Army position, policy, or decision, unless so designated by other 
documentation.

EXECUTIVE SUMMARY

The Center for Public Environmental Oversight (CPEO), a project of the 
Pacific Studies Center, conducted field work to evaluate community 
attitudes toward the various technologies and approaches to Chemical 
Warfare Materiel (CWM) response. CPEO Executive Director Lenny Siegel 
visited five communities where Formerly Used Defense Sites (FUDS) have 
known CWM issues and interviewed stakeholders, including local, state, 
and tribal officials. The five FUDS were the American University 
Experimental Station, Spring Valley, Washington, DC; Amaknak Island, 
Unalaska/Dutch Harbor, Aleutian Islands, Alaska; Former Lowry Bombing 
and Gunnery Range (also known as Buckley Field), Aurora, Colorado; Black 
Hills Ordnance Depot, Igloo, South Dakota; and Former Camp Sibert, 
Steele, Alabama. The stakeholders who took part in this study were 
remarkably frank, and they offered valuable, though varied opinions 
about the technologies with which they were familiar.

CWM at Formerly Used Defense Sites includes actual chemical munitions, 
such as mortar rounds, artillery shells, and possibly aerial bombs; 
Chemical Agent Identification Sets (CAIS); bulk storage containers; and 
CWM laboratory debris. The U.S. Army Corps of Engineers has counted 100 
or more FUDS known or suspected to contain CWM, and the number is 
updated periodically.

At FUDS, the U.S. Army Corps of Engineers is responsible for conducting 
the site investigations and subsequent excavations that lead to the 
recovery of buried chemical munitions. When suspect CWM is found, the 
U.S. Army Corps of Engineers may call in Technical Escort Units from the 
22nd Chemical Battalion. The Non-Stockpile Chemical Materiel Project 
(NSCMP), a branch of the Chemical Materials Agency, may be brought in to 
destroy the materiel.

There are numerous technological options, some of which have been proven 
in the field, for addressing recovered chemical munitions, including 
Open Detonation, the Explosive Destruction System, Controlled Detonation 
Chambers, Stockpile Demilitarization incinerators, commercial hazardous 
waste incinerators, and the Large Item Transportable Access and 
Neutralization System. Chemical Agent Identification Sets may be 
destroyed in the Single CAIS Access and Neutralization System, the Rapid 
Response System, or commercial hazardous waste incinerators, and 
community education is a key response action at any location where the 
Sets may be been buried or otherwise discarded.

At sites governed by the Comprehensive Environmental Response, 
Compensation, and Liability Act, Community Acceptance is a criterion in 
the remedy-selection process. However, the public at the studied FUDS 
are generally unaware of the range of technologies designed to treat 
recovered CWM. Many of the respondents, familiar with the CERCLA 
remedy-selection process, explained that they would expect to evaluate 
treatment technologies, at the sites within their communities, after 
hearing their respective advantages and disadvantages from officials of 
the U.S. Army Corps of Engineers and environmental regulatory agencies.

Those of the respondents in this study who expressed opinions generally 
opposed "incineration," the number one controversy at CWM Stockpile 
demilitarization sites because of concerns over atmospheric emissions. 
However, a number of people suggested that incinerators that prevent 
harmful emissions might be acceptable.

Most of the study participants believe that it is better to transport 
the treatment technology to the recovery site than to ship the CWM to a 
treatment facility. The Explosive Destruction System is highly regarded 
by those stakeholders who are familiar with it. Some of the respondents 
volunteered that it does not make sense to store chemical munitions on 
the surface. Most believed that education is an appropriate response to 
potential CAIS discoveries. Some felt that monitoring for emissions was 
a key part of any treatment system.

Experience at Stockpile demilitarization sites over the years 
illustrates how the storage and disposal of chemical warfare materiel 
and its demilitarization byproducts can generate intense emotional 
reactions from host communities. The Non-Stockpile Project has avoided 
such challenges by institutionalizing a give-and-take relationship with 
community activists, regulators, and others through the Core Group.

The key lesson of this study was that stakeholders' acceptance of CWM 
treatment technologies is primarily a function of the level of trust 
that they exhibit toward the U.S. Army Corps of Engineers and other 
government officials at their sites.

To promote the development and/or acceptance of chemical warfare 
materiel disposal technologies and strategies at Formerly Used Defense 
Sites, the U.S. Army Corps of Engineers should work to include public 
stakeholders from FUDS in the Core Group or a similar national dialogue 
on buried CWM response.

To ensure that trust is already established when site-specific decisions 
about CWM disposal need to be made, FUDS project managers must be 
prepared to work cooperatively with communities and reminded of the 
importance of developing such relationships.

If the U.S. Army Corps of Engineers anticipates, understands, and 
addresses up front the concerns of FUDS communities where CWM is found, 
it can accomplish its mission with a minimum of delay, expense, and 
controversy.


--


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org


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