Systems and Technologies for the Treatment of Non-Stockpile Chemical Warfare Materiel (2002)

As demonstrated in the literature and by the Army’s own experience in the chemical stockpile program, public involvement is key to the timely achievement of the Non-Stockpile Chemical Materiel Product’s (NSCMP’s) mission (NRC, 1994, 1996a, 1996b, 2000a, 2001a). The previous reports noted that the public should be thought of not as monolithic but as different “publics”— that is, stakeholders¹ whose interests, level of awareness and information, and desired level of involvement vary. Facilitating their input to a policy or technology and their understanding and ultimate acceptance of it involves identifying interested or affected stakeholders, providing open and timely information, discussing and clarifying the issues of concern, putting in place mechanisms to facilitate their engagement, and establishing procedures to evaluate the recommendations of these publics and to give them feedback on how and why their input was or was not used (NRC, 1996a, 1996c, 1999b, 2001a).

In evaluating public involvement issues facing the NSCMP and making recommendations on them for this report, the committee reviewed a schedule of NSCMP program activities; Army Regulation AR 360-1, which provides guidelines on the Army Public Affairs Program; and recent public involvement of the PMCD and its public outreach plans related to non-stockpile activities (Booz-Allen and Hamilton, 2000; U.S. Army, 2001h).

Committee members also monitored the Non-Stockpile Chemical Weapons Citizens’ Coalition (NSCWCC) and the Chemical Weapons Working Group (CWWG) Web sites and other National Research Council (NRC) publications and activities, as well as environmental publications such as Defense Environmental Alert and Superfund Report. In addition, the committee reviewed formal and informal discussions with, and documents provided by, stakeholders during its earlier studies (NRC, 1999a, 2001a). Primary stakeholders with whom the committee had met previously included federal and state regulators, representatives from the NSCWCC, the Citizens’ Advisory Technical Team (CATT) established under the ACWA Program, and the Core Group established by NSCMP.²

For this report, the committee sought the views of additional stakeholders on their program experience and recommendations to the Army concerning public involvement. The committee selected these stakeholders because their public involvement experience included non-stockpile issues (e.g., at Aberdeen Proving Ground) or focused solely on the non-stockpile program (Core Group and NSCWCC). The committee’s plans to meet with members of the public at Pine Bluff Arsenal, where non-stockpile facilities are planned, were not realized because no community-wide, site-specific outreach and involvement activities had been initiated by the installation at the time of this writing. The committee conducted both formal and informal discussions with the following stakeholders:

• A subgroup of the committee met with chairpersons of the Restoration Advisory Board (RAB) and the stockpile Citizens’ Advisory Commission, both at Aberdeen Proving Ground (APG), in March 2001.³

• One NRC committee member observed a RAB meeting at APG in July 2001, and a subgroup of the committee subsequently conducted a series of 1-hour telephone interviews with five RAB members representing a cross section of interests and backgrounds. Some of those interviewed were also members of the APG Superfund Citizens Coalition.

• A subcommittee conducted a 90-minute telephone interview with a representative of the NSCWCC.

• Two committee members observed a meeting of the Core Group in June 2001, gave a presentation on the committee’s activities, and talked informally with Core Group members.

• Two committee members and the study director made an initial visit in August 2001 to Pine Bluff Arsenal and the White Hall Outreach Office, one of two offices established by PMCD. They met with outreach staff and technical staff associated with the stockpile and non-stockpile programs, as well as with the chairperson of the Pine Bluff Stockpile Citizens’ Advisory Commission. Subsequently, two committee members observed the scoping meeting for the environmental impact statement (EIS), held in October 2001.

In their discussions with the committee, stakeholders provided input on several key program issues. Although the groups that they represent cannot be considered statistically representative of the public at large, these stakeholders indicate the viewpoints of informed and active opinion leaders that the Army should consider as it develops its overall strategy and plans.⁴

There is almost universal opposition to importing out-of-state wastes that could result in a site becoming a “dumping ground.” Mobile technologies are viewed as a way to address this concern—for example, a member of the APG/RAB said it is better for NSCMP to work on developing mobile technologies rather than on trying to find a state and a site willing to take everything. Many stakeholders acknowledged that there is no one answer for non-stockpile disposal: all situations are different and different options are needed. One person, for example, considered it a balancing problem and said that both permanent and mobile technologies are needed.

The use of stockpile facilities to dispose of non-stockpile items both within and between sites is generally viewed as a site-specific issue that depends on both technical feasibility and public acceptance. Public acceptance varies not only from site to site but also at individual sites. At APG, for example, some (but not all) citizens in Harford County with whom the committee spoke saw no problem, whereas citizens across the Chesapeake Bay in Kent County are strongly opposed. Some citizens viewed the use of stockpile facilities for non-stockpile items as a breach of trust and expressed concern that it could represent the first step in making their site a dumping ground for out-of-state waste (there seemed to be general agreement, however, that existing and planned facilities at APG will probably suffice for non-stockpile needs). At Pine Bluff, program staff informed committee members that state regulators are strongly opposed to use of the stockpile facility for non-stockpile materiel and indeed will not consider a permit modification to allow it.

Nonincineration technologies being developed by the NSCMP program appear to have broad acceptance. RAB members at APG strongly endorsed them as a needed ad

vance over open detonation, which had the potential for emissions to the atmosphere as well as noise. One of the members said that the non-stockpile program has a good reputation and characterized the technologies as “decent first steps.” This person expressed the view that the technologies are acceptable from an environmental perspective, both nationally and in the field. Members of the NSCWCC praised the Army for its efforts to develop nonincineration technologies that are both feasible and acceptable to the public.

Stakeholders generally had favorable views on deployment of the MAPS at APG and on the EDS. While MAPS was acknowledged as not providing a total solution since it does not destroy the agent, it was nevertheless supported by those with whom the committee spoke because it could deal with other wastes of community concern at APG as well as help to keep the Army from “using up” the EDS. However, as evidenced by a letter from a representative of the APG Superfund Citizens’ Coalition, some members of the local community are concerned about the cost of MAPS and the associated potential for DOD to consider its use for out-of-state waste in order to justify that cost.⁵ The EDS, in turn, was favored as a solution for materiel that must be destroyed immediately and would otherwise be detonated. One RAB member at APG, commenting on reported criticisms that the EDS is too costly and produces too much secondary waste, said that the first step in a new technology is never the cheapest and most efficient and that it has to be seen as something that will become a valuable tool as future generations are developed. Some Core Group members reported reservations about the Donovan blast chamber. While recognizing that it is able to handle more waste, they expressed concern that its effectiveness in destroying chemical agent had not yet been tested. Some also said that in judging a disposal technology, containment is more critical than destruction efficiency.

Some environmental activist groups continue to strongly oppose incineration—indeed, incineration is a hot-button issue that extends beyond the chemical weapons policy area. The NSCWCC continues to advocate storage of neutralent pending the development of nonincineration secondary technologies. It believes that postponing deployment of nonincineration alternatives is a viable option, given the slippage in meeting original CWC deadlines. An NSCWCC spokesperson said that broad public acceptance of plasma arc technology, currently under consideration for one of the facilities to be deployed at Pine Bluff, cannot be assured and hoped that NSCMP would not rush to put the technology in place. The spokesperson characterized plasma arc as a “synonym for incineration,” with the associated disadvantages of high temperature and potential for formation of dioxins and reported that environmental and public health organizations around the world are very concerned about the extent to which the technology is being promoted by some vendors. Similar reluctance to embrace the technology has been expressed by a Core Group member and author of a recent report (Lynch, 2002).

As reported previously (NRC, 2001a), NSCWCC has recommended several criteria for technology selection. These criteria are consistent with the findings from earlier ACWA and AltTech studies (NRC, 1999b, 1996c):

• ability to contain by-products and effluents for analysis and reprocessing

• ability to identify by-products and effluents

• low-temperature and low-pressure operation

• no production of dioxins or furans

• incorporation of pollution prevention (i.e., as little generation of secondary waste as possible) (NRC, 2001a)⁶

The NSCWCC’s advocacy of pollution prevention was also endorsed by a member of the APG RAB, although he noted that the cradle-to-grave concept of looking at a technology as a whole—taking into account the amount and type of secondary wastes produced—is moderately new to DOD. He added that this is a hard concept to get across to installations in the field that are faced with the everyday task of doing the work when there are too many tasks and too little time and money, and that it will take time for people in the defense community to view the issue holistically.

Everyone interviewed agreed on the need for public involvement in NSCMP decisions. When asked for suggestions on how the Army should deal with the communities near which it is proposing to construct new facilities,

interviewees cited three components of an effective approach and offered several recommendations:⁷

1. Early provision of information to the public—“openness,” “transparency,” “provision of as much information as possible,” “deal proactively with the public,” were frequent recommendations. RAB members at APG and the NSCWCC representative all commended the Army for its improved information flow and effort to be open with the public.

2. Willingness to go beyond the provision of information by listening to the public and establishing working relationships with it was recommended. At Aberdeen, for example, several members of the RAB commented favorably on the open provision of information, respect for citizens’ views, and openness to incorporating these views and priorities into decisions. Most RAB members interviewed by the committee pointed to the effective working relationship between the Army and community that had resulted from such an approach.

3. Inclusion of the public in identifying and addressing the trade-offs inherent in developing strategies, systems, and facilities was recommended. All persons with whom the committee spoke acknowledged the complexity of the non-stockpile program and the challenges faced by management. Several recommended that the Army include the citizens who are most affected by Army decisions in the process of identifying and resolving trade-offs in the selection of disposal technologies and that it put in place mechanisms that allow active community input early in the process, when critical decisions are being made.⁸

For example, in discussions with the committee in open session, citizen representatives cited the dialogue process, including its linkage to affected communities, established by the ACWA program as a model for early and direct public involvement in technology decisions (NRC, 2001a).⁹ In particular, they noted the trust engendered among all participants by a process in which public input was valued and recognized as an essential part of developing a solution. An APG member added that, regardless of the specific technology, there are critical considerations such as waste streams, long-term risks, and stability and that educated community members may have perspectives on these criteria that are very different from those of a military entity, regulatory agency, or private company. He expressed the view that to not consider these differing perspectives is foolish in this day and age.

It was apparent from the discussions that almost all of those interviewed rated the Army and the non-stockpile program highly for their performance on the first two public affairs components—specifically their increased openness in providing information and in listening to, and developing relationships with, a range of stakeholders. Some stakeholders said, however, that there is room for improvement, particularly in terms of providing involvement mechanisms for citizens to provide input to decisions. At APG, for example, one RAB member reported that, in his opinion, there has been “reasonable” involvement and that the program is headed in the right direction. However, he believes the non-stockpile program and the military in general have a long way to go in terms of understanding what adequate and effective public involvement really is.

In addition, some stakeholders said that NSCMP needs to recognize the public’s ability to help NSCMP management achieve its program mission. One stakeholder said that many of the personnel are engineers who see the public as a stumbling block rather than a positive force that can work effectively with them to achieve their mission. This individual further noted that there is a lot of historical baggage, there needs to be greater trust in the public and regulators to come up with innovative ideas, and that the Army needs to make some shifts in its assumptions, based on success stories, to date. Another stakeholder said that the government should

stop spending millions of dollars on a product that it only assumes will be acceptable to the community. He cited as an example the Army’s preference for incineration, which it views as an efficient, working technology. He pointed out that if Army personnel had a relationship with people at a site, they would soon find out that incineration is not acceptable to the local community. He said he viewed involvement as a process of thinking ahead before developing plans and spending millions of dollars, but noted that this view goes against the institutional way of thinking. He believed strongly that the non-stockpile program needs to expand its involvement activities in order to move ahead.

Several success stories were related. A member of the RAB at APG noted how the RAB enhances the Army’s ability to overcome its narrow technical focus and see the big picture from the community’s perspective. Other members of the RAB cited specific ways in which RAB recommendations on facility design and emergency preparedness had been adopted by the Army. Some pointed to the value of public input in moving the Army from its previous focus on the most contaminated areas at APG to a new focus on land and waterway boundary areas, where the risk of public exposure is greatest. Core Group and NSCWCC representatives pointed to the valuable role that members of the informed public had played in facilitating EDS deployment at Rocky Mountain Arsenal. NSCMP acknowledged in Core Group meetings that the Core Group and other members of the public, who had been informed about the EDS by public affairs staff, played a very positive role by advocating the use of EDS in discussions with the EPA, state regulators, local officials, and skeptical members of the public in communities near the arsenal.

Based on a review of program documents, several observations can be made about NSCMP public affairs activities. For this section the committee reviewed Army Regulation (AR) 360-1,¹⁰ recent NSCMP public involvement planning documents (Booz-Allen and Hamilton, 2000; U.S. Army, 2001h), information provided at Core Group meetings, the schedule of NSCMP program activities, and information provided at the EIS scoping meeting in Pine Bluff and during the earlier visit to the arsenal of some members of the committee.

First (consistent with the information provided in the committee’s discussions with stakeholders), activities recommended in AR 360-1 and described in the public affairs strategy and the Pine Bluff public outreach plan (Booz-Allen and Hamilton, 2000; U.S. Army, 2001h) focus almost exclusively on providing information and opening channels of communication to hear stakeholders’ values, concerns, and needs (i.e., the first two components of a public affairs program).¹¹ While NSCMP is to be commended for its commitment to improving these activities, including placing a priority on interaction with Native Americans and on addressing environmental justice issues, Army and NSCMP management commitment to the third component, public involvement, is lacking. The committee’s observation indicates that current activities—particularly at APG and with the Core Group—appear to be leading to improved dialogue and relationship building with a diversity of groups. However, the program does not include a means of linking national-level and local-community dialogues, either in the Core Group structure or in a formal process for influencing decisions, such as the ACWA dialogue, that is recognized and supported by senior Army decision makers. As demonstrated in the present report, there are many trade-offs to be addressed by the Army in developing strategies, systems, and facilities, yet the affected public is not formally involved in assessing these trade-offs.

Second, the project schedules provided to the committee by NSCMP reveal several weaknesses, particularly in relation to public involvement and permitting. In general, there is an inconsistent use of milestones, making it difficult to measure progress and perhaps leading to the neglect or delay of important issues. Several specific weaknesses, discussed below, appear to indicate that the involvement of stakeholders is viewed as a requirement of the law and not as an integral and valued part of NSCMP’s overall decision-making process.

Specific weaknesses associated with public involvement include the following:

• Public involvement and permitting are treated as independent activities that have no effect on other activities or decisions, indicating the absence of a relationship between public contributions and program decisions and the apparently low value placed on the former.

• Only the minimum time called for by law is set aside for considering and incorporating public comments,¹² indicating an unrealistic time frame for public review by all (not only local) stakeholders, particularly in view of the stockpile program’s experience of public opposition and associated program delays.

• Public involvement activities (other than time scheduled for public review of the National Environmental Policy Act and permitting documents) are linked only to the pre-operational and operational phases rather than to the construction and design phases of the non-stockpile facility proposed for Pine Bluff, a sign that “involvement” comes only after critical technical decisions have been made.

• Public involvement activities are included only for local stakeholders at Pine Bluff, indicating a gap between national and local activities and the potential for underestimating the impact of national stakeholders on program decisions.

• There is no mention of any of the alternative nonincineration technologies currently being designed and tested by NSCMP, indicating that they are not being considered for possible introduction.

• There is only limited training of managers in interacting with the public. The project schedules show one day of training in risk communication, with no indication as to the intended recipients (is the course for public affairs staff only, or for management?). Non-stockpile public affairs staff are to be commended, however, for having very recently provided awareness training on Native American perspectives for project managers. Similar training on African-American perspectives is planned in the future. However, no management training in interacting with other segments of the public is planned or referenced in the project schedules.

Third, in discussions with this committee, NSCMP spokespersons consistently emphasized the importance to the program of the plans being developed for a non-stockpile facility at Pine Bluff Arsenal. Yet, the limited plans for public involvement in Pine Bluff facility decisions contrasted sharply with the high level of RAB members’ awareness of non-stockpile activities and the public involvement activities conducted by the garrison commander at Aberdeen Proving Ground. For example, as committtee members who visited the arsenal and the outreach office at Pine Bluff learned, community outreach and provision of site-specific information on the envisaged non-stockpile facilities and plans were not conducted among the Pine Bluff community until immediately before and during the EIS scoping meeting. PBA staff said that one reason for this lack of site-specific non-stockpile information and outreach was the higher priority assigned to stockpile program needs. Site personnel also believed that their local public is very supportive of arsenal activities and disinclined to become actively involved. Further research is needed to systematically characterize community views and interpret the limited public attendance at the scoping meeting and the paucity of public comments submitted on the Pine Bluff EIS. Experience at other stockpile sites shows the need for coordinated, consistent program-wide planning for and implementation of public involvement. In particular (1) continued local public support cannot be guaranteed and must be carefully nurtured, as it was at APG, and (2) attention must be paid to the full range of stakeholders likely to become active and have the ability to affect program decisions.

Finally, as evidenced in recent public involvement and public outreach plans for non-stockpile activities (Booz-Allen and Hamilton, 2000), NSCMP does not have the authority to direct information, outreach, and involvement programs at the many sites where non-stockpile chemical materiel may be found. The document specifies that authority resides with the installation commander who “will request assistance from NSCMP as appropriate” (Booz-Allen and Hamilton, 2000, p. 18). Thus, without agreement between NSCMP and the installation on program priorities, NSCMP is limited in its ability to develop public involvement activities that are consistent across sites, that respect national program priorities and needs, and that respond to local concerns and audiences.

Finding 5-1. NSCMP has become more open in providing information and in developing relationships with a range of stakeholders concerning NSCMP issues. The committee finds, however, that there is room for improvement in three areas:

• coordination of the missions of the program and the installations and associated public involvement plans and activities to ensure that NSCMP develops public involvement activities that are consistent across sites and concur with national priorities and needs

• expansion of public affairs programs to emphasize the development of involvement (as opposed to outreach) activities that engage the public at both the local and national levels and allow them to contribute to program decisions

• integration of local, site-specific public involvement activities and national-level public involvement activities into NSCMP project schedules to provide opportunities for all interested citizens to affect key decisions

Recommendation 5-1. As with RAP activities, public involvement should appear seamless across Army programs and transparent to local and national stakeholders. The committee recommends that the Army establish central direction

to ensure coordination of program and installation missions and to promote continuity and consistency in public involvement programs across installations and between program and installation staff.

Recommendation 5-2. The committee recommends that the Army expand its public affairs program to include involvement as well as outreach activities. Specifically, for the Army to gain from lessons documented in studies of the stockpile program, the committee recommends as follows:

• The Army should direct installations to implement, in coordination with program staff, a strategy that includes development of public involvement mechanisms. Such mechanisms must be fully integrated with project schedules so that the public has a genuine opportunity to provide input to project decisions. Their goal must be to engage both the local public and other stakeholders in discussing and evaluating the various technologies being considered and to provide a continuing means of involving them in future planning efforts and project decisions.

• The Army should conduct public involvement training for program and installation personnel, including commanders, public relations, and program technical staff. Such training must be more extensive than a one-day training course in risk communication and must be conducted very early in the program. The training should be provided on a continuing basis to ensure adequate preparation of newly assigned personnel.

• NSCMP should consider how the program could more effectively use existing mechanisms, such as the Core Group, to include and engage citizens at the local level as well as the national level in identifying specific concerns and considering the trade-offs inherent in program decisions.