| 5 | Johnston Island: destruction of the US chemical weapons stockpile |
Introduction
Chemical weapons were first used during the First World War – with well over a million casualties and almost 100,000 deaths, including more than 50,000 Russians. The United States, concerned about potential use of these weapons against our troops, built a chemical weapons arsenal during the First World War, and that stockpile steadily increased. The United States began destroying the weapons during the late 1960s, under the so-called CHASE program (“cut holes and sink ‘em”). In 1985, decades after building the second largest chemical weapons arsenal (the USSR had more weapons), Congress ordered the US Army to destroy its aging chemical weapons stockpile. Many of the weapons had become a threat to US soldiers, workers, and nearby populations. Congress was persuaded that some weapons could accidentally detonate and/or self-ignite. The 31,500 metric tons of weapons were stored at eight sites on the continental United States and at Johnston Island, an atoll about 800 miles from Hawaii (Figure 5.1).
The US stockpile consists primarily of vesicants (blistering agents) and organophosphorus nerve agents (Munro et al. 1999; National Research Council 2001). All of these chemical weapons can be lethal under certain conditions. Table 5.1 shows their major impacts on human health. The blistering agents may also be carcinogenic. Individuals who routinely handle these weapons told the author that they were more concerned about the vesicants than the others because of their blistering properties.
Location of Johnston Atoll in the central Pacific Ocean
Table 5.1 Major chemical warfare agents
Type |
Agents* |
Symptoms and health effects |
Vesicant agents |
HD (mustard) |
Blisters develop in hours to days; eyes and lungs affected more rapidly; timing for vapors is 4–6 hours; skin effects at 2–48 hours |
Nerve agents |
GA (tabun) |
Potent cholinesterase inhibitor; difficulty breathing, sweating, drooling, convulsions, dimming of vision; incapacitates at low concentrations, kills at sufficient dosage; timing for vapors is seconds to minutes; skin effects at 2–18 hours |
Respiratory agent |
Phosgene |
Difficulty breathing, tearing of eyes, damage to and flooding of lungs, suffocating, death; timing is immediate to 3 hours |
Blood agents |
AC (hydrogen cyanide) |
Rapid breathing, convulsions, and coma; kills at sufficient doses; nonpersistent, inhalation hazard, immediate effects |
*GA (tabun) = N,N-dimethyl phosphoroamidocyanidate; GB (sarin) = methylphosphonofluoridate isopropyl ester; GD (soman) = pinacolyl methyl phosphonofluoridate; H/HD (mustard) = bis-(2-chloroethyl)sulfide; HN (nitrogen mustard): HN1 = bis(2-chloroethyl)ethylamine; HN2 = bis(2-chloroethyl)methylamine; HN3 = tris(2-chloroethyl)amine; VX = S-(diisopropylaminoethyl) methylphosphonothiolate O-ethyl ester.
Number of weapons is a reason why some sites are more dangerous than others. The Tooele (Utah) site housed 13,600 metric tons, as compared with only 523 metric tons at the Lexington–Blue Grass (Kentucky) site. However, each ton is not equally hazardous (Table 5.2). About 60% of the original weapons stockpile had been stored in bulk containers (called “ton” containers), similar to tanks used for storing propane and other bulk liquids. These containers had no attached fuel or explosives, so they were less hazardous.
About 40% of the stored munitions consisted of more dangerous artillery projectiles, bombs, cartridges, land mines, mortar rounds, and spray tanks. They are more worrisome because fuel and explosives are part of these assembled weapons. The older weapons are troublesome. X-rays allowed us to see inside the weapon, and what we sometimes found was that the agent had decomposed into liquid, solid, and gas. The behavior of these compromised weapons, if disturbed, was less predictable than when the weapon was manufactured. Another issue is that some weapons were not perfectly manufactured and are more likely to leak. When found, these “leakers” are stored in another container (overpacked). Also, when the Army attempted to remove the explosives, the device that was supposed to unscrew the front-end did not always work because of manufacturing inconsistencies. The Army had to build a new device to remove the explosives, and meanwhile had to set aside these weapons. Much, but not all, of the entire aging stockpile was stored in earth-covered bunkers, colloquially called “igloos.” The igloos could, under some conditions, be breached by an explosion.
Table 5.2 Distribution of unitary chemical weapons stockpile, by storage location, February 2010
*See Table 5.1 for description of warfare agents; HT (mustard) = bis2(2-chloroethylthio)ethyl ether.
†B = bombs; C = cartridges, mortars; M = mines; P = projectiles; R = rockets; ST = spray tanks; TC = ton containers.
Risk also depends on the fate and transport characteristics of the agents and their by-products. The Army developed rigid protocols to limit risk; for example, workers, air inside the destruction facility, outdoor air quality, stack exhaust, decontamination solution, fuels, use of protective suits, and equipment all must be tracked and managed (US Army 1988; National Research Council 2001). Chemical weapons destruction facilities have sophisticated monitoring equipment that can detect very low concentrations of agent. Workers are not permitted to enter rooms with agent unless they are in pairs, and they enter in sealed, impervious suits. The author was told of instances of employees being discharged from these high-paying jobs for what many would consider minor violations of these requirements. He witnessed one such incident, when a civilian contractor who could not find his gas mask borrowed another gas mask, and was fired for this violation of protocol. Nevertheless, no-one could say with 100% certainty that agent could not hurt the workers or escape the destruction chambers. Consequently, at Tooele, for example, carbon filtration was added to the emissions control system.
The number of people who could be exposed is another risk factor. Fortunately, nearly all of the weapons have been stored in remote locations. Johnston Island, the case study for this chapter, contains only military personnel and civilian contractors or visitors. Tooele, the site with the largest proportion of weapons, has some farms and homes within 10 miles (16 km) of the site, but the nearest large population cluster is Salt Lake City, more than 50 miles away. The riskiest situation involved Pine Bluff, Arkansas, where people lived within a mile of the site. Initial risk assessments at each site showed that doing nothing was riskier than moving and destroying the weapons. For example, estimates based on very conservative assumptions were one or more public fatalities in 20 years of continued storage at the Pine Bluff site at a probability of 3.03% (1 in 33), which compared with 1 in 20,000 in the case of on-site incineration of the weapons (US Army 1996, 1997).
While the main concern of the US Congress was human health risk associated with accidental or deliberate detonation of chemical weapons, international relations played a role in the call for destruction of these weapons of mass destruction. Following the devastating use of chemical weapons during the First World War, the United States signed the Geneva Protocol of 1925, and in 1972 it signed the chemical weapons treaty. Both signatures did not guarantee international compliance because neither addressed verification of weapon destruction. In January 1993, the United States signed a United Nations treaty, yet the US Senate did not ratify it until 1997. The delay was caused by members of Congress who asserted that some nations would not sign, and others would sign the treaty but violate it. Congress was also concerned about industrial espionage during inspections in the United States (General Assembly of the UN 1992; Committee on Foreign Relations 1996; Rotunda 1998; Yoo 1998). The UN treaty required that 1% of the weapons be destroyed by April 29, 2000. In fact, 15% of the US stockpile had been destroyed by 2000. In comparison, Russia, with a stockpile of 40,000 metric tons, did not meet the year-2000 deadline owing, it claimed, to a lack of funds (Greenberg 2003). By signing the international treaty, the United States agreed to eliminate the stockpile by April 2007, with the possibility of a 5-year extension.
Also, in 1990, the United States signed a treaty with the then Soviet Union that required 80% of their stockpiles to be destroyed, as well as production of chemical weapons to cease. Overall, the US Congress, a bilateral treaty with the USSR, and the UN treaty all required destruction of the US chemical weapons stockpile.
As part of its requirements, the US Congress required the Army to monitor progress toward destruction of the stockpile. The stockpile destruction program was to be overseen by the National Research Council, the US Department of Health and Human Services, the Centers for Disease Control and Prevention, the Environmental Protection Agency (EPA), the Council on Environmental Quality, the Occupational Safety and Health Administration, the Office of the Secretary of the Defense, and state and local government agencies. Furthermore, the Army required citizen advisory commissions to bring state and local public concerns about disposal to the Army, and promote public involvement at each of the eight continental US sites (National Research Council 2000a).
Several controversies have marked the program. The first was that, until the 1970s, the Army disposed of its unwanted munitions by burning them in pits. This caused mistrust on the part of communities. When the author visited some of the sites, residents reported feeling deceived and were reluctant to trust the Army. During the 1970s, the Army began considering neutralization and incineration. Incinerators were built on Johnston Island in 1990 (see below). Incineration has been criticized by some citizen groups (most notably the Chemical Weapons Working Group) and certain elected officials. The Chemical Weapons Working Group and others filed an environmental justice complaint with the EPA asserting that the Army was not fulfilling its mandate by opting for incineration. The Army did, in fact, use neutralization (e.g. hydrolysis) at several sites, but this also was not risk-free (National Research Council 1998, 2000b). Incineration was the main technology at five sites; hydrolysis and related methods were used at the other four sites (Table 5.2).
A second controversy at some of the sites was about emergency planning and management. At some sites, the Federal Emergency Management Agency (FEMA), which is responsible for the off-site plans, had a difficult time working with some state and local governments. For example, in 1996 the US General Accounting Office determined the readiness of the Anniston area for a chemical emergency event. The GAO concluded that the site was not prepared, that two-thirds of the money already allocated had not been spent, and that the Army, FEMA, and the state and local governments were in disagreement regarding fund amounts and allocation (GAO 1996). These problems continued, but were eventually solved and the weapons were destroyed (GAO 1997, 2001).
Cost has been a less controversial issue. In 1985, the cost of disposing of the chemical weapons was estimated at $1.7 billion (Lambright et al. 1998). Other estimates place the estimate at over $12 billion (WILPF undated), and this author's estimate is no less than $20 billion. In addition, there are large amounts of munitions and non-stockpile items that were part of the program, which will cost many more billions of dollars to destroy.
The destruction of the US chemical weapons stockpile represents a massive expense per dollar invested in the protection of the public's health (see also Chapter 6) for a high-consequence but very low-probability risk. The Army did not expect a series of technology decisions would be turned into a clash of values and morality, in which they would be portrayed as not doing everything possible to protect the public's health. The Army also has an ethical commitment to destroy these weapons because of the potentially stigmatizing effect of these stockpiles. In February 2010, the Army reported that 71% of the stockpile had been destroyed, including nearly all the fully armed and most dangerous weapon configurations, and including all the agent and weapons on Johnston Island (CMA 2010).
The remainder of this chapter focuses on the first place where US chemical weapons were destroyed: Johnston Island. I picked this location for three reasons. First, Johnston is about as remote a location as possible; therefore, it would be logical to assume there was little public interest. However, there was a substantial reaction to the Second Supplemental Environmental Impact Statement (SSEIS; US Army 1990a,b), which in ways described below was quite different from common NIMBY responses (see also Chapters 1 and 4). Second, Johnston was the first site to build and operate multiple incinerators for just these agents and munitions (and a variety of other supporting technologies). Johnston Island was an amazing engineering feat. Before describing the Johnston Island SSEIS, I should point out that I served on the Third NAS stockpile committee for about 6 years. However, I played no role in the Johnston EIS process described in this chapter.
Johnston Island, the destruction of chemical
weapons, and an ethical challenge
Johnston Island is an unincorporated US territory located in the central Pacific Ocean about 800 miles (1300 km) southwest of Honolulu, Hawaii (Figure 5.1). It is about 2 miles long and half a mile wide, and is about 6 feet above sea level. It is the largest of four islands: East, Johnston, North, and Sand (Figure 5.2). As
Johnston Island shipping channel and ship wharf area
a visitor to the island, the dominant visual impression is the runway that runs down the middle of the island. For the author, this was reinforced one morning while out jogging and faced with red warning lights flashing at the end of the runway, meaning get away from the runway because an airplane is approaching to land (Figure 5.3).
Johnston has an area where nuclear materials, non-chemical weapon materials and contamination are found; overall, the impression of the island is similar to being on the deck of an extremely large aircraft carrier. However, Johnston Atoll has been a National Wildlife Refuge since 1940. Several of the author's colleagues have asserted – and demonstrated – that the area surrounding the island has some of the best fishing immediately offshore in the Pacific.
Johnston Island already had chemical weapons before the SSEIS in this chapter was written: unitary chemical weapons moved from Okinawa in 1971. Unitary chemical agents and weapons are to be distinguished from binary chemical weapons. Binary weapons are built so that the toxic agent is not active in the weapon. The weapon has to be launched before the chemicals mix and become active, which makes it much safer before launch than the unitary munition. The unitary weapon contains the lethal or incapacitating mixture. Note that Johnston Island, even with its full complement of weapons, accounted for about 6% of the stockpile (see Table 5.2).
In 1983, the Army prepared an EIS for the construction and subsequent operation of an incinerator on the island (US Army 1983), and in 1988 it prepared the first SEIS (US Army 1988) to consider how to manage the wastes produced by the incineration process for the weapons already on the island.
In the case of Johnston Island, the life cycle of the destruction of chemical weapons moved to Johnston Island from Germany had six steps:
- 1 moving the weapons from existing storage near Clausen, in RhinelandPalatinate, Germany, onto vehicles
- 2 moving the weapons to Bremerhaven, Germany for transfer to Johnston island
- 3 transport of the weapons on two ships to within 19.2-km (12-mile) territorial limits of Johnston Atoll, which took 1.5 months
- 4 unloading the weapons and bringing them to Johnston Island, where they were to be stored for incineration
- 5 incinerating the weapons 6 managing the waste products.
- 6 managing the waste products.
This SSEIS deals with steps 4 and 5, and more briefly discusses steps 1–3 and 6. By focusing on steps 4 and 5, as described below, the SSEIS arguably did not discuss the most serious risks, and the risks that most distressed public stake-holders.
The lead agency for its preparation was the Department of the Army (DOA), the Program Manager for Chemical Demilitarization. Five federal agencies cooperated in the preparation of the documents: the Defense Nuclear Agency;
Location of facilities and major roadways on Johnston Island
the Department of Commerce, National Marine Fisheries Service (NMFS); the Department of Energy (DOE); the Department of the Interior, Fish and Wildlife Service (FWS); and the Environmental Protection Agency.
As mentioned above, the ethical dilemmas inherent in this proposed action and underscored by this SSEIS were the major reason for choosing this case study. I raise two questions at this point in order to underscore the issues. Was it appropriate to include only minimal information about the first stages of the life cycle of the destruction of the agents and munitions? With regard to this question, not every EIS in this volume covers the entire life cycle of an action. For example, Chapter 4 examines the construction and operation of an LNG facility near Baltimore, Maryland. That EIS did not include the impact of securing the natural gas from the ground (risk and impact outside the United States), nor the risk of loading it on a massive ship. It did not discuss risks associated with the ocean voyage. The chemical weapons SSEIS has the same omissions. The chemical weapons SSEIS says that:
other phases of the movement of the European stockpile will be addressed in separate environmental documentation. Environmental analyses of the movement from existing storage to port in FRG is the responsibility of the host nation. The ocean transportation to the 19-km (12-miIe) limit of Johnston Atoll and possible alternatives have been assessed in a separate Global Commons environmental assessment under Executive Order 12114.
(US Army 1990a, p. 23)
A stated objective of the Johnston Island chemical weapons project was to destroy the Asian chemical munitions already on the atoll. But the second piece of that technological challenge was that it was to serve as a proof-of-method demonstration of the Army's preferred method of disposing of the stockpile of unitary chemical agents and munitions. Is the blatant statement and implementation of that principle in this location appropriate, given the history of the area?
Preferred action
The preferred action was to incinerate the stockpile of NATO chemical munitions at Johnston Island. The SSEIS reported that these munitions consisted of about 100,000 munitions of 8-inch and 155-mm projectiles containing VX and GB nerve gas agents. These weighed approximately 430 tons. As noted earlier, the proposed action does not begin with moving the weapons from their locations to Johnston Island.
Nevertheless, beginning at the start of the process, the Army placed the munitions on pallets, and these in turn were packed in containers. The inner of two containers is built to be vapor-tight and meets International Maritime Dangerous Goods Code requirements. In turn, these were packaged in military vehicles (so-called MILVANs) that are not airtight for further control and protection. Two ships accompanied by US naval vessels (route kept secret) brought the ordinance to within 12 miles of Johnston Island.
The SSEIS officially begins with the two ships being guided by tug boats to the atoll's wharf. The naval escort stays with the second ship while the first is unloaded. The process of transferring the munitions to the island, the report says, takes 2 weeks.
The second phase is to unload the two ships containing the weapons. Each ship's on-board overhead cranes, the report says, are used to offload the MILVANs to transport trailers. An important step in this process is that each MILVAN is monitored for leaking agent. Any found to be leaking are moved immediately to the chemical exclusion area on the atoll and decontaminated. The MILVANs are then to be transported to the chemical exclusion area while guarded by military police.
The third phase is placement of the weapons in the chemical storage area until they are incinerated. The area is heavily guarded and monitored by lighting, and protected by barricades and intruder detection devices. Some munitions already on site will be destroyed first, and then the European munitions will be placed in the on-site igloos. The report estimates this will take 120 days. The note expects the actual incineration will take 3.5 months.
The last phase requires removal of the MILVANs (they are reused) and movement of waste to a site on the continental United States for disposal.
The SSEIS focuses on five impacts, and judges all of them to be insignificant:
- increase in land use for temporary holding of MILVANs
- increase in the total number of chemical munitions in storage
- increase in the total emissions and wastes from 3.5 additional months of operation
- temporary increase in the number of workers residing on Johnston Island
- increased potential for an accident that could release chemical agent into the environment.
Because the document has no major impacts to report, it makes no sense to go through the exercise of reviewing every potential impact. Table 5.3 lists the major categories of impact considered in the SSEIS.
It does make sense to illustrate the carefully crafted responses in the document. For example, here is a verbatim presentation on threats to endangered species:
The only rare species of reptiles in the Johnston Atoll area are sea turtles. The threatened green sea turtle (Chelonia mydas) and possibly the endangered hawksbill turtle (Eretmochelys imbricata) have been observed feeding at Johnston Atoll, although nesting is not known to occur. Green sea turtles are much more common and are often observed feeding along the south shore of Johnston Island. It is estimated that 200 green sea turtles use this
Table 5.3 Environmental impacts considered for Johnston Island EIS
Water resources |
Groundwater |
|
Ocean water |
Air quality |
|
Ecology |
Terrestrial |
Waste management |
Liquid process waste |
Analysis of potential accidents |
Agent releases to the atmosphere (effects on humans and ecology) |
Worker safety and agent monitoring land |
Occupational safety and health |
Cumulative impacts |
Air quality |
Unavoidable adverse environmental impacts |
|
Irreversible and irretrievable commitment of resources |
|
Short-term use and long-term productivity |
|
area of Johnston Atoll as a feeding ground. NMFS studies done in 1983, 1985, and 1987 found that green sea turtles at Johnston Atoll were more healthy and robust than turtles studied in the northwest Hawaiian Islands. Three turtles tagged in that study were subsequently sighted in the Northwest Hawaiian Islands. From these sightings. -. . . The Johnston Atoll and Hawaiian Island green sea turtle breeding population are the same. The resident FWS managers state that the turtle feeding ground near the sewage outfall has one of the highest concentrations of green sea turtles at DOD-nesting foraging grounds in the Pacific.
Unlike other islands in the Pacific where the green sea turtle is protected but still taken for food by local inhabitants, the combination of strict government control of Johnston Island and resident FWS personnel ensures protection of the local green sea turtle population.
(ibid., p. 55)
The impression is that the Army is protecting the species, which indeed is likely to be the case.
Not surprisingly, on-site personnel were concerned about occupational exposures and safety. Here is a flavor of what the document says about this issue and what already happened on it:
Numerous health and safety plans, including the JACADS [Johnston Atoll Chemical Agent Disposal System] Safety and Occupational Health Plan and the Johnston Atoll Medical Support Plan, establish procedures to ensure the health and safety of individuals working in munitions disposal operations. All JACADS personnel are given training and information on hazardous chemicals in their work area before their initial assignment and whenever a new hazard is introduced into their work area. On-going training topics include accident prevention; wearing, adjusting and caring for protective masks and clothing; emergency procedures; and decontamination procedures. All personnel arriving on Johnston Island are briefed on chemical agent effects; they are issued and fitted with a protective mask.
Agent monitoring . . . is provided to ensure rapid response if leaking agent is detected, in which case procedures from the CAIRA Plan would be initiated. These procedures define activities to protect workers and to respond to a chemical release. The Army has conducted a preliminary assessment of potentially hazardous areas on Johnston Atoll to determine the nature and degree of threat posed by these areas and to identify areas that may require immediate cleanup activities. Two areas of concern are a former herbicide (“agent orange”) storage area and an area containing plutonium-contaminated soil. The former herbicide storage area is located on a peninsula at the northwest side of the island. Previously, herbicide was inadvertently spilled in this area. Access to this area has been restricted by fencing. All island personnel are briefed about the restricted area and Johnston Island security personnel routinely monitor the area. The US Air Force has responsibility for cleanup activities in this area. The plutonium contamination resulted from the malfunctioning of missiles during the 1962 atmospheric nuclear tests conducted by the United States.
(ibid., pp. 73–74)
An interesting footnote to the above description is that David Gibbs, a maintenance pipe welder, was killed on November 27, 1997 when a piece of equipment fell on him that was part of the Deactivation Furnace System. The accident analysis showed that the contractor had not been instructed in the proper safety practices for this task. The author knows of no other fatalities at Johnston.
Accidents
Prior to the SSEIS, the US Army (1983, 1988) had analyzed 3000 possible accidents, rating each by likelihood, the potential amount of agent that could be released, the type of agent, how it could be released (spill, detonation, or fire), accident locations, and the duration of time of the release. The SSEIS lists one “worst credible accident” for:
- storage in igloos
- disposal and handling operations
- interim and continued storage
- MILVAN handling and transport.
The EISs concluded that the accidents have likelihoods of less than one chance in a million. If they occurred, then there would be some potential health effects. The current SSEIS presented a more sophisticated modeling analysis than did the prior version, and this presentation was enhanced by the presence at the public hearing of an expert from the Oak Ridge National Laboratories, who carried out plume simulation models.
The report presented two types of accident analysis: one is a detonation, fire, and/or spill leading to an airborne release; the second is a water emission resulting from a spill. For example, the report considers a plane crash into a metal building holding agent, leading to a spill, as the most serious water accident. The report acknowledges the possibility of serious damage near the spill, but states that the agent would dilute in the open ocean. The modelers conclude that, in the case of an airborne emission, lethal exposures could extend as far as approximately 62–76 miles for the air and 14 miles for the water emission, but would not reach Hawaii (these were worst-case scenarios).
In this regard, the report notes:
The accident analysis presented in this section involves many conservative (i.e., pessimistic) assumptions. Worst case accident scenarios and worst case meteorological conditions are used to establish the absolute upper bound on any potential effect of chemical agent accidentally released to the environment. Those accidents are extraordinary events with an extremely low likelihood of occurrence; it is further assumed that no actions are taken to control or mitigate the consequences of such an accident. The result of these assumptions is the identification of a hypothetical zone of potential impacts that can be used to describe the boundary beyond which adverse environmental impacts would not be expected to occur.
(ibid., p. 63)
Activities and land uses on the crowded atoll were planned at least partly to protect the 1200+ occupants. Unloading from the wharf would not occur when winds could injure personnel. The storage areas were located downwind from housing. With regard to the environment, the SSEIS reports that the bird population nests upwind but feeds downwind of the incinerator site. A release could harm them, depending on the amount and time of exposure. The endangered humpback whale and Hawaiian monk seal are noted to visit this area, but the report concludes that these visit are so infrequent that the risk is low. Endangered green sea turtles are found in the area, and could be injured by a spill or atmospheric emissions. The NMFS and the FWS were reported to be advising the Army as part of their cooperating role status regarding ecological issues.
Cumulative impacts
Cumulative impacts can result from individually minor but collectively significant actions occurring over a period of time. Review of past activities and reasonably foreseeable future activities at Johnston Island allowed for a qualitative cumulative impact assessment in the following six areas:
- Air quality: destruction of the European stockpile means 3.5 months more of operations. The emissions will remain the same per unit of time, but increase 20%.
- Land use: 1.2 hectares (3 acres) of land will be needed for the temporary holding of munition-filled MILVANs in the exclusion area, and perhaps 1.2 hectares (3 acres) for the temporary holding of empty MILVANs. This is far less than 1% of land on the island. The report says that the land will be returned to its previous state after the campaign is completed.
- Groundwater: Johnston Island has no potable groundwater.
- Waste production and disposal: all the waste is to be removed from Johnston Island and disposed of at an approved site on the continental USA.
- Terrestrial ecology: there will be temporary loss as a result of MILVAN holding and road surfacing. The report indicates that there is little seabird activity in that area.
- Aquatic ecology: no adverse impacts are expected, and construction of a new waste treatment plant is expected to have a positive effect on water quality.
The conclusion is that there are no significant cumulative impacts on Johnston Island resources. No unavoidable adverse environmental impacts were expected.
Labor, materials, and capital spent on the preferred action were described as an irretrievable commitment of resources, but seemingly given little weight.
Alternative actions
More than any case study in this book, the alternatives were critical here, and yet were essentially dismissed. The no-action alternative was to leave the weapons in Germany in their storage areas. That option was rejected because in 1986 President Ronald Reagan agreed with Chancellor Kohl to remove them from Germany by 1992. In 1992, Secretary of State Baker and Chancellor Kohl agreed to speed up the removal to no later than December 1990. In essence, the Army had to move the weapons from Germany, so there was no German-based option.
Legal constraints severely limited options that had not already been precluded by political decisions. The SSEIS interprets the Federal Public Law 99-145 as favoring rapid destruction of the munitions. In fact, the schedule was not followed in many continental US locations. Transfer of the European chemical munitions was prohibited until the Secretary of Defense certified to Congress that there was sufficient storage capacity for the European weapons and that the Johnston Atoll disposal system had destroyed live agent chemical munitions. Once the stockpile left Europe, alternatives that may have been considered included disposal at facilities other than on Johnston Atoll, and interim storage at locations other than Johnston Island. In addition, a number of options within these major alternatives could have been considered. These included alternate transport modes (e.g. air or sea), alternate routing, and alternate disposal technologies. But they were not considered in detail in the SSEIS.
The report also briefly discussed, and then dismissed, the eight continental United States sites as inappropriate, given the prohibition against bringing the weapons to the United States and even transferring them among the eight sites. The report argues that each site will have technology that fits its weapons. (See above for discussion of sites and program cost.)
The most compelling reason for not using the US facilities was the prohibition on the movement of chemical stocks into the country from outside the continental United States. The document dismisses other European locations as unsuitable because there is no place to store the weapons, much less destroy them.
The report concludes that only the Johnston Island site can most effectively handle the European stockpile. The Johnston Atoll site is asserted to be the best currently available and readily accessible site for destroying the agents and weapons. Entirely new storage and disposal facilities could not be constructed at non-US locations without building new facilities and getting approvals, which doubtless would have proven difficult, if not impractical or unfeasible. US-based destruction was precluded by the requirement that the technology was to be demonstrated on Johnston Island before being used on the continental United States. In reality, the political process apparently left no politically and legally actionable options.
Given the restricted scope of the SSEIS analysis, which means assuming that the agents and weapons were anchored off the coast of Johnston Island, the impacts of adding the additional ordinance to what was already on the island leads to the rational conclusion that the impacts, as interpreted by the SSEIS, are relatively minor. For example with regard to construction, no additional buildings are proposed. The document suggests that some road and soil stabilization will be required in the chemical area, which will also mean some additional dust generation. In contrast, any other option, other than keeping the ordinance stored in Germany at its current location, would have required building new facilities.
Incineration is preceded by disassembling the ordinance, that is, removing the explosives from the assembly, draining the gas, and removing the fuel. The facility has four different incinerators to handle this process and a feed system that was specifically designed for these purposes. There is a liquid incinerator for the gas, a deactivation furnace for the explosives and fuel assembly, a metal parts furnace for metals that have been in contact with the gas, and a dunnage to burn the other wastes. Each one has a pollution abatement system. These specially built systems were to be tested on Johnston Island before being adapted for other locations. The marginal impact and risk of destroying the European weapons is minimal compared with what it would be for using any other location that did not have these technologies already in place. The document notes that the predicted concentrations of contaminants will be well below National Ambient Air Quality Standards (NAAQS) for criteria pollutants, and meet the rigid high standard for destruction of chemical agents. In comparison, the other alternatives would have required building systems elsewhere (four of the continental US sites did build incinerators), or would have had to wait for another technology to be developed and then tested (four did), meanwhile assuming that none of the aging ordinance would detonate.
The Army planned to reuse the MILVANs and decontaminated scrap metal and to package and ship solid wastes to the continental United States for disposal. At the time of the hearing, the Army was negotiating to find the best option. Hence the public did not know where the waste products were to be shipped. In short, none of the alternatives was given serious consideration in the document; by precluding other major alternatives, primarily for political reasons, they were left with Johnston Island.
Compliance with regulations
The document took great care to demonstrate that the Army had been complying with federal legal requirements. The SSEIS notes that it initiated informal scoping meetings on the Johnston Island project in February 1982 with the EPA, FWS, and NMFS. More meetings were held in May and July 1982. In March 1983, scoping workshops were held for federal, state, and local agencies and the general public. In February 1983, the Army issued a Notice of Intent to prepare an EIS for the project, which was published in the Federal Register, and the Army issued formal press release. In July 1983, the Draft JACADS EIS was distributed and the Notice of Availability for that document was published in the Federal Register. The Final EIS was published in November 1983, followed by a Record of Decision in December 1983.
In 1983, the Army began considering the option of ocean disposal of the waste generated by the Johnston Atoll facilities. In November 1985, a public hearing was held in Honolulu, Hawaii, to elicit public input on the proposal for ocean disposal. Then the Army decided to prepare an SEIS to evaluate disposal alternatives for the process wastes. A Notice of Intent was published in the Federal Register on April 30, 1987. The draft SEIS was distributed in October 1987. Comments were received, and the final version was published in November 1989. A Record of Decision was issued on December 27, 1989. The notice to prepare the second supplemental (SSEIS) to deal with the wastes from Germany was issued in September 1989. In February 1990, the draft SSEIS was distributed. The public meeting was held in Honolulu on March 20, 1990, and is summarized below. The report very carefully, and I am sure quite purposefully, listed and described more than two dozen federal laws, regulations, and executive orders with which it had complied.
Public response
The Johnston Atoll EIS attracted about 100 people to a public meeting in Honolulu, Hawaii on March 20, 1990. The text was 519 pages, of which twenty-seven came from nine federal agencies and the remaining 492 from more than two dozen spokespersons and individuals. The federal respondents had been cooperating agencies. For example, the NMFS was satisfied with the Army's response to its earlier suggestions, and offered a few more. The EPA asked for more information, which is typical. They offered ten comments or questions asking the Army to explain the legal reasons why the European stockpile had to be moved, emphasizing the need for as little interim storage as possible, suggesting that their Resource Conservation and Recovery Act permits would need to be changed, and asking questions on worker exposure and safety.
Jonathan P. Deason, US Department of the Interior, Office of Environmental Affairs noted that the transportation, storage, and disposal would have little direct impact, and yet he noted some concerns about potential impacts from human waste disposal associated with additional workers. Representatives of the DOE, the Defense Nuclear Agency, and the US Public Health Service had little to add.
In contrast, the public representatives had a great deal to submit to the record, and none of it was supportive of burning the weapons on Johnston Island. Rather than review each one, I have divided the comments into four themes in order of the frequency of their utterance.
Availability of documents
The most often asserted argument was that the Army had not provided the documents for review in sufficient time for public review. Several people testified that they obtained a copy only a week before the public hearing. One testified that the Governor's Office of Hawaii and the Health Department received copies of the document from her, not from the Army (US Army 1990b, p. 445). Her statement, while more aggressive than others, is consistent with the sentiment as judged by the transcripts. Marsha Joyner testified:
This whole secrecy has been too much. We published the notices, we called the newspaper, we handed out the EIS, and for anybody that got one, it came from us. I think since the Army did such a piss-poor job, that we are entitled to at least a 90-day period when everyone in the State, especially the Health Department, the Civil Defense, the Governor's Office has the time to read this. And to go any further is ludicrous, and, as everyone has said. If it does go any further, it means that it's a done deal and you have lied to us again.
(ibid., pp. 445–6)
A number of respondents asserted that the failure to make the document available long in advance of the meeting was a deliberate effort to circumvent the legal requirement. No-one representing the Army debated the charge; they could not explain why, for example, it was not available in public libraries, and they promised that they would look into what had happened. Some of the 100 attendants concluded that the Army would not even make the transcript available, despite its spokespersons indicating that it would be made available. This incident was embarrassing for the Army.
Environmental injustice
A second theme was that the transfer of weapons from Germany to Johnston Island was an environmental injustice. Marsha Joyner, a Hawaii resident, made a statement that requires no interpretation:
the fact that you can move this convoy of 400 tons of lethal nerve gas across thousands of miles of ocean and around non-white nations and not notify anyone amounts to environmental terrorism. This is racism at its highest level. The thing about racism is that it is so insidious that you don't even know that you are doing it. You don't see us. The military record of people treatment in the Pacific since martial law was declared has been one of shame. I find it hard to believe that this is any different. In preparing the EIS the statement was made that it (Kalama Island) is away from population centers. What you neglected to say is white population centers.
(ibid., p. 82)
Others added that they felt like guinea pigs. Several noted that a spill could jeopardize the perception of the growing tourist industry in the region and undermine the region's growing economy.
Incomplete science
The third theme focused on incomplete science. Presenters argued that movement of the waste was irrational. They noted that, if the waste was so safe, why not incinerate it in West Germany, where it originated. If it is so safe, why is its path across the oceans a secret? Greenpeace presented a 100+ page report, arguing that it wanted the waste stored in Germany until a safer disposal method was available. Many of the attendees were persuaded by the Green-peace report and referred to it in their comments. Hawaii legislator Annelle C. Amaral stated:
The conclusion is clear: the risks created by transporting the chemical weapons from Europe to Johnston island far outweigh the marginal benefits of disposing of these weapons at Johnston Atoll versus disposing of them on-site in Europe or waiting for better solutions in the future.
(ibid., p. 29)
Various presenters questioned specific elements of the science and engineering. For example, a meteorologist questioned the plume models used to simulate contaminant dispersion, arguing that the models lacked sufficient information about local weather conditions, and that in fact concentration of lethal agents over the Hawaiian Islands could be higher than estimated in the Army's computer models. Several commentators argued that Johnston Island had to be evacuated twice because of hurricanes (Celeste in 1972 and Keli in 1984), and they wanted Army to explain what it would do if the island and igloos containing the weapons were swamped by a hurricane; what would happen if a hurricane came while ships carrying the chemical weapons were waiting to unload their hazardous cargo; and what the Army would do if there was a spill.
Other comments focused on the potential impact of the action on surrounding waters, and on sea turtles, fish, whales, and the atoll's bird sanctuary. Two speakers were worried about the transport of water brines from the site to the continental United States. Several asserted that the German government lacked experience in moving these kinds of weapons, and still others were worried about the stability of the weapons and the effort to manage them on the island before incineration. Several speakers referred to nuclear hot spots from an accident in 1962 with a nuclear-tipped warhead firing, and Agent Orange hot spots on the island (a 1977 spill on a ship that was incinerating Agent Orange offshore), and were concerned about protecting those on the island.
Legality
The fourth theme was that the EIS was violating the law. Two attorneys testified and challenged the legality of the action. Paul Spaulding, III, representing the Sierra Club Legal Defense Fund, submitted a fourteen-page memo arguing that the Army had violated NEPA by not addressing the movement of agents from Europe to Hawaii. In essence, he argued that the EIS was not a comprehensive life-cycle analysis of the waste management issues because it focused on destroying the gas on the island, while ignoring the transport from its location in Germany to the atoll. He asserted that the real question is, how should the waste currently in Germany be destroyed?
Attorney Spaulding continued that the US Army had bowed to politics, that in 1986 President Reagan had promised Chancellor Helmut Kohl of Germany that the United States would move its entire European (NATO) chemical weapons stockpile out of Germany by 1992, and earlier if possible. Spaulding asserted that Chancellor Kohl's desire to move the weapons out of Germany was insufficient reason for the US Army to move them to Johnston Island.
He wanted more attention focused on the no-action alternative – leaving the weapons in Germany until a better disposal method could be developed, or destroying them in Germany or elsewhere at a NATO location. He pointed out what he considered an inconsistency by arguing that the EIS rejected the Aberdeen Proving Ground in Maryland as a site because it is near Chesapeake Bay, and for various other reasons. And yet, he wondered, how are these same concerns not present at Johnston Island? If it is risky, he argued, to transport the weapons to Maryland, then how could it not be risky to transport them to Johnston Island? If the species in Chesapeake Bay are at risk, then are not those surrounding the atoll and on the atoll's bird sanctuary equally at risk? The preferred solution, he argued, is not legal. He added that “Whereas the public ordered the environmental equivalent of a ‘filet mignon’ steak, the Army has now served it with a ‘ground beef’” (ibid., p. 34).
It did not escape the two attorneys that whereas nerve gas on the continental United States has to be destroyed on site, that is, no transport is allowed across state boundaries, it is permissible to move it halfway around the globe from Europe to Johnston Island. One attorney, Jon M. Van Dyke, argued that he was not persuaded that this action was even legal. His argument was that the two original islands were only a little more than 50 acres when the United States seized the atoll from the Kingdom of Hawaii in the nineteenth century; through dredging and dumping, the island had become almost 700 acres in size. Van Dyke asserted that the atoll, to all intents and purposes, is a man-made structure at sea, and the 1972 London Dumping Convention, ratified by the United States, does not permit the destruction of waste on bodies at sea, including platforms or man-made structures. Many of these arguments were thoughtful and well put.
Interview
David Kosson is Professor and Chairman of Civil and Environmental Engineering at Vanderbilt University. His specific research has focused on mass transfer of contaminants in soils, sediments, and wastes; development of innovative remediation processes for waste sites; methods to test for leaching; and many others. More broadly, Professor Kosson has been a leader in national efforts to manage nuclear waste and chemical weapons. Apropos this chapter, he was a member of the National Academy of Science's chemical weapons so-called “stockpile committee” for two full three-year terms, and he chaired it during a period when the committee visited sites not only to examine the technical issues, but also to listen to public viewpoints. I would find it hard to think of anyone who has a better understanding of the technology and the public– political side of this issue. I interviewed him on February 24, 2010.
I asked Professor Kosson to assess the complexity of the engineering tasks at Johnston Island. He responded that each of the four incinerators operated relatively independently. The greatest risk was dismantling the weapons and feeding them into the system (see above for a description). The facilities are built so that the most dangerous areas are in the center. The hot zone is heavily monitored and secured. Then there is a buffer zone, and finally an outer zone. The intensity of monitoring decreases with distance from the inner hot zone.
Professor Kosson believes that the technology built on Johnston Island could have been built without demonstration on Johnston. However, it was helpful to have had the demonstration first on the atoll because lessons were learned about systems operations, future design improvements, instrumentation, and about handling the ordinance, agent, and waste on Johnston. If it had been built first at a continental United States location, he thinks that they might have first needed to build a demonstration project, rather than a full-scale operating plant. Professor Kosson praised the Army for “groundbreaking efforts” to use probabilistic risk assessment and linking the risk assessment to its risk management practices. Overall, based on his public experiences at the continental United States sites, he feels that it was sensible to have a demonstration in a less populated area in order to gain both technical and public confidence.
With regard to the risk of removing the waste from Germany and shipping it across the globe, Dr Kosson believes that the US Army treated this shipment as it would the movement of any weapons, which means that it was handled by weapons experts, packed by experts, and guarded by military personnel. While handling weapons is always a risk, he reiterated that the greatest risk was disassembling the weapons and the movements associated with those processes – as well as doing nothing, that is, allowing the weapons to age, and potentially leak or have accidental auto-ignition.
To emphasize the relative significance of risks, Professor Kosson noted that, in light of the successful destruction of the weapons at Johnston Island, Tooele, and other incineration sites, the Army had proposed using incineration at other sites. However, some local communities had opposed incineration. For example, the Blue Grass, Kentucky site (see Table 5.2) rejected incineration in favor of a set of technologies that had not been demonstrated. Consequently, the destruction of agents at that site, stored primarily as fully configured rockets, will be delayed a decade. Meanwhile, the weapons are aging in place, which poses a greater risk than using incineration or another proven technology.
Evaluation of the five questions
Information
The focus of this document is a proposed supplementary action. A supplementary EIS should not be expected to be as thorough about the entire project as the original final EIS. But it should thoroughly cover the supplemental proposed project. This SSEIS does not. I have also read the original EIS and the first SEIS mentioned above.
The most obvious shortcoming is the absence of information about the risk of moving the NATO agent and ordinance from Germany to Johnston Island. Earlier in this chapter, I compared the Johnston Island EIS with the LNG proposal in Chapter 4. Neither provides information about extracting the materials from their location and moving them across the ocean. However, there is an important difference between the two proposed actions. Presumably, residents of the Baltimore area and the surrounding mid-Atlantic region would benefit from the natural gas, and there would be some employment, although not much, over the lifespan of the LNG facility. The geography of the benefits would not equal the geography of the risk, but there are some benefits.
The Johnston Island project offers benefits to contractors, and the SSEIS asserts that the Army's presence protects sea turtles from hunters. There are local benefits in the Johnston Island case, to elected officials of Germany who have successfully persuaded the United States to move the agent and munitions from Germany, and to residents who lived in the community surrounding the weapons storage area in Germany. Of course, had there been an accident during the transport of these weapons, the benefit would have been replaced by serious problems for the German government. But there were none. Also, there are benefits to residents of the eight states of the continental United States whose risk was reduced by piloting the incineration technology at Johnston Island. None of these benefits is explicitly discussed in this report, and for me this is a remarkable omission. Perhaps the Army assumed them to be too obvious.
If there were to be any benefits to the Johnston Island area, they are not defined in the SSEIS. Even the soldiers and contractors are not local. Furthermore, the SSEIS does not claim any local benefits.
The most troubling omission is that the movement of these materials from Germany to a remote island in the Pacific stands in clear contrast to policy for the continental United States, which does not permit unitary chemicals weapons and agent to be transported across state boundaries. If the agent and weapons cannot be moved within the United Sates, what is the rationale for moving them across the ocean? The obvious answer is that the proposed action was a political decision.
This interpretation is reinforced by the explicit statement that the set of technologies had to be proven before they could be used in the continental United States. For residents of the Hawaiian Islands and Micronesia governments, it was not a leap of faith to assume that this region, where nuclear weapons were tested, and Agent Orange was burned offshore, was once again a sacrifice zone for the United States. The testimony of regional residents emphasized this point – the people felt like guineas pigs. The environmental justice literature did not emerge until the 1980s, and President Clinton's executive order requiring explicit consideration of environmental justice was not until 1994. I suspect that that this would have been a different document had the decision been made in 1995 rather than 1990, but that is speculation. There is no way around the observation that this action appears to be insensitive to environmental racism and to the history of this area. To the people of this Pacific region, this action was unfair.
The Army did not even consider the impact of a potential accident on local fishing and recreation. Instead, these concerns were dismissed because the additional ordinance would only take 3.5 months to destroy, and the report did not consider the possibility of an accident during transport.
The science and engineering is also limited, compared with what would now be expected. The plume models were state-of-the-art then, but the assumptions used in the modeling lacked sufficient local data. However, it is hard to see how the results could lead to an imminent threat to Hawaii and other populations in the Pacific area. The remoteness of Johnston Island was protective. Better data and models would not have led to evidence to change the decision.
The tone and writing are satisfactory. Indeed, the message to regional residents is remarkably clear. If the writers wanted to hide the message, they certainly did not do a very good job of burying it in facts. The report is relatively short, and easy enough to read. The biggest problem I have is the missed opportunities to explain this decision in the way that Professor Kosson did.
Comprehensiveness
This document, indeed all three documents, were not comprehensive. The components of the life cycle that are presented are adequately discussed, although, as noted above, that would not be my conclusion if the report had been issued in 1995. By starting the EIS off the coast of Johnston Island and asserting that it would only take 3.5 more months to destroy the nerve gas, the SSEIS was figuratively pre-ordained to find no significant impacts. After all, if the full program takes 3–4 years for the Okinawan ordinance, then 3.5 more months for the NATO agent is a minor addition to the risk. Again, the writers of this document had opportunities to offer more thoughtful explanations than they did.
Coordination
Judged by their terse responses to the SSEIS, the cooperating federal agencies were supporting the decisions; however, the author (perhaps projecting) reads some frustration in their official responses. The EPA urged the Army to make information available: “Since the publication of the Draft EIS, much additional information concerning the munitions and the proposed program has been declassified and made publicly available. We strongly recommend that the formerly classified information be included in the Final EIS” (US Army 1990b, p. 5).
EPA offered other suggestions about sampling, notably about how the information will be distributed to the public:
The Final EIS should provide additional information concerning the trial burns under the Toxic Substances Control Act (TSCA) and operational verification testing. This should include the materials incinerated and compounds monitored. . . . In addition, the Final EIS should include data for the stack gas toxicity monitoring program. . . . For work to be completed in the future, the Final EIS should indicate at what point and how the results of these three procedures will become available to the public.
(ibid., p. 8)
EPA also added the following statement about impacts on non-island personnel: “The Final EIS should discuss the potential impacts on other populations (fishing fleets, etc.) at risk in the event of an accidental release” (ibid., p. 10). I found it shocking that these suggestions had to be made by the EPA in a written report; all this seems to be obvious without the need for EPA prompting.
The US DOE has had more than its share of EISs that have drawn heated responses. Frank Bingham, Director of the DOE Environmental Protection Division, offered five comments, many focusing on the report's failure to explain the science and engineering, even including a discussion of public participation and not providing a list of persons, groups, and agencies contacted. Again this author found these terse statements to be surprising insofar as the lead agency would not normally have such obvious omissions. These statements are illustrative of the lack of comprehensive treatment of issues in this SSEIS.
Representatives of the State of Hawaii opposed the proposed action and, along with others, were angry about not having the documents made available to them in a timely manner. The choice of language by Representative Annelle C. Amaral is quite telling, as it points to a failure to deal with key issues in the document:
While some may argue that storage of these chemical weapons may pose hazards due to the possibility of their containers developing leaks or through accidents, I would note that the possibility of accidents occurring is much greater every time these containers are handled. Moreover, the possibility of an accident will be infinitely greater if this project is carried through – these containers will have to be shipped half-way around the world, during which trip they will probably have to be handled at least five times: loaded onto a train or truck in Europe, loaded onto a ship, unloaded from the ship to other vehicles at Johnston Atoll, placed in a storage area, picked up from the storage area, and placed in the incinerator facility. That is the minimum of handling I can envision. Add to that the threat caused by normal wear and tear during transport and the possibility of accident, or even sabotage, during transport. Add to this equation the law of human activity, that if anything can go wrong it will go wrong.
The Army, in its 1983 EIS, stated that there are presently no plans to dispose of chemical agents or munitions on Johnston Island that are not stored there at this time. Now, however, less than a decade later, the Army is attempting to overturn this statement of its intent and purpose in the development of the Johnston Atoll Chemical Agent Disposal System to allow itself to bring materials to Johnston Atoll from the four corners of the world for disposal, if necessary.
(ibid., pp. 29, 230)
These statements should not have been needed to be raised by a representative of a state government. These issues should have been addressed in the SSEIS.
Accessibility to other stakeholders
The author concludes that this decision had been made, and no other options were to be considered, because of political and legal decisions. Hence it is hard to understand why the documents were not made available far in advance of the meeting. A conspiratorial theorist would argue that the Army deliberately waited to make this document available to avoid a politically embarrassing confrontation in Hawaii. However, the Army representatives seemed genuinely embarrassed by the charges of not making the documents available. Furthermore, the author has been at meetings in the continental United States where an estimated 500 people were present and used language that was a lot stronger than that used in this Hawaii meeting. The Army chose incineration in those cases, and was under no obligation to change its decision in the Johnston Island case. This case study clearly demonstrates that access to the documents and process does not imply a different decision. With documents now automatically available on the web, the complaints aired at Johnston Island should not be repeated.
Fate without an EIS
The decision was a political one, and the SSEIS probably slowed down the implementation, but not by much because of the time-sensitive political decision.