Local News
CARNEY?S POINT, NJ- The U.S. Army is proposing to pre-treat stockpiles of VX nerve agent at its Newport Chemical Agent Disposal Facility in Newport Indiana, and then transport the resulting hydrolysate across the country to the DuPont Chambers Works facility at Carney's Point, Salem County, NJ for final treatment and disposal into the Delaware River.
The Chemical Weapons Convention, in force as of April 29, 1997, requires destruction of chemical weapons by the year 2007.
The US stopped production and shipment of chemical agent and weapons in the late 1960's. For nearly 40 years chemical weapons have been stored at the Newport Chemical Depot. Originally the Army agreed with its Indiana Citizens' Advisory Commission and planned to destroy and dispose of the VX nerve agent stored at the Depot on site, at the Newport Chemical Agent Disposal Facility. Following the attacks of September 11, 2001 the Army changed its mind, and decided to partially treat the nerve agent on site, turning it from VX nerve agent to VX hydrolysate, and then transport it to an alternative facility for final treatment and disposal.
The Newport Indiana community has repeatedly voiced its preference that the VX nerve agent be treated, destroyed and disposed of on site in Newport as originally agreed to by the Army. But the Army has, unilaterally, decided to veer from that agreed upon course of action.
First the Army proposed to ship the VX hydrolysate to a company in Ohio for further treatment and disposal. A strong public outcry against the proposal forced the Army to abandon it. By August 2003, the Army was already proposing to instead ship the VX hydrolysate to DuPont along the Delaware River although the proposal was only noticed publicly in December 2003.
The Army is proposing to "neutralize" the VX nerve agent stored at the Newport, Indiana facility using a chemical neutralization process. The neutralization process results in a solution called VX hydrolysate or VXH. While VX hydrolysate is said by the Army to be much less toxic than VX, they agree that additional treatment is needed in order to meet requirements for disposal. Additional treatment is also necessary to meet the requirements of the Chemical Weapons Convention.
There are a number of concerns associated with VX hydrolysate. VXH is highly caustic and could be harmful to humans and materials. VXH has a very strong odor. It is possible that under the right conditions (if the pH were decreased below the 13 to 14 range) VX could be reformed. And the organic layer in VXH is flammable, therefore VXH must be kept sealed from the environment at all times. (Final Report, Treatment of VX Hydrolysate by PermaFix of Dayton, Report prepared for Montgomery County (OH) Commissioners by Dr. Bruce E. Rittmann, John Evans Professor of Environmental Engineering, Northwestern University)
Chemical neutralization of other chemical weapon agents such as mustard and nerve agents also produce hydrolysates. But the composition of each hydrolysate and the potentially viable treatment alternatives for each hydrolysate varies. Therefore, DuPont's history with treating mustard agents at this Chambers Works facility does not necessarily translate into a capability to handle VX hydrolysate.
The Army asserts that prior to transport the VX hydrolysate will "be analyzed and certified that it contains no detectable nerve agent before it leaves the destruction site in Indiana." (Letter from Colonel Jesse L. Barber, Department of the Army to Maya van Rossum, the Delaware Riverkeeper, January 16, 2004.) This does not mean that the VX hydrolysate will not contain any VX. The detectable limit being used by the Army is 20 ppb, therefore the Army will allow VX nerve agent to be shipped off site and to New Jersey as long as the VX in the hydrolysate is less than 20 ppb. .
According to an Ohio EPA study, VX at a level of 20 ppb after 17.4 hours killed half of the striped bass exposed. As a result of this and numerous other concerns, an agency toxicologist "strongly recommended" against discharge of treated VX hydrolysate into the local POTW and waterbody until there was "more information about the possible toxic effects of the treated hydrolysate discharge on aquatic life". (Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA)
Further, in an August 26, 2003 article in Chemical & Engineering News ("Destroying Chemical Weapons, Army's Problem-Plagued Program More Costly than Originally Planned", Lois R. Ember) Terry Arthur, a Newport spokeswoman said that while the Army committed not to ship VX hydrolysate off-site unless the VX levels were less than 20 ppb, it couldn't now honor such a commitment. She went on to say, "As measured, caustic neutralization produces a hydrolysate containing 40 to 80 ppb of VX."
After neutralization, the VX hydrolysate contains:
Ethylmethylphosphonic acid (EMPA),
mehylphosphonic acid (MPA),
2-(diisopropylamino) ethanethiol (thiolamine), and
EA2192.
(Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA)
EMPA and MPA are "schedule 2 precursors" in the Chemical Weapons Convention, meaning they could potentially be reconverted to nerve agent. (Using Supercritical Water Oxidation to Treat Hydrolysate from VX Neutralization, 1998, Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Board on Army Science and Technology, Commission on Engineering and Technical Systems (CETS), National Research Council, National Academy Press, 1998, also found at www.nap.edu/openbook/0309060435/html/7-10.htm)
EMPA and MPA are resistant to biological treatment. (Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA)
EA2192 is as toxic as VX and is the most toxic degradation product from VX hydrolysis. (Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA)
Little is known about most VX hydrolysis degradation products - the products that result from neutralizing VX as proposed. (Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA)
There are no bioassay toxicity data for EA2192. But it is known that while EA2192 does not bioaccumulate it "retains its anticholinesterase [nerve-agent] activities and. therefore is a potential toxic threat to aquatic life". (Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA; Final Report, Treatment of VX Hydrolysate by PermaFix of Dayton, Report prepared for Montgomery County (OH) Commissioners by Dr. Bruce E. Rittmann, John Evans Professor of Environmental Engineering, Northwestern University.)
There do not appear to be any studies on the impacts of MPA, EMPA or EA2192 on the environment or aquatic resources. The toxicity effects of these chemical compounds needs research as all three compounds may be present in the discharge that enters the Delaware River as a result of DuPont's proposed treatment method.
Important Questions:
With regards to the proposed discharge and the environmental impacts of this proposal there are a number of important questions:
* Will the discharge contain phosphanate? At what level? What is environmental impact of this? What is the aquatic impact of this? What studies back up the assertions about impact?
* Will the discharge contain phosphate? At what level? What is environmental impact of this? What is the aquatic impact of this? What studies back up the assertions about impact?
* EA 2192 is very close to VX, and is toxic. Will this be in the discharge? What is environmental impact of this? What is the aquatic impact of this? What studies back up the assertions about impact?
* Will EMPA be in the discharge? What is environmental impact of this? What is the aquatic impact of this? What studies back up the assertions about impact?
* Will MPA be in the discharge? What is environmental impact of this? What is the aquatic impact of this? What studies back up the assertions about impact?
* What work has been done on fugitive emissions? What are the potential environmental and/or health impacts?
* What will DuPont's new or upgraded air permit allow them to emit? What are the potential environmental and/or health impacts?
* Will DuPont be pursuing a new or upgraded water discharge permit? If not, why not?
* When will the truck route be chosen and will all the communities along the route be consulted and will a public input process involve these communities?
* How many trucks and trips over what period of time will be needed to fully transport the proposed materials? Is the material to be shipped finite or can stockpiles from other locations be added to the present stockpile at the Newport Indiana Facility? How will the public know if amounts beyond the present Newport stockpile are added?
* What is the statistical chance of an accident along this route with this number of trucks over this period of time (not just accidents caused by the trucking company, but any kind of accident)? Is there a highjack analysis done for the truck shipments? What is the Dept. of Transportation classification of the hydrolysate being shipped?
Delaware Riverkeeper Network Position: The Army should revert back to its original plan to treat and dispose of the VX Nerve Agent on site, at the Newport, Indiana facility. The Newport, Indiana community has been vocal in supporting this option and through an advisory committee worked for many years with the Army on devising a safe and effective process acceptable to all. This option also avoids the dangers that accompany a long transport of VX hydrolysate which contains dangerous constituents and can contain any amount under 20 ppb of VX nerve agent.
COMMENTS DUE APRIL 19, 2004
To Comment on this proposal write:
Newport Indiana Stockpile Outreach Office
P.O. Box 279
140 S. Main St.
Newport, IN 47966-0517
Fax: 765-492-4475.
Please copy:
Delaware Riverkeeper Network
P.O. Box 326
Washington Crossing, PA 18977
Fax: 215-369-1181
To report pollution incidents and other threats to our river or to become a Riverkeeper call the Riverkeeper Hotline at 1-800-8-DELAWARE.
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