Remarks of Dr. Richard Magee before the Umatilla Chemical Demilitarization Citizens Advisory Commission, Oct. 7, 1996

Some Umatilla and Morrow County residents argued that an incineration plant would increase risk in the area. Dr. Magee attempted to reassure them.

Dr. Magee, who directs the Center for Environmental Engineering and Science at the New Jersey Institute of Technology, is chairman of a National Research Council committee overseeing the Army’s chemical weapons disposal program.

In November 1995 we were given five alternative technologies to study. We were given the two Army-based technologies, neutralization and neutralization followed by biodegradation, and three private vendor technologies. We put together an extensive questionnaire, a 13-page questionnaire that went out to vendors. We made 14 site visits to vendors, numerous interactions running back and forth learning about technologies. We have been meeting with citizens, regulators and Citizen Advisory Commissions in the two sites. We were asked, by the way, to look at those technologies only for the two bulk storage sites.

What that means is that of the eight sites in the United States, two of them are very unique in the sense is all they have is a single agent, mustard at Aberdeen, Md., and VX at Newport, Ind. They are in steel containers maybe five feet long and 2 and ‘/2 feet in diameter. The important thing is there are no explosives, no energetics, no propellents. They are tbe two simplest sites that we have. Most of the technologies being put forward, even though we might argue a little bit about that, were looking at agent destruction, and they seemed to be the appropriate sites. We then conducted this in-depth evaluation from November when we got this data all the way through June, finished up the report in June and July and then sent it out for review. Academy reports undergo extensive review. They were sent out to 10 people throughout the country; we don’t know who they are. None of them challenged our findings, but they still had time to make 340 individual comments. So we ended up with an 118-page response memorandum. We have to answer each comment, either with a text change or why we don’t think the comment is appropriate or that is has been answered someplace else.

We did not look at technologies that might be appropriate or applicable at a mixed site such as Umatilla. We did not look at cost. We looked at three criteria: engineering performance or process efficacy; health, safety and the environment; and the implementation schedule. We met with citizens, met with the regulators to see if they would permit it or not, met with the public to find out what criteria the public wanted to see in the technology and we made the following recommendations: For Aberdeen with mustard, we recommend they do neutralization with offsite biodegradation at a TFDF (Treatment Storage Disposal Facility.) After all the research, the best conditions for neutralizing the mustard happens to be 90-degree centigrade water, and just mixing the mustard in there. By mixing mustard in 90-degree C water, it drives most of the mustard to a chemical called thiodigycol. It’s a very common chemical. If you’ve got a ball point pen, it’s probably what lubricates the ink in your ball point pen. But 90 percent goes to thiodigycol; the other 10 percent goes to other types of organics. When it does that, the process results in a very acidic condition, pH 2, 50 you have to add some sodium hydroxide to bring it back up to 7. What that also does is it tends to take the chlorine out that been formed in HDL to give you a salt in the bottom that gives you sodium chloride, which is table salt.

When this is done, we now have 30 times the volume that we had before. For every gallon of mustard we put in, we end up with 30 gallons of hydrolysate, of which approximately 29 is water. That material is not particularly toxic but it is also not releasable into the environment under those conditions. So it requires a post treatment step.

It turns out the material is very biodegradable. This is demonstrated by Army studies at Aberdeen. They went to a sanitary waste treatment plant, got up a series of bugs from the bottom, and they just loved that thiodiglycol. They basically degraded the thiodiglycol. The Army, as they were developing this technology, would then also ship the hydrolysate offsite to a Dupont facility in New Jersey. (A plant on the Delaware River at the tip of New Jersey.) They sent a sample up and said, “Can your facility accept this waste?” If you have such a facility you have to show the regulators (under RCRA laws) you can treat the waste before you discharge it into the environment. The results from Dupont were very encouraging. They are a potential recipient of the hydrolysate, for treatment and discharge into the Delaware River.

The reason we recommended neutralization followed by off-site treatment is that it seems we have an existing structure in the country. We have these facilities, we have the permits for the facilities, we have the working people and all the equipment. Why do we build another faculty when we can ship it off? It seems to be a better way of doing it. By the way, the Army does not have procedures that allow for large off-site shipping at this point. If we chose not to do that, our second recommendation was to neutralize and then do biodegradation on site. It turns out they have a treatment works there so they can build these sequencing batch reactors, carry out the biodegradation on site and take the water from the reactors and put it in the treatment works and discharge it into the Chesapeake.

We just felt the other technologies we looked at, which were in various stages of development, did not offer us the same level of confidence they would work. We didn’t say they couldn’t work but we feel there’s still development work going. This is one we had a lot of data on, a lot of confidence, and felt very comfortable that this was a good solution for the Aberdeen site.

For Newport, the VX results were not quite as clean as the Aberdeen site. Yes we can neutralize VX, by using one-third VX and two-thirds sodium (unknown word) solution. It turns out that reduces the toxicity of VX by about 40,000. It’s still toxic, but a lot less toxic than VX. To date, the degradation studies for that hydrolysate have not been that promising, both by the Army in their independent studies in the laboratory and (in a coming report) from Dupont they were having trouble degrading the organics that were still left in that hydrolysate. The panel felt there were other TFDFs using difference processes that were not in the report that could handle that hydrolysate. But the answer at Newport is hydrolyze and ship, but you have to find a TFDF that can accept this waste and treat it.

In the event they can’t do that, you have to abandon neutralization of VX, and our recommendation is that they follow up by electrochemical oxidation. We point out in the report it’s the least developed of all the technologies, but it has many of same features of neutralization in the sense it’s carried out under low temperature, low pressure, it’s a simple process that doesn’t involve elaborate controls. We looked at all sorts of things. Some of these processes have 15 different steps in them, all which involve very integrated controls between the various steps to make the process work. For processes that had never been used on agent before, there could be a lot of development work. And also the more complex the processes, you also have the possibility more things might go wrong. We felt the more simple processes would be a better solution than the other technologies. We didn’t say the other technologies couldn’t be made to work; we made a lots of cautions in the report about questions we had that weren’t fully answered in the development stage.

None of those technologies are fully ready to go to the field tomorrow. We were getting constant changes throughout the whole process. That was one of the difficult things about this. We would meet with the vendors and discuss with them their technologies, raise issues and we would get a change a week later — ‘Oh yeah, we’re going to do it this way.’ We had to say as of April 4, no more changes, because we couldn’t change the report every time we got a new memo.

The bottom line, the panel feels very comfortable in the recommendations that both of these technologies would work, neutralization and biodegradation at Aberdeen, neutralization and some other process at Newport. As I try to explain to people, there is now another tool in the toolbox, at least for those sites.

Is it safer than incineration? We didn’t try to answer that question. No one can answer that question fully today. The reason they can’t is the following: We have recommended all along at every site that two things be done, that there be a site specific risk assessment, which is called a Quantitative Risk Assessment (QRA) and there be a health risk assessment (HRA.) None of these has matured to the point, nor gone on to the piloting, so we will know exactly what will come out the back end so we will be able to do a complete HRA or QRA. The reason we can do it for the baseline incineration is we have data from Johnston Atoll. That gets plugged into the HRA, and once we get the data from Tooele trial burns, we’ll probably update the HRAs.

Once the Army decides to go ahead and pilot these technologies then in fact we will have some data and you can go back and do those calculations. (It’s) helping me understand what this means because I’m not a risk assessment (person.) I know more about how things burn and what combustion products look like and how incinerators work. Let me help you understand how I understand or at least how I interpret QRA data and ITRA data. People always ask me is it safe? And there is no definition of what is “safe” means, you can’t look up what safe means and what might be safe for me may not be safe for you. So what we do is, people run these HRAs and they come up with a number and the number says based on what we think this technology will do, there is this chance that this one person may potentially get cancer in a 70-year life time. That is what you get, a number that is what the HRA gives you.

Now a typical number might be one times 10 to the minus 6. What does that say? That says one chance in a million for additional cancer. People say ‘That could be me, I don’t like that.’ The only answer to help you understand that is the following: Who determines that one in a million is O.K.? That becomes a policy decision, not a scientific issue. Drinking water standards in this country are set at 10 to the minus 5. (10 in a million) Water has to have a health risk of lower than at least 10 to the minus 5. When they clean up hazardous waste sites, EPA is recommending a range of 10 to the minus 4 and 10 to the minus 6, depending on the site, etc.

I am not here to set the limit, but there is a limit you get with an HRA. Many people feel when you get below 10 to minus 6, then the health risk becomes lost in the background noise. You’re now talking one-tenth of a person in a million. Somewhere along the line, no matter which technology you use here, someone is going to do an HRA, and you’re going to get a number, and the number is not going to be zero. The question it becomes is, is a lower number better than another number? You have to make the decision. The people I talk to (say) once you get below 10 to the minus 6, one in a million, you get lost in the background noise. People don’t regulate it because they cannot measure it. Same with the QRA, the potential for fatalities. I forgot what it is up here, is it an airline crash into an igloo, is that the worst case? They are usually governed by external events. It could be that or lightning or an earthquake. An earthquake is what I usually hear in Utah. The ones that usually come up are airplane crashes, lightning or earthquakes. What they’re saying is that these are low probability occurrences, but they have major effects if one of those things should happen, if you lose an igloo due to lighting or an earthquake.

Also there is a potential in storage. In the processing risk, what happens if someone takes a loaded one ton container and drops it into an incinerator? What is the chance of that happening? The rule of thumb that the Army has been using in the QRA is less than 10 to -8. The nuclear industry they uses 10 to -6, two orders of magnitude less. What that says is that when they do a QRA for technology, if they find that the risk is higher than that, then they go ahead and try to mitigate that. When they did the QRA for Tooele there were about three or four items that came up that looked like they may be particular problems. So they changed the processing rate, they made some small design changes all in an attempt to get the risk down. So the number, whether it’s 10 to the -6 or 10 to the minus -5, somebody has got to set that number. Then it gives you from an engineering viewpoint to say if you have a risk higher tban that, ‘What can I do to mitigate that risk? How can I redesign my facility? How can I change my operation? What do I have to do if a forklift driver drops a pallet of M55 rockets?

The processing risk is made up of lots of individual risks, starting all the way from the time someone goes out to an igloo, picks up a munition and starts moving that from the igloo into the processing facility, all the way into the processing facility where you try to get the agent out of

the munition so you can treat the agent separately. Things could drop, things could explode, things could happen, and ultimately you get down to the end and the agent gets processed, whether by neutralization, incineration, or X. That last step is a small component of the total risk. Doesn’t mean you shouldn’t be concerned about it; doesn’t mean I’m not concerned about it. You have to think about this processing risk. Everybody keeps focusing on that last step all the time and doesn’t worry about all the other things leading up to that last step along the way.

(On the question of how the NRC alternative technology report relates to Umatilla), The question was asked today, and it’s a logical question. ‘Wait a minute, 62.9 percent of our stockpile is mustard in one ton containers. Sounds to me that looks like Aberdeen. Is our mustard any different?’ Without analyzing it, I doubt it is, probably the same kind of mustard. Does that mean you could use the same kind of technology recommended for Aberdeen? Why not? The catch, and there is a catch, is that you remember the Aberdeen facility was scheduled to come on line for processing in the year 2002 or 2003. That was one of the last two sites they were going to start going through the permitting phase because it was only bulk containers.

The biggest concern in the whole stockpile, by the way, are the M-5 5 rockets. Back in 1985 that what’s started the whole program with the Army. We have over 400,000 M55 rockets, all loaded, ready to go, if anything goes wrong, lightning strikes, something goes wrong with the propellant, one of these things ignites in an igloo, we could have rockets shooting all over. This is a big risk; it’s a concern. I understand years ago there was an igloo that exploded at the (Umatilla) depot –conventional weapons — a long time ago. If that would have been chemical weapons, it would have been catastrophic. I’m not just scaring you. I don’t play that game. I’m telling you M55 rockets are the potential problem. You have them, unfortunately; Aberdeen doesn’t. Aberdeen has time to start their permitting application (for neutralization) and still be on the same schedule they would have been with the baseline (incineration) process.

I understand out here you guys are in a different situation. You’re moving ahead; you’ve got a permit application in; you’re trying to make a decision as to whether to go ahead with the baseline system or not. The question I was asked this afternoon was couldn’t we use neutralization to do the other? I’m saying scientifically you could use it. I can’t tell you can’t. You’d have to find a place to send the hydrolysate and or you’d have to treat it and release that water into a body of water around here, and that may not be acceptable to a lot of people also. I can’t tell you that scientifically you wouldn’t use it. I wouldn’t tell one site you can neutralize mustard and someplace else you can’t. But I don’t know what the implications would be on your schedule. Would it delay the whole thing another three or four years? I don’t know. Just remember if you do, your storage risk will not go away, and the M55s will not go away. I’ve thought a little bit about it; I don’t see how you could start the plant hot and then build the other plant after you’ve started because that would put your workers in a situation in trying to work in areas there might be some contamination inside the building. You try to lock various sections together; these buildings are very well designed to keep the air flow going in one direction so you can capture it in charcoal filters.

Q. (From Frank Harkenrider) Are you saying incineration is the best technology for the M55 rockets at the Umatilla Chemical Depot?

A: Incineration is the only technology we know that can handle the entire M55 rocket. The other technologies could maybe handle the agent, but they can’t handle the other parts of the rocket.

Q. (Harkenrider) Can you burn the mustard at the same incineration plant or do you have to ship it?

A: We burned the mustard at Johnston Atoll, we burned the mustard in Iraq. The Canadians burned their mustard, the Brits burned their mustard. This is the first time people have developed an effective process for neutralizing mustard on a large scale. What I’m concerned about here is the implication of trying to put another technology in and delaying the program. That to me is the issue you have to address if you really believe the storage risk is that much greater than the processing risk. We’ve had it done a couple of times and we’re convinced on the Academy committee that where’s the risk is. It’s not going to be in the processing.

Q: (Harkenrider) Why is that so hard for everybody to figure out?

A: In fairness to everybody, despite what I may tell you about my beliefs on incineration and what a lot of other people will tell you, not everybody believes that incineration is as benign as I may want to make it out to be. The only way I can answer people when they challenge me, as though I’m coming in here and supporting this ‘evil’ technology that’s going to kill the world. You’re saying, ‘I know you’re from New Jersey, but have you completely lost it?’ There’s probably 150 hazardous waste incinerators that are operating in this country every day that are permitted by RCRA (all different kinds of hazardous wastes). I have taken Congress staff people to Europe, and you look at incinerators in towns where you could literally throw a stone from the closest residence to a hazardous waste incinerator in Basil(?) Switzerland. I stood outside the gate of the one in Nyberg(?) Denmark. Huge, it takes all the way of the whole neighborhood, and people live in the town and they have lived there for years. All these things people say can happen, I go out and I can’t find the data to support it.

We’ve looked at the data from Johnston Atoll. The EPA sets the limits on emissions and these limits are set based on these health risk assessments and their national standards. That incinerator out there is probably at least 10 times lower in emissions than all the RCRA standards, in some cases less than that, but they are not zero. But your fireplace isn’t zero, your home furnace isn’t zero. Your car is not zero. There is no data in my mind that would support a major health or environmental hazard. (At Johnston Atoll) they’ve been monitoring the marine life and the lagoon out there since the place started up, working with Woods Hole, the oceanographic institute in Massachusetts. There a big preserve right of the end of the island, and they tell me the birds are flourishing. The plant’s been operating six-seven years there, and we’re not seeing that.

I’m not saying incineration is the only way to go, but there’s no way I can look at the preponderance of data that is out there and (understand the complaints.) People are saying, ‘People are going to die 40 miles away.’ I’m saying there is no way you can get a plume of stuff 40 miles away. It’s just not scientifically sound. I don’t know any other way to say it — it’s nonsense.

Q. Explain the shutdowns at Tooele.

A. Neither shutdown had anything to do with incineration. One shutdown occurred because part of the problem is whenever you open up a weapon, there’s vapor (under) pressure, so you immediately get agent in the room, that’s why it’s all done robotically. You then cascade that air to a set of charcoal filters banks to absorb it. As I understand, in the vestibule they had two dampers and they closed it off They trapped some vapor in there and that stuff migrated back to another part of the plant which they didn’t expect. It was all internal migration. They now have corrected that by keeping that damper in an open position so the air flow will always draw any of that stuff back to another passageway. In the other (shutdown), someone went down into the electrical room one day and noticed a little drop of water on the floor. It happened to be ‘decon’ solution. When people work in hot areas, they have to wear protective clothing, and they hose them down before they go into their decon locks to move through to make sure there was no agent on them. Obviously there was a slight crack in the floor. So the decon solution, rather than going into the drain, went into a crack into the floor. Should those have happened? Absolutely not.

Q. (Commissioner James Stengle) Was this a consensus report, everybody in full agreement among the 14 panelists? Are the representatives on the panel all hard scientists; such as chemists and engineers?

A. Yes (the report was unanimous.) If people do not agree, they can write a minority opinion. There was no minority opinion. (As for the committee makeup), there was a social scientist on it (from Arizona State) who helped us arrange public meetings and with regulators and to get public input on it. There also was a risk assessment specialist from Los Alamos, but most of the other people (all had technical backgrounds).

Q. (Stengle) You have said a couple of times that “You” are the ones to make the ultimate decision. Who is this “You?”

A: As I understand it, the ultimate permitting call will be made by the regulators. But I understand you as the Citizens Advisory Committee obviously have a lot of input into that decision-making process. You set out to interface with the Army and I assume to let your views be made known to both the regulators and board representatives alike. And I believe you are accountable to the public, at least you are in my mind. When I say ‘you,’ I think it’s the community’s decision. I don’t think it’s my position to make that decision. If you want me to make it for you, I wouldn’t have a problem of doing that. I would rent myself out as a canary if that would help. If you want to pay my salary I would be happy to sit out there. Ultimately, I think all that someone like myself could do is come here on behalf of 14 very fine individuals and answer any technical questions like how we challenge the decisions we made. You may not agree with the assumptions I made, things that we use for decision making may be different ones than you. You may decide for yourself. Ultimately, I guess it’s got to be between the community and the Army. If the facility does not go up, then that stuff is just going to sit out there. In my mind that’s not going to help you and it is going to frustrate me. The only reason why I do this and we don’t get paid for this job is because I want to be part of the solution. Ultimately, it’s your community, not mine so I’m here to help.

Q. (Citizen Tom Kingston) A couple years back now, they had some research going on to freeze these M55s in the igloo and neutralizing the liquid before. Where does that stand now?

A. There was a study by an NRC committee; the process was called cryofracture. It was not necessarily in the igloo per se, but to drop these rockets into liquid nitrogen, you would freeze everything at once and if you then hit the material, it would probably shatter. Aluminum wouldn’t do that; the projectiles would fit that category. If you take 220,599 individual pieces in your arsenal each of them have to be handled one at a time, if you would drop this into a room it would crack, then we would shove everything into an incinerator. That was the proposal; the Academy got really nervous about that. First of all, when they did the test they were getting fires in the bottom of the cryofracture pit. Second of all, one thing the baseline system does is separates the explosives from the agent. The explosives go one way, the agent goes another way. This would put it all into one incinerator at the same time and what our concern was if you had detonation explosives in there with unreacted agent, you would have the potential of blowing all the agent up the stack. In spite a lot of pressure on Congress, we don’t think that is a safe way to do the job.

Q. (Burns) Would you subject yourself and your children and grandchildren to an incinerator in your community? What about the people who don ‘t have a faith in computer-generated HRA’s?

A. Someday I believe you are going to have to accept a technology to get rid of this stockpile whether it be incineration or neutralization or some other technology down the road. What are you going to use to make a judgement on whether or not the technology is safe? You are going to have to use that same risk assessment technology that you don’t feel comfortable with today, it’s the only tool that we as professionals can put on the table today. Somewhere down the line if you don’t like the methodology of this technology then I don’t know how you’re going like it for any other technology. I can’t believe that it’s in the best interest of your community and you to leave this stuff sitting there.