This appendix summarizes information provided to the committee by public interest group representatives, including members of the Cease Fire! Campaign. Cease Fire! Campaign is a national coalition of more than 60 local groups that is a leading opponent of open burning (OB) and open detonation (OD). Understanding the basis for public concerns can play an important role in building support for proposals for implementing alternative technologies at specific facilities and communities. Failing to adequately address these concerns, on the other hand, could undermine support for promising methods of treatment, which could affect the ability of the Army to achieve its stated goal of increasing the use of alternative technologies in lieu of OB/OD. The reporting of the concerns of the public interest groups in this appendix does not imply any agreement or disagreement by the committee.
In their written presentations and verbal comments, public interest group representatives
- Described their concerns about OB/OD and a stated objection to OB/OD wherever it occurs;
- Expressed their support for identifying and using alternative technologies in lieu of OB/OD wherever possible; and
- Provided a list of criteria for decision makers to use in designing, evaluating, and selecting alternative technologies (presented in Appendix B).
The criteria and other input to the committee (e.g., “Camp Minden Dialogue Process,” Facilitators’ Report, March 15, 2015) are informed by the representatives’ experiences as neighbors of facilities that use OB and OD; by their experiences with waste incineration facilities; and by their experiences with the technology selection and decision-making processes used by other agencies, such as the U.S. chemical weapons demilitarization program. Notably, the majority of comments and written documents submitted by Cease Fire! members about OB/OD addressed facilities other than the seven stockpile depots that are the focus of this study. Indeed, as stated by the Joint Munitions Command chief of public affairs, there is very little overt controversy or opposition at the seven stockpile sites involved in conventional munitions demilitarization. Opposition appears to be most prevalent at Army munitions production sites, as well as at other federal agency (e.g., Department of Energy) sites where OB/OD is being carried out. However, members of the Cease Fire! Campaign are active at both the national and local levels, and as demonstrated in their presentations and documents, their concerns could impact activities at the seven stockpile sites that are the focus of this study.
The concerns expressed by representative of public interest groups are based on three intertwined issues:
- The characteristics of a technology and associated risks (e.g., the potential for catastrophic releases, the familiarity of a technology and its risks, types of secondary wastes generated, pollution abatement methods, distribution of risks and benefits within and among communities);
- The management of the technology (e.g., information is publicly available about how the technology and its pollution abatement system work, monitoring data are immediately available and accessible); and
- The processes for making decisions (e.g., whether they are viewed as being fair, transparent, and based on accepted and appropriate criteria).
Concerns expressed by the representatives are not limited to a particular treatment method; rather, they extend to the full demilitarization system and its management, which includes handling, storage, processing of material, treatment and disposal of secondary wastes, and intersite transportation of munitions and wastes.
CONCERNS ABOUT DEMILITARIZATION TECHNOLOGIES
The potential public health and environmental risks of treatment technologies are a primary concern expressed by those providing input to the committee. Their perceptions about these risks are a major contributor to public opposition to OB/OD and also the impetus of this report. These perceptions could also be the basis for supporting some alternative technologies and apprehension about other alternatives, such as incineration. For example, the Cease Fire! Campaign states that it “seeks to protect human health and the environment by calling for the immediate implementation of safer alternatives to open air burning, detonation, and non-closed loop incineration/combustion of military munitions.”1
Specific concerns that were expressed to the committee about designing, evaluating, and selecting alternative technologies include the following:
- The potential for contamination of surface and groundwater, soil, and air resulting from treatment activities. These concerns include the potential for both acute and chronic risks and impacts to the public, especially for vulnerable populations and those living close to the site. They include, for example, exposures from air emissions from specific events as well as cumulative and long-term risks from repeated exposures.2
- Nuisance risks that communities have experienced from OB/OD. These include property damage from vibration and blasts (e.g., broken windows and broken dishes), noise, odors, and dust.
- Inability to monitor and characterize emissions. Concerns about inadequate monitoring and the continuation of a long-standing concern about incineration emissions were very evident. As discussed in the following section, the ability to monitor and characterize a technology’s emissions is also closely linked with public confidence in the management process and in assuring the public that public health risks to the surrounding community are fully identified and evaluated.
- Redistribution of risks resulting from the increased transportation of munitions from one site to another to facilitate the use of non-OB/OD treatment methods or the selection of a technology that would require the shipment of secondary wastes, such as brine, to a subsequent site for final treatment. As stated in the presentations of Cease Fire! members to the committee, their opposition to shipment is based on global perceptions of harm and unfair redistribution of risks to receiving communities.
Although the representatives identified potential alternatives to OB/OD that have been developed or deployed, they do not necessarily endorse or support any one of these technologies; rather they want an assessment of alternatives, conducted independently of the Army, to assure communities of their safety. Their goal is for any assessment to “use their criteria to assess the technologies, then allow each community to decide what is important to them.”3 They recognize that all of the criteria do not need to be met before selecting a technology; rather that the criteria are aspirational and provide a list of issues that should be explicitly considered. For example, site-specific considerations could include proximity to nearby residents, proximity to tribal land, and demographics of nearby populations, including growth and encroachment of populations over time. In addition, physical characteristics may be relevant. Although controversial, one representative of the public commented to the committee that thermal treatment with pollution abatement is worth considering, especially if other alternatives to OB/OD require large volumes of water in water-scarce areas.
CONCERNS ABOUT THE RISK MANAGEMENT AND DECISION PROCESSES RELATED TO OB/OD AND ALTERNATIVE DEMILITARIZATION TECHNOLOGIES
Concerns expressed to the committee by representatives of public interest groups about the technical risks of technologies are closely interwoven with their concerns about the management of risks and decision-making processes associated with conventional demilitarization technologies. Although controversy and opposition appears to be concentrated at Army sites such as production sites that are not the focus of this study, their experiences with OB/OD in multiple contexts beyond the seven demilitarization sites color their views of Army management of conventional munitions demilitarization.
The intertwining of technical and management concerns is most clearly demonstrated in discussions about monitoring. In many statements public representatives revealed an underlying lack of confidence that emissions monitoring will be adequate to protect human health. As one representative emphasized, “A lot of what the community acceptance is about is about monitorability and our ability to know what is actually going on,” and:
1 For information about the Cease Fire! Campaign, see https://cswab.org/cease-fire-campaign/about-the-campaign.
2 While not within the scope of this study, the representatives also expressed concerns about the risks to public health and the environment posed by legacy wastes at sites with ongoing operations. They believe that residual contamination and unexploded ordinance within site perimeters may prevent a comprehensive identification and evaluation of the risks from current or future operations.
3 J. Williams, executive director, California Communities Against Toxics, and F. Kelley, member, steering committee, Cease Fire! Campaign, “Presentation to the National Academy of Sciences Committee on Alternatives for the Demilitarization of Conventional Munitions,” presentation to the committee, October 23, 2017.
Monitorability is very critical because that’s how we know what is actually happening. Everything can be perfect on paper but as we all know, if it’s not operated correctly, there’s something else that happens, [and] what you thought were the emissions may not be what the actual emissions are.4
The importance of monitoring all emissions, exemplified by technologies that can “hold, test, and release” (i.e., characterize all wastes—solid, liquid, or gas—before release), has long been emphasized by some members of the coalition.
Public interest group representatives expressed little confidence that the management of demilitarization activities will ensure protection of the public. As indicated in their expectation of an independent review by the committee, they believe that contractors’ evaluations and reports are subject to conflicts of interest and that state regulators lack the expertise and resources to effectively evaluate and monitor Army demilitarization activities. Comments received by the committee indicate that the loss of trust and confidence expressed by public interest group members is compounded by their past experiences related to other military programs—in particular, with the early phases of the chemical weapons demilitarization program, prior to the Assembled Chemical Weapons Assessment dialogue process. While many of their experiences have been at sites that are not the focus of this study, public interest group representatives expressed to the committee a general view that the Army’s actions and perceived failure to respond to public concerns have created an adversarial atmosphere at sites that are conducting OB/OD operations.
Additional concerns expressed by public interest groups and members of the public related to the management of demilitarization of munitions are reflected in their general views about Army management of OB and OD at various sites, and include their beliefs that
- Information provided to the public has been, at times, inconsistent or inaccurate.
- There has been a lack of opportunities for public involvement.
- There has been inadequate effort by the Army to investigate public concerns, including consideration of risks to vulnerable populations in decision making and a lack of transparency.
- The full costs of OB/OD, including environmental impacts, health impacts, and site remedial activities have not been taken into account.
- There has not been a serious effort by the Army to seek and use alternatives to OB/OD more broadly, as demonstrated by perception that
- The distinctions among different types of munitions and “accounts is artificial and bureaucratic”;5
- The responsibility for transitioning to alternative technologies is fragmented, especially with regard to public interactions; and
- There is a lack of funding for the implementation and research and development of alternative technologies.
At the same time, the committee was provided with information suggesting that public acceptance of alternative technologies, even when viewed as risky, may be possible when decision processes are responsive to community concerns and promote shared learning. This point is demonstrated by the experience at Camp Minden and with experiences with the U.S. chemical weapons demilitarization program (EPA, 2015, Attachment A). While Camp Minden is not one of the seven stockpile depots being studied, it is significant because of the active role played by the community in providing input into the state of Louisiana’s selection of an alternative technology for the treatment of 15 million lb of bulk propellant improperly stored at a contractor’s site, resulting in a significant safety hazard. The example is also significant in illustrating the way in which decision making based in technical evaluations is intertwined with public confidence in management process, especially transparency. Significant public outcry resulted in the reversal of the initial decision to treat the propellant by OB and the design of a decision-making process to quickly help the community, local officials, and regulators identify and evaluate alternative technologies to deal with the complex, emergency situation, even without full information about pollution abatement. The process of arriving at a solution involved a mixture of technical and process actions designed to improve, and assure the community of, process safety and the transparency of decisions;6 dialogue among stakeholders; information about the constituents and magnitudes of releases from the system’s pollution abatement system to the environment; methods implemented to ensure that the
5 The public interest groups that oppose OB/OD had anticipated that the congressionally mandated statement of task governing this study would encompass a broader scope and include all Army sites using OB/OD to treat waste munitions, bulk energetics, and associated wastes. While the committee acknowledges the groups’ concerns about the scope of the study, the committee was limited in its work to the sites addressed by the statement of task.
6 R. Hayes, president, El Dorado Engineering, “El Dorado Engineering’s Technologies for the Demilitarization of Conventional Munitions,” presentation to the committee, October 24, 2017; J. Williams, executive director, California Communities Against Toxics, and F. Kelley, member, steering committee, Cease Fire! Campaign, “Presentation to the National Academy of Sciences Committee on Alternatives for the Demilitarization of Conventional Munitions,” presentation to the committee, October 23, 2017; L. Siegel, executive director, Center of Public and Environmental Oversight, “Communities and Conventional Munitions Demilitarization,” presentation to the committee, August 23, 2017.
releases were monitored; independent experts from trusted sources who were able to observe tests and share information with the public in a way understandable to them; and a contractor open to scrutiny and responsive to questions and concerns (EPA, 2015). In the words of one public interest group representative who spoke about the Camp Minden experience at the Committee meeting:
Transparency is so critical. … There was a lot of distrust of [the Environmental Protection Agency], distrust of [the Department of Defense], distrust of our state government when we started and then we were able come to the table, arrive at a solution and build trust with each other. And a lot of that [trust] was built on every step of this process was going to be transparent—whatever technology was implemented, we wanted it to be fully transparent, we wanted to know how would the pollution abatement system work, how would they test for various emissions, how would we know that everything was operating the way it was designed to operate.7
The focus on transparency and other process features described above helped to build trust and acceptance of the selected treatment technology. The urgency of the situation also contributed to public acceptance of the technology used at Camp Minden by placing a premium on selecting an “off the shelf” technology that had already received approval by the regulators and the Department of Defense and could be implemented immediately.8 It also encouraged agreement among the various parties, even though the particular technology selected was not necessarily the preferred choice of every participant (EPA, 2015).9 Also significant, consistent with community members’ opposition, the state governor subsequently did not allow the facility to become permanent.10
In summary, the committee heard from comments and presentations from public interest groups that there is significant, national-level public opposition to the continued use of OB/OD. While there is general support for seeking and using alternative technologies that are perceived as having less public health and environmental risk, support is context-specific, as opposition may arise about particular alternative technologies in specific communities. Understanding the basis for public concerns can play an important role in building support for proposals for alternative technologies at specific facilities and communities, while failure to adequately address them could undermine support for promising methods of treatment. This, in turn, could affect the ability of the Army to achieve its stated goal of increasing the use of alternative technologies.
EPA (U.S. Environmental Protection Agency). 2015. “Results of the Camp Minden Dialogue Process, Facilitators’ Report, March 13, 2015.” https://www.epa.gov/sites/production/files/2015-03/documents/camp_minden_dialogue_facilitators_report_final_3_13_15_0.pdf.
7 J. Williams, executive director, California Communities Against Toxics, and F. Kelley, member, steering committee, Cease Fire! Campaign, “Presentation to the National Academy of Sciences Committee on Alternatives for the Demilitarization of Conventional Munitions,” presentation to the committee, October 23, 2017.
8 J. Williams, executive director, California Communities Against Toxics, panel discussion on October 23, 2017.
9 F. Kelley, member, steering committee, Cease Fire! Campaign, panel discussion on October 23, 2017.
10 More Questions Over the Future of Camp Minden Burn Chamber, https://www.ktbs.com/news/arklatex-indepth/more-questions-overthe-future-of-the-camp-minden-burn/article_64e58c2c-05c7-11e8-a329472c9a69530b.html.