April 1, 2004
Mr. Chairman and members of the Subcommittee, I am Patrick Meehan, Deputy Director for Program at the National Center for Environmental Health, one of the centers within the Centers for Disease Control and Prevention (CDC). I would like to thank the Subcommittee for inviting me here today to discuss CDC's legislatively mandated public health oversight role in the chemical demilitarization program of the Department of Defense. I would also like to thank the subcommittee for your interest in ensuring the safe destruction and disposal of our nation's chemical weapons stockpile.
My testimony will focus on two general topics: (1) CDC's mandated role in overseeing the plans of the Department of Defense for destroying the nation's stockpile of chemical weapons and (2) CDC's involvement at the Newport, Indiana and the Aberdeen, Maryland disposal facilities.
CDC's Overall Chemical Demilitarization Mission
The U.S. Department of Health and Human Services is mandated by law to oversee the plans of the Department of Defense for destroying the nation's stockpile of chemical weapons, including any plans to transport or dispose of lethal chemical or biological warfare agents. This mandate was delegated to CDC from the Office of the Surgeon General in 1981. Our mission in carrying out the mandate is to protect the public's health and safety by reviewing plans, providing advice, and making recommendations on the safe disposal and transportation of both stockpile and non-stockpile chemical warfare agents. The Secretary of Defense is required to implement CDC's recommendations for precautionary measures to protect the public health and safety. In carrying out these activities, CDC's primary focus has been on preventing potential problems that could adversely affect the health of disposal site workers and the surrounding communities.
CDC begins its oversight function for the disposal of agent by reviewing the Army's proposed destruction technology. CDC then examines facility design provisions and operating procedures that are to protect the workforce and surrounding communities. During operations at chemical weapons destruction facilities, CDC conducts periodic on-site reviews for the purpose of ensuring safety. Because air monitoring is a critical element in detecting any possible agent release incidents, CDC regularly examines air monitoring procedures and strategies, including the number and placement of air monitors as well as the quality of the data from these systems.
In addition, CDC, in conjunction with state and local environment and health authorities where chemical weapons stockpiles are located, evaluates other functions at a chemical destruction site, including process safety, industrial hygiene, and medical readiness. Together, such activities contribute significantly to preventing exposure to chemical agents. Finally, to ensure that medical and emergency personnel near a facility are prepared to respond to an incident involving release of a chemical agent, CDC makes itself available to provide consultation services to those personnel and the Community Stockpile Emergency Preparedness Program (CSEPP).
In undertaking our oversight responsibilities at destruction sites, CDC is currently addressing several key issues. First CDC is working with the Army to implement revised airborne exposure limits of chemical warfare agents for workers and the general population. In response to a request from the Army, CDC recently updated these limits to ensure that workers and the public are protected from exposure to a harmful concentration of agent. Second, CDC must strive to ensure worker and public safety are adequately addressed during the start-up of disposal facilities. Third, CDC is in discussions with the Army to improve air monitoring methods and technology in such a way as to reduce false positive instrument responses, improve response times, and meet the newly recommended airborne exposure limits. Finally, we are faced with the task of examining unique problems impacting human health associated with new non-incineration technologies such as those at Newport and Aberdeen.
CDC's Activities at the Newport and the Aberdeen Chemical Agent Disposal Facilities
Both the Aberdeen and the Newport facilities were constructed rapidly following the events of September 11, 2001. The rapid construction occurred within the goal of reducing the threat of terrorism in connection with the nation's chemical weapons stockpile. We believe that some of the difficulties at these facilities arose because there is less experience with the new neutralization technologies compared to the incineration technology used at other sites. An added challenge is that both design and construction occurred concurrently at these facilities.
During 2004, CDC's chemical demilitarization program has focused much of its activities on the Newport Chemical Agent Disposal Facility in Indiana because the planned process is a relatively new technology, and operations are scheduled to begin soon. The proposed process at Newport, Indiana will use chemical neutralization of the chemical agent VX, followed by secondary transportation to and treatment and disposal of the resulting wastewater at an off-site facility. CDC has devoted significant resources to evaluating the first phase, the neutralization of VX at the Newport site. The two basic concerns with this first phase are (1) ensuring that the waste hydrolysate, the waste byproduct of neutralized VX, does not contain any detectable level of VX and (2) ensuring that the facility can operate safety.
Last year, CDC conducted an evaluation of the Newport site's hazard analysis process. The review provided recommendations in several key areas, including (1) the extent of independence of the contractor's review team, (2) whether the hazard review methodology is appropriate, (3) whether the documentation for the review is complete, (4) the need for a human error/human factors study, and (5) the need to manage and evaluate changes to the design and processes. The Newport staff and contractor are currently addressing our recommendations. In addition to the CDC review, the Newport project team has contracted with the Mary Kay O'Connor Process Safety Institute of Texas A & M University to conduct an independent risk analysis of the process. CDC will review the results of the analysis before the facility begins processing agent.
In conformity with public laws delineating our involvement in chemical demilitarization, CDC's role generally ends when the waste no longer contains any detectable level of chemical weapons agent, at which time the responsibility for the waste falls under existing transportation and environmental disposal regulations. Nonetheless, CDC is available to provide assistance to the Army or to EPA within our areas of expertise.
The Army's proposal for secondary treatment of Newport caustic hydrolysate at a Dupont facility in New Jersey has generated significant public controversy. CDC has reviewed and provided comment on one draft Dupont report related to health hazards associated with the hydrolysate—a document titled Health Hazard Considerations for Safe Management of Newport Caustic Hydrolysate (NCH). CDC was not asked to review the other three Dupont documents. In short, CDC has not conducted a comprehensive review or an analysis of the proposed project to transport and treat the secondary waste generated by the VX neutralization.
The Aberdeen Chemical Agent Disposal Facility is another chemical neutralization facility at which CDC has been active in an oversight role during the start-up of operations. Before the Aberdeen facility began processing agent, CDC evaluated the air monitoring systems and laboratory capabilities, attended integrated operation demonstrations, and enlisted the support of occupational health experts at CDC's National Institute for Occupational Safety and Health to assist in an examination of process safety. CDC is aware of the operational problems at the Aberdeen site and has been briefed by the Army on the status of the facility. CDC is planning to revisit the facility in May of the current year to review changes the Army has made to the operation.
Although I have pointed out a number of challenges currently associated with our oversight responsibilities, I must also emphasize that CDC has had a long and successful working relationship with the Army's chemical demilitarization activity. The successful completion of the agent destruction mission at Johnson Atoll and the safe elimination of the GB stockpile at Tooele, are representative of the true accomplishments in reducing the threat of chemical weapons. CDC looks forward to contributing to continued safe progress in this vital program.
Mr. Chairman and members of the subcommittee, this concludes my testimony. I would be happy to answer any questions and respond to any requests for additional information.
Last Revised: April 5, 2004