21 March 00 rev 28 Mar 00

Executive Summary

In early February of this year Pat Suter, Chair of the Coastal Bend Chapter of the Sierra Club and I, were invited by the Army to visit the chemical weapons storage and disposal facility at Tooele, Utah known as CAMDS to learn more about the VX neutralization process. This report is about what we learned as a result of that trip.

The United States and its Army is faced with a tremendous problem in destroying this nation’s stockpile of chemical nerve agents. As of March 2000, some 28,000 tons of these agents remain to be disposed of. This task must be accomplished by 2007 in accordance with International Treaties of which the U.S.A. is a signatory. The project is 14 years behind schedule and more than $900 million over budget. The Army stopped producing nerve agents in 1968 and has been looking for ways to destroy them since 1960.

Twenty eight thousand tons of nerve agents is about 25 billion doses, each lethal enough to kill a very large human being the size of Hulk Hogan. Each dose is about 10 milligrams or an eighth of a baby aspirin. Just the USA stocks alone are enough to kill every human being on the planet five times and the Russians have a stockpile at least as big as ours.

Up until recently the Army favored the incineration as the ideal way to destroy these stocks. With incineration a 99.9999% efficiacy is achieved. They built two production incinerators, one each at Johnston Island in the pacific (1985) and one at Tooele, Utah (1989). To date these two facilities have destroyed almost 6,000 tons of agents and munitions out of an original load of about 34,000 tons or an average of 461 tons per year. At the present rate of destruction, it will take in excess of 60 years to destroy the remaining stocks. The problem is compounded by the congressionally mandated policy that all stocks must be destroyed in place, presumably because the transportation of these agents is thought to be too dangerous. Over eight million pounds of chemical agents are stored in the East upwind of large population centers. A third incineration facility is being built in Umatilla, Oregon, and should being operation in a couple of years.

Incineration has potential problems. Mainly the incinerators can produce deadly by-products such as Dioxin, which the EPA says is 300,000 times more carcinogenic than the banned DDT even in very small quantities. No one knows the effect of ingesting small amounts of this deadly chemical. At the Tooele incinerator, it has been reported by an opposition group called FAIR, that if more nerve agents are burned the concentration of Dioxin in the soil and food chain will exceed safe standards by over 50 times and possibly more. This same group reports significant quality and other errors, omissions and cover-ups at the chemical deport, some of which are apparently documented in a Federal lawsuit. Tooele is located approximately 30 miles up wind from Salt Lake City.

In 1995 the Army began seriously exploring alternatives to incineration and eventually agreed to intensively investigate six core alternatives. Three of these were studied extensively, some others are still to be explored, and one of them was rejected. The subject of this report is the surviving VX Neutralization/Supercritical Water Oxidation (SCWO) process and the role of Corpus Christi, Texas, in this experiment (The "Corpus Christi Experiment"). We are told that the results of this experiment will be used to construct a full scale production facility at Newport, Indiana. Our analysis of the facilities, both in Corpus Christi and Tooele, raises many questions about what might be learned.

The Newport Chemical Depot in Indiana has over 1,200 tons of VX chemical agents stored in bulk. The VX Neutralization /SWCO process was selected for this location as a hoped for alternative to incineration. Pending the outcome of these experiments, all funding for incineration is on hold. Briefly, the process is a two-stage. The first is to mix the raw chemical agent with heated Sodium Chloride (lye) and water for a period long enough to break the chemical bonds and turn the VX into a hydrolyzed solution now known as "VX Hydrolysate". The VX Hydrolysate, which is toxic in itself, does not possess the deadliness of the raw VX, but is still considered a Schedule II agent. That means it could be chemically recombined to VX but I have been told by the Army that this is not economically feasible. Second, the VX Hydrolysate is processed in a SCWO reactor to further break down and reduce the Hydrolysate to heavy but still toxic salts and water. The SCWO reactor is a high-pressure high temperature reactor. According to the National Research Council (NRC), the heavy salts must be disposed of in an appropriate landfill designed for this purpose and the resultant water can then be treated by a conventional sewerage treatment plant.

The Corpus Christi Experiment consists of processing 200 barrels of VX Hydrolysate (approximately 9,000 gallons) trucked here from Tooele, Utah, some 1,300 miles away. A semi-portable SCWO plant was manufactured in San Diego and shipped 1,300 miles to Corpus Christi to process the VX Hydrolysate. The resultant, which is claimed to be seawater (water plus the heavy toxic salts we presume), is then to be pumped 5,000 feet into the briny sands under Corpus Christi and the Gulf of Mexico along with other toxic and heavy effluents (about 13 million gallons down holed every year).

Would it not have been better to conduct this experiment at Tooele in a protected environment with local civilians and experts who should have the chance to evaluate the technology and who would actually like to hold the experiment there? Or would it be better to conduct the experiment in Newport, Indiana, at the very site where the eventual plant will be built and where an EIS has already been published outlining the risks? Why was Corpus Christi chosen? We don’t know for sure but there are serious questions regarding disclosure of risks, avoiding the EIR/EIS process, and the general regulatory system for monitoring this type of process and looking out for the best interests of the citizens of this community.

The NRC issued a report in 1998 on the neutralization/SCWO process. While generally upbeat about the potential, it does point out a number of flaws and un-certainties, which still must be overcome. The government’s own EIS issued in December 1998 for the Newport facility is one of the best reference works as to what work has been done to date to investigate alternatives to incineration but also indicates that not all problems have yet been solved.

Strangely enough, the Centers for Disease Control issued a favorable report on incineration in late 1999, which is sure to fuel this debate. If incineration is as harmless, as claimed, why is there a need for alternative technologies?

The stated purpose of The Corpus Christi Experiment is to gain knowledge to build the Newport SWCO plant. There are significant differences in The Corpus Christi Experimental equipment and any eventual plant, as pointed out by the NRC. Therefore there are real concerns as to whether the experiment will yield any real value or contribution that could not have been accomplished elsewhere.

I believe the reasons Corpus Christi was chosen for this experiment are not based in the technical issues or even in the desire to learn more about the process so a bigger plant can be built. The commercial vendor (DSI) simply had a chance to increase revenues in a state and in a locality where everyone is asleep at the switch as far as toxic waste disposal and pollutants are concerned. It was easy to pull this experiment off here.

Consider the following: Not even a minimal environmental statement or report was prepared on The Corpus Christi Experiment. The failure to publish even a minimal report is contrary to public policy. The vendor handling this experiment is grand fathered into this area to dump toxic wastes into the sea beds below us without significant further scrutiny and no special permits or explanations are required for the VX Hydrolysate. The vendor even bragged that the company was not legally obligated to tell anybody anything about the experiment (which is tragically true). Simply stated, when all the above facts are coupled with a weak government and ineffectual regulatory oversight, the combination makes the citizens of Corpus Christi less empowered than others in these matters which affect them.

We want to point out that the Sierra Club recognizes that the disposal of these chemical weapons and agents is a National nightmare and a nightmare that must be solved in the right way without harm. The men and women of science working for and contracted by the Army to deal with this problem are bright, sincere, well intentioned and intelligent people and are trying to do the right thing in correcting this cold war mistake of epic proportions. We also believe the Army is being open and forthright about these very complex and technically risky issues in terms of process repeatability and quality control.

The official position of the Sierra Club is in opposition to the incineration of the chemical stocks. We encourage the Army to find the right alternative solution to the problem with minimal environmental and human damage.

We believe that everyone has to shoulder some of the burden and are hopeful that the VX neutralization/SCWO process works as expected and can be brought on line in the needed time frame. We also believe that there should be full and timely disclosure and debate in these matters which was shamefully not done in this instance.

Lastly, because the reactor vessel in Tooele broke down and won’t be fixed, we are told that only 120 barrels of VX Hydrolysate will be processed in The Corpus Christi Experiment instead of the planned 200 barrels. We greatly appreciate the fact that ~3,200 gallons less of VX residue will now reside in our sea beds.

For this reduction, I and our many colleagues are grateful. The State of Texas, Nueces County and Corpus Christi already rate very high on the list of toxic waste releases and disposal dumps. Everything we can do to reduce that load is important. We don’t need a Love Canal in South Texas.