Home Ace Issues Bluegrass Army Depot stakeholders: Gas is getting on my nerves

Bluegrass Army Depot stakeholders: Gas is getting on my nerves

Ace Coverstory June 1991. Rural Gravesite, Madison County: “Shall We Invest?”(Eight Ways of Looking At A Mustard Gas Stockpile)
BY Larry Rosenberg
U.S. Army, Office of the Program Manager For Chemical Demilitarization
This is the first time that I have had the pleasure (yes, the pleasure) of addressing an issue that invokes such strong emotions from all it touches—the elimination of chemical weapons from storage sites across the United States.
The pleasure I feel is not derived from the controversy, but from playing a small role in President [George Herbert Walker] Bush’s stated goal of “ridding the world of these weapons of horror.”
The total elimination of chemical weapons is a benefit the human race must experience in the near future if we are to take the next steps in the preservation of our planet.
The Army’s goal, simply stated is thus: the destruction of the entire stockpile of lethal unitary chemical agents and munitions which are currently being maintained at nine different locations.
The Army has moved responsibly in developing a program that is both environmentally safe and extremely effective as a result of its systematic study and investigation of all available technologies.
The incineration technology developed by the Army has been reviewed extensively by many agencies including the National Research Council of the National Academy of Sciences, the U.S. Environmental Protection Agency and the Department of Health and Human Services. These agencies — whose charge it is to protect the people and the environment — have all endorsed the Army’s incineration technology.
None of the alternative technologies for disposing of chemical weapons has provided viable replacements for the Army’s high temperature incineration process.
Furthermore, the continued storage of the chemical stockpile may in the future pose a real environmental and public health risk which necessitates that the destruction process be started before the perceived problem becomes reality.
Besides, the transportation of these chemical weapons by truck and rail to another site is an intolerable risk. The fact is transportation of these weapons increases environmental and public health risks.
I do not believe the residents of Richmond support this alternative nor do I believe it should find much support outside of those individuals who have endorsed this policy in the first place. Besides, who would accept it?
Can we as a society wait for new ideas to pan out before we take action and destroy those aging chemical stockpiles whose sole existence threatens the public health and the environment while we delay for a promise of an unproven “safer” technology? Can our children wait? I think not.
We—the engineers, the safety officers, the chemists, the environmentalists and, yes, even the public affairs people who work at the Office of the Program Manager for Chemical Demilitarization—take our responsibility of executing President Bush’s goal and the chemical stockpile disposal program very seriously and stand committed to following an orderly path which will ensure that the stockpile will continue to be destroyed safely, with no harm to the public or the environment — with much pleasure.

By Bill Rice
Concerned Citizens of Madison County
My wife and I have lived on a farm adjacent to the front gate of the Bluegrass Depot for 40 years. Our friends and neighbors were hospitalized in 1979 after being explosed to a toxic cloud that originated on the depot and was caused by improperly burning smokepots.
In February of 1984, your people briefed a local group of over 300 people on plans to build an incinerator here to dispose of our nerve gas stockpile.
You granted us a Congressional hearing here in Richmond, with both sides presenting pros and cons, and with many qualified studies given. Again, the plea was given to treat us equal with the Germans and move the gas.
Then, in 1989, Congress funding a study for the ongoing use of the incinerator, and we now know the rest of the story.
You have told us many times transportation was out of the question — safety, politics and costs — and yet now, you have moved all the nerve gas stockpile out of Germany. It was moved by trucks, trains and ships (loaded and unloaded four times and handled eight times) and now stored on Johnston Island, to be destroyed there in the middle of the Pacific Ocean, away from school, cities and large populations.
In the last few months, I have watched hundreds of trucks loaded with munitions and supplies leave the the depot and head for the coast, to be transported to the Middle East. Our friends and neighbors worked 12-hour shifts, 7 days a week, loading those trucks and railcars to supply our troops. They did more than their part and are local heroes, and we are proud of them.
Desert Shield has again proven the expertise of our Army in transportation of dangerous materials.
Desert Shield has shown the threat of chemical warfare and how frightening it is to the military and the citizenry (especially old people and young children). TV brought home to us how alarming it would be to send our children to school with their gas masks, rubber suits and syringes and atropine each day. It showed us how affected our community would be.
We live in one of the finest regions in the United States — the air is clean, our water is safe and our economy is strong. It is a wonderful place to live, work, and raise a family. WE DON’T WANT OUR WAY OF LIFE CHANGED.
Since 1984, the following groups have been born: The Concerned Citizens of Madison County, the Hopkins’ Task Force, the Kentucky Community View (funded by the Army) and Common Ground: Kentuckians For Moving the Nerve Gas. All of their findings were the same—move the gas.
Each Day your experts plan to locate an incinerator here looks more stupid. Each day your arguments have less credibility and foundation.
In conclusion, I would strongly recommend that you go back to Washington—meet with your superiors and form a whole new study team. A team that knows the definition of the word “common sense,” for it is quite evident that your present group has no earthly idea what what the term means.

Kentucky Environmental Foundation
General Busbee, your programmatic decision to burn nerve gas here is not a sound decision for the Lexington Bluegrass Army Depot. It is a decision based on insufficient and outdated, site-specific data, and insufficient appreciation of the tenacity of perception of those who live here.
So, for instance, when you decided that incineration was best in 1982, you did not know what you know now about chemical neutralization of these weapons. Information about catalyzed neutralization or biological degradation will change your decision that incineration is the safest way to go.
In the mid-70s, when you neutralized 8.4 million pounds of nerve agent at the Rocky Mountain Arsenal, you say you had problems with slow reaction times, with excessive quantities of organic process-wastes. There were problems of reconversion and large-scale production (FPEIS, p. 2-86).
But we have come a long way since 1982.
Since 1982, you have solved the reconversion problem by changing the spray dryers to drum dryers.
Since 1982, you have made reaction rates millions of times faster by using catalysts.

Since 1982, you have learned to deal with organic process wastes by treating waste water the way every waste water treatment facility in the United States treats wast organophosphates with technology that has a 75 year old track record.

Since 1982, industry has been using enzymes to make pesticides biodegrade, to make petroleum biodegrade, to make waste water biodegrade. And someone at Aberdeen Proving Ground (maybe down the block from your offices) has developed iodosobenzoates to make nerve gas catalytically degrade — a catalyst that eats nerve gas. And eats it millions of times faster than the process you used in 1932. All the problems that you reported having with neutralization have been addressed or could be addressed with technology now available. Why, then, should incineration here be the preferred alternative? You have a better way than incineration.

Back in 1987, somebody sold you a pig in a poke. They convinced you to stop looking at neutralization, which would cost $28 million dollars, and to look at incineration, which would cost $2.5 million dollars — $25 million cheaper, they said. You built an incinerator on Johnston Atoll, and rather than costing $2.5 million dollars, it cost us taxpayers, at last count, $250 million dollars — one hundred times more than the estimate. And the $28 million dollar neutralization system, now 10 times cheaper, is proving to be safer; it has a longer industrial track record; it produces no dioxins or furons.

Now, in 1991, you know that there is a safer way than incineration. We ask you to look at other ways of disposal in a Site-Specific Environmental Impact Statement, before you make your decision for the Lexington Bluegrass Army Depot. We have a right to that in law.

Even the Navy is looking for a better way; they are looking at Super-Critical Water Oxidation to destroy little stashes of chemical weapons stored in places like the Phillippines (DARPA contract BAA #91-05). Are you going to let the Navy beat the Army, without a fight?

The Army is going to built a huge, dioxin-belching, harmful, expensive incinerator, while the Navy develops a destruction process mounted on a trailer that can go from site to site. Our folks at the Depot would be disappointed if you did not beat the Navy to the punch with a safer alternative than incineration here. Look at that in a Site-Specific Environmental Impact Statement; do it for the men and women at the Ordinance; they deserve it. And they have a right to it in law.

General Busbee, we are not the enemy; we are on your side. We have the collective common sense to know that it is foolhardy to spend, at last estimate, half a billion dollars, to build an incinerator three times the size of Pattie A. Clay Hospital, to burn one and a half percent of the national stockpile 5,00 feet from 800 school kids. There is a safer, cheaper way; you know there is.

And what about moving the nerve gas? You have not shown us that you can burn it more safely than you can move it.

During the initial stage of moving chemical weapons out of Germany back in 1986 or so, you were planning to pack and ship the munitions like convention high explosive ammunition. But the Coast Guard said, “You guys are crazy. You cannot ship hazardous, gaseous, explosive munitions like that. That stuff might leak.”

What did the Army do? Give up and go home? Nope. You developed a secondary steel container — an airtight, portable, steel magazine, complete with braces and ballasts. The Army knows how to design for transport. You do it all the time, and you do it without incident.

But the Germans raised a question — one that we think about a lot. What about a transport accident? What if a train hits an abutment? There would be gas all over the place.

Did that stop the Army? Of course not, you went into testing programs.

The drop and transportation test. You loaded a container with chemical weapons and dropped it to see what would happen.

The explosion test. You filled a canister with live munitions and simulated agent, and detonated one of them.

The trial by fire. Twenty-four projectiles, three of them armed like tactical rounds, inside the steel container, were set aflame until one of them exploded.

The results: the overpack dramatically reduced the risk of the move. You knew you could do it. The Germans knew you could do it; they even agreed to build the containers for you.

The Army knows how to design for transport. So you planned, designed, packed and moved a stockpile similar in size to the one here in Madison County, Kentucky. You moved it by truck, train, and ship, halfway around the world, without harming anyone along the way. And it was, in your words, an “unqualified success.”

You knew you could do it, and you did it. And all this is new information for risk assessment here. Since the containers passed your tests, people along the route are in significantly less danger than you said in your Final Programmatic Environmental Impact Statement. Crunch the figures in a Site-Specific Environmental Impact Statement; you know you can do it here.

CHARLES BRACELEN FLOOD, Concerned Citizens of Madison County

I would like to give all of us a few glimpses into the future, and this will, of course, include future uses, if a nerve gas incinerator is built and operated in Madison County.

It is so symbolic that we are here at Clark-Moores School, about a mile from where you propose to build and operate your nerve gas incinerator. A few years from now, there will also be 800 children in this building, but their preparation for coming to school will be a little different. In a typical family, the parents will ask Johnny if he is sure that he has his atropine kit with him and may also ask Susie if she has her hoot-type gas mask with her.
If Johnny doesn’t seem quite so healthy as he grows older, that may not be too surprising. There has never been a study done on the long-term health risks of being in the same area with a nerve gas incinerator. We will be the guinea pigs.
However, there have been studies done on areas in which there are hazardous waste incinerators. In some of those areas, what do we find? “Serious exotic debilitating diseases,” as the studies put it. We don’t have to look very far to see what can happen when you allow severe pollution to occur in your area. Calvert City, Kentucky has the highest cancer rate for teenagers of any community in the nation.
In short, we have been overlooking a few things. We’re not talking here about just burning off 70,000 nerve gas rockets. We’re also talking about burning off mustard gas projectiles; ironically, the mustard gas may give us even more problems that the nerve gas. Your own question-and-answer sheet asks a very interesting questions: “If there is only a small amount of chemical agent released from the facility and it doesn’t kill me when I breathe it, how can it affect me and my subsequent health?” Part of your answer is, “Mustard agent has produced long-term health effects in World War I soldiers exposed to (small) doses….Mustard agent is also a carcinogen,” or cancer-causing agent. But let’s not argue about which is the most dangerous—your own fact sheet says that “with large enough doses,” any of these chemical agents can kill you.
Another thing we have been overlooking, besides the risks that we are going to run from incinerating these weapons, is other future uses. Three times now, in the past seven years, we have been face with government-initiated suggestions and studies of the following idea. The Army burns off its thousands of tons of chemical weapons—you won’t even tell us how many mustard gas projectiles you have—in the middle of this populated area. Then, if anybody is left, we have this to face. You can modify this facility to burn off other things. We can start with hazardous substances right on you own base that might, in fact, send out emissions that would be more toxic than anything you had put into the air until that time. In the MITRE report that you recently commissioned, there are 12 items mentioned, including the same kind of smoke munitions that sent 50 people to the hospital in 1979 (p. xix), and the comment is that they are “demilitarized in deactivation furnaces similar to the deactivtivation furnace used in the chemical weapons process.” Being site-specific, the study also points out that at your facility here, some things that will need to be destroyed, somewhere, somehow, are not only your conventional munitions, which could involve thousands of tons of explosives, but also “contaminated soil, sludges, and carbon filters contaminated with hazardous substances or explosives”(p.xliii).
In other words, you can modify this nerve gas incinerator to become a huge hazardous waste incinerator. This study is practically a handbook on how to go about it, including what laws a Congress could change, once they see that an incinerator that was originally estimated to cost $25 million now costs $500 million, and must be kept going in order to justify this preposterous cost. Among the solutions suggested (p.5-5) is that the government could sell the entire facility to a private corporation.
In that case, instead of a one-time, carefully monitored move of chemical weapons out of here, we are facing a nightmare that any community would dread. Random shipments of hazardous materials would be coming in here, night and day, by truck and train, from every direction, well into the next century. We would become the great dumping ground for the worst acids, the worst toxic sludge, the worst by-products of this nation’s thousands of factories. Let’s be specific: Five of the 10 states that produce the most, and the worst, of these dangerous substances encircle Kentucky. We would be having constant shipments pouring into the Bluegrass region from the north, the south, the east and the west.
Let’s look at what, in fact,has happened in areas close to toxic waste incinerators in Europe, where hazardous waste incinerators have been operating longer than they have here. In Holland, an area of 26 miles in every direction around one hazardous waste incinerator is so badly polluted that nothing grown in that area can be sold outside of it. No meat from cattle, no milk from cows, none of the vegetables, non of the fruit, nothing. The pollution is so bad that mothers are advised not to breast-feed their babies because their mother’s milk is polluted. All this could be waiting for us down the road, because the Army cannot guarantee us that their incinerator, if built here, would not have those future uses. All it takes is a stroke of the pen, on some future day—the Army may have nothing to say about it.
I would say to the Army, however, that there is another and very different glimpse into the future. You are the ones who double-crossed us by promising us a true site-specific environmental statement, including a serious study of transporting these weapons out of here. Then you made a mockery of that by saying, as one of your representatives did here in Madison County the other evening, that all you are going to do is look for things like a cave under your projected building site and, if you find a cave, then you will move the building over a little farther.
In the process of insisting that everything be programmatic, you have created a two-edged sword. By insisting that you are doing everything right, everywhere, in terms of technology, paperwork, compliance with the law, then, if it can be shown by us in Kentucky that you are doing something wrong, the whole program may have to shut down until the matter is ruled on.
This is not what we wanted; you forced it upon us. But I think that you ought to do an entirely new kind of risk assessment: You ought to take back to Washington a realistic appraisal of our ability to stop you from building your incinerator here and an estimate of how that might stop the entire program in its tracks. For seven years, we have been asking you to get out from under your paperwork and take a clear look at what you are really doing to us, here. You are captives of a bad decision regarding this proposed facility here, and, step by bureaucratic step, you are marching down a dead-end street here in Kentucky. Again, we ask you to turn back of your own volition—listen, thing about technologies other than incineration, do real studies on transportation. Do serious estimates of what is involved in destroying only 1.6% of the nation’s chemical weapons stockpile at a cost of half a billion dollars.
Specifcally, you must broaden the scope of your risk assessment to include possible, arguably probable,future uses here.
So again, we are asking you to turn back, to consider alternative technologies, or do what we all know that you can do—take these weapons out of here, and lift this threat from us. But believe us, if you go on, you will see lived out here the word of the French general, Marshal Fock, who said, when he had finally won his great victory, ” We fought to the end, and then we fought beyond the end of the end.”

BY Laura Manges
Common Ground
I am obstetric nurse here in Madison County, and also the mother of a 9-year-old son, Forest and a 5-year-old daughter, Summer. They’re an important part of why I’ve been involved for seven years in this struggle against the Army’s proposed nerve gas incinerator in Central Kentucky.
“Incinerator” is a deadly word. Ask almost anyone in Madison County. What many of us may not realize, however, is that you don’t even have to write the words “nerve gas” in front of “incinerator” to make it a toxic word. Aside from all the terrible risks associated with nerve gas—including a possible explosion in one of the four stacks of this proposed facility, resulting, perhaps, in the immediate ddeaths of hundreds or even thousands of our citizens—let’s look at the day-in and day-out burning of what would appear to be the safest thing such an incinerator could handle: Our municipal garbage.
Remember, however, there’s a strong push in Congress right now for continued use of these incinerators. This would include burning more military toxic and hazardous material, and industrial toxic and hazardous wastes which cover a broad range of substances. Remember, also, that of the top 10 toxic and hazardous waste-producing states in the nation, no fewer than five border Kentucky.
Dr. Peter Montague, Director of the Environmental Research Foundation in Princeton, New Jersey, discusses what happens chemically when incinerators are the waste disposal method of choice. The fundamental problem with incineration, Dr. Montague says, is that at up to 2,000 degrees Fahrenheit, a “witch’s brew” of chemicals is released from the smokestack. Chemicals have a life of their own, and they all don’t react alike. While some of the chemical bonds will be broken because of the intense heat, others will go the other way and become more toxic because of it — for example, the dioxins and benzofurons.
Also, with incineration, you are creating a class of soot so small in size it can’t be capture by filters. As Dr. Montague says, “This soot has a diabolical characteristic; it presents a large surface area compared to its volume. It’s like taking a block and crushing it into gravel, which immediately increase the surface area of the block. Then you take the gravel and crush it into sand, which also further increases the surface area. The material coming out of incinerators is much smaller than grains of salt or sand. These fine particles become coated with exotic toxic materials that are flowing up in a gas stream.” Unfortunately, the number and size of particles allowed for incinerators is not regulated by federal or state government, just their total weight—but weight isn’t important here.
Wind and dust storms produce relatively large particles. This is important because, as Dr. Montague explains, “The junk nature produces is not as small as this. We simply don’t have the evolution to deal with these little pieces. Because of their small size, the particles go into the deepest part of the lungs, the bloodstream.” It doesn’t take a scientist to figure out what happens next.
Cancer and other diseases are what our citizens will be experiencing, in great numbers, if the Army get its way and builds this “state-of-the-art” incinerator in Central Kentucky. And please spare us all the talk about your fancy scrubbers and your high tech pollution abatement system. We don’t need skewed Army reports and biased risk assessments telling us that life with an incinerator will be just fine. We have friends in Western Kentucky who are living —and dying— the nightmare.
No, Mr. Manning, LWD in Calvert City doesn’t generate hazardous waste on-site, as any part of a manufacturing process, but the chemical companies in the town do. As our good friends, Kentuckians for the Commonwealth, tell us, “LWD’s incinerators, burning wastes from other companies, mostly outside Kentucky, produces more hazardous waste that all but one facility in Kentucky.” The folks in Calvert City told us that 70% of what that facility burns is brought in from other states.
And it’s the same all over the country. “State-of-the-art” is a fancy phrase that simply means “the best we can do now.” The death and disease rates rise dramatically in communities that site incinerators, all claiming to be “state-of-the-art.”
Building an incinerator requires the use of a hazardous waste landfill for the tons and tons of toxic ash it will produce. Hazardous waste landfills are the hardest of all facilities to site, except perhaps at the Bluegrass Army Depot in Central Kentucky. Yesterday, Mr. Baronian informed us the Army has contracted with a company in California to take the ash fromt he nerve gas burned here. We’d like a copy of that contract sent to our legal team. What happens if the California company’s landfill is full by the time the burn here is completed? At the rate things are moving and the rapidity at which hazardous waste landfills are filling, this is not an unreasonable worry. What responsibility will the Army have, both in terms of future burning and hazardous waste landfilling, should they decide to sell this facility to private companies sometime in the future? I think we all know the answer to this question.
Solzhenitsyn said, “When you take everything from people, you give them a great power, because they have nothing more to lose.” This is a Russian perspective. We Americans supposedly have the dignity of democracy to help us struggle. But democracy hangs in the balance here. If you who are commissioned to protect our lives consider them of such little consequence that you would do this thing, after all the hard data we are presenting, then democracy is dead—at least for the people of Kentucky.
We know that animals will go to extraordinary lengths to protect their young. We will do no less. Please don’t force this incinerator and a hazardous waste landfill down our throats. If you choose to pursue this unwise course, I believe you will encounter all the fierceness of mother bears and lionesses in numbers extraordinaire. And you can be sure, the lions and papa bears won’t be far behind.

BY Peter J. Hille
Steering Committee, Common Ground
I’d like to talk a little bit about the little bit that is known about incinerating nerve gas. I’d like to start with this hart that shows how well the prototype incinerator on Johnston Atoll really works. It doesn’t work very well. The upper line shows what was projected, while the lower line shows what was actually achieved during the test period. Obviously, the projections were quite optimistic. In reality, the incinerator has been shut down during 50% of the test period due to system failures. This test incinerator has been shut down during 50% of the test period due to various system failures. This test incinerator has failed to demonstrate that incinerating nerve gas is a feasible, reliable, predictable process that could be done safely in a populated area.
I won’t try to talk about everything that has gone wrong out there—I think a few examples will be sufficient. The following information comes from the General Accounting Office of the United States Congress, which says “The liquid incinerator’s secondary chamber was damaged when a hole burned through its outer plate.” In other words, they burned a hole in the side of the incinerator. Also, according to Army officials, “The deactivation furnace kiln warped and rubbed against the cover, preventing proper rotation.” Now, if this kiln doesn’t rotate properly, it may not achieve complete combustion of the nerve agent.
The report goes on: “Technical problems also surfaced with the process equipment….During systematization testing, sheared 19-inch rocket parts collected on the conveyor belt from the deactivation furnace, damaging heating coils hanging above the conveyer.”
And the problems weren’t limited to technology failures. The same report indicates significant problems with personnel: “In addition to its failure to recruit sufficient numbers of technical personnel for JACADS, the operations and maintenance contractor filled many management positions with personnel who did not have the appropriate credentials or experience. For example, on of the three persons who held the position of project manager, the senior contractor position on Johnston Island, did not have an engineering degree and did not have plant start-up experience. After serving as project manager for about 20 months, this individual was demoted and reassigned to the plant manager position.”
And there are other problems, even more threatening in nature—actual live agent releases. In 1988, there was a release in Tooele, Utah. Fortunately, nobody was hurt out in the desert. Last December, there was a release at Johnston Atoll. Nobody was hurt out in the middle of the Pacific Ocean. Bud don’t tell us it can’t happen here. We remember all too well the smokepot incident that sent over 40 Kentuckians to the hospital in 1979. We remember that the Army denied responsibility for weeks. We remember that the emergency rooms could not find out what the victims had been exposed to. We remember that Lt. Col. Donald Tribe suggested that perhaps the toxic cloud was released by dissident college students, or disgruntled workers, or maybe nearby farms. Yes, we remember. We know about supposedly “safe” incineration, and we know from experience that accidents happen.
Well, I’m just a citizen, I’m not an engineer, although I don’t think you have to be a rocket scientist to figure this one out. But I’d like to share with everyone here tonight the assessment of an engineer who knows quite a lot more than I do about these incinerators: Mr. Charles Baronian, the Army’s top engineer on this project. According to the Associated Press, he characterized the situation at Johnston Atoll as “very depressing for an engineer.” Mr. Baronian goes on to say that “We’re seeing more of these types of problems than, frankly, we anticipated.
It is not our responsibility, as citizens to identify and develop better alternatives. It’s your nerve gas, it’s your problem and it’s your responsibility to come up with a better solution. Go back to the drawing board, build a better transport container, or go back to the laboratory and develop a better disposal technology, start over from scratch if you have to, but rest assured that you will never build a nerve gas incinerator in Central Kentucky.

BY Bob Tussey
Engineer with Kenvirons, Inc.
I have closely followed this issued since 1984 and served as one of five members of the Citizens’ Review Study Group under an EKU-Army contract in 1987.
Tonight, I only want to make a point or two about the procedures the Army is using to conduct these environmental studies, and, using these results, conclude which disposal alternative is safest. I propose that the procedure is seriously flawed and, on the basis of the intent of the environmental laws, the procedure borders on a sham, which means it’s “counterfeit.”
The main reason I say this is that the Army can be convinced to change its mind and change its course. The Army changed its mind during the move of the nerve agent from Germany, and it learned a lot. The Army started the move as a “covert” action, in other words, everything secret, then changed it to an “overt” action, in other words, keep the public fully informed and involved, which serves to allay their fears.
Many, if not all of us local people, are here tonight to continue to push the Army to give the transportation alternative a fair shake. The scope of this upcoming study must include an updated comprehensive study and evaluation of the transportation alternative, and I personally think that air transportation using th prove safe C-130 aircraft is best.
The Army has said that the purpose of this meeting is to identify issues, etc., that will be included in the scope of the upcoming site-specific environmental study. Although this process is referred to as an environmental impact assessment, in this case, it is more properly a “Safety and Health Impact” Assessment. There is more concern here for human damage than environmental damage.
I therefore propose that this site-specific study scope include a re-evaluation and study of the transportation alternative, including recalculation of all risks based on:
(1) New information and data learned in the German stockpile move, including extensive and successful security procedures.
(2) The risks mitigation obtained by using specially designed and developed transportation overpack containers. These containers should significantly reduce slow-speed takeoff and landing accident risks.
(3) The reduced risks associated with the safety of extensive air transport of troops and materials during the recent Persian Gulf War. There now is far more data on the safety of using the C-130 aircraft for such a move.
Based on the Army’s own admission, the risk analysis in the FPEIS concluded that the risk of on-site disposal is about the same as the risk of off-site transport. The record of decision indicated, however, that the on-site alternative was selected because of ability to more effectively respond to emergencies, simpler security, less vulnerability to terrorism, and fewer political impacts. The problem, however, is that these issues were not compared objectively—only subjectively, in other words, “gut judgment.” I suspect that these issues were not fully developed and evaluated and that air transport was short-changed. I therefore propose that this scope also include reducing these key concluding issues to objective information for comparison and that issue-explaining scenarios be developed and analyzed; for example, air transport security similar to that used recently in the Persian Gulf war, so that fair mitigation measures can be applied.
If this level of analysis is performed, then surely a new, fresh analysis of the transportation alternative will conclude that off-site transportation is the preferred alternative.

BY Craig Williams
Common Ground
I oppose this most dangerous and ridiculous plan for another six years or another 60 years, if that’s what it takes to make the only sensible conclusion clear to the decision-makers. It is not reasonable to burn the most deadly substances known to man in the middle of a populated area!
In the January, 1991 issue of the Chemical Stockpile Emergency Preparedness Program’s (CSEPP) Update Letter, General James Molloy, who is on the panel before us tonight, stated “The opposition to the proposed incinerator is a small vocal minority, most of whom live outside Richmond.”
I would like to call the general and the entire panel’s attention to the numbers of people attending tonight’s meeting and to their reaction to the speakers’ condemnation of this project and ask him if he thinks this is a small vocal minority who oppose this plan. I would also like to point out to all of the representatives of the military, as well as the civilians taking part in the process, the fact that we here in Central Kentucky do not see this as a problem for only those who live in Richmond. What a preposterous statement to come from the man in charge of emergency preparedness for our state. No, we in this audience are from all over Kentucky, not just Richmond, because we understand, perhaps better than some would like us to, the repercussions this insane idea would have on our state.
I would like to present for the record tonight the following facts concerning the regional impact the citizens of Kentucky feel this would have. The Fiscal Court of Madison County, the Fiscal Court of Estill County, the Fiscal Court of Jackson County and the Lexington-Fayette Urban County Government, representing the second largest city in the entire state, have all passed resolutions within the last month firmly opposing the building of this incinerator here in Madison County. In addition, resolutions have been passed by the Berea City Council and the Richmond City Council and are awaiting action by the Fiscal Courts of Rockcastle, Garrard, Jessamine, Powell, Scott, Woodford, Boyle, Bourbon and Pulaski counties, as well as the Fayette County Environmental Commission. We feel these resolutions will pass; governmental bodies representing 546,000 people will be on record opposing this idea. We will stop this incinerator!
In addition, the Faculty Senate of Eastern Kentucky University recently passed a resolution 82-2 opposing an incinerator. The Eastern Kentucky University Student Senate likewise voiced its opposition. The University of Kentucky Student Government, as well as the University of Kentucky Faculty Council, have also joined the long line of academic bodies strongly opposed to this project. The president and faculty of Berea College have long been on record in opposition and have again recently voiced their sincere concern and opposition to this proposal. In addition, the Student Senate of Berea College has passed a resolution of a similar nature. This represents close to 40,000 students and over 2,000 faculty, all opposed to this unsafe project. We will stop this incinerator!
The governor of the Commonwealth of Kentucky opposes this, as did his predecessor. The lieutenant governor, the attorney general, the state auditor, the secretary of the Natural Resources and Environmental Protection Cabinet, the Kentucky Environmental Commission chairperson, the senators and representatives of the good people of Central Kentucky all oppose this plan. The mayors of Lexington, Richmond and Berea are against it. We will stop this incinerator!
The most recent poll, completed April 15 of this year, just 10 days ago, shows that 81% of the people of Madison County are against this idea and that, along with all these, the government bodies indicate that not thousands, not even tens of thousands, but hundreds of thousands of people are vehemently opposed to the thought of burning chemical weapons in this place we call home. We ask that these facts be published in the next issue. General? Hardly a small vocal minority! We will stop this incinerator!
We, as concerned citizens, have hired experts, formed a coalition of attorneys (with 38 years of collective environmental law among them), have formed an independent, non-profit foundation and now have ten chapters of Common Ground in ten separate counties to demand that this insane idea be stopped. And, ladies and gentlemen, it will be stopped.
The German government stopped you from building an incinerator in their country. The Soviet people in a little town called Chapayevsk, not much bigger than Richmond, Kentucky, stopped the Soviet government from using an incinerator to burn nerve gas by refusing, through public outcry, to allow that government, a Community government that is supposedly not responsive to the public feelings, to build such a facility. Are we less important than these? Are we —taxpaying, loyal Americans— any less worthy of consideration when it comes to our rights to be safe? To be safe from a bureaucracy that makes decisions based on schedules rather than safety? That bases its plans on outdated and contrived studies that attempt to make their decisions appear credible? That do not adhere to the law that Congress passed that states that these munitions be destroyed in the “safest and most environmentally sound manner possible?” That is, in fact, —I repeat— in fact, responsible for more toxic and hazardous waste sites than any other group in this country? Including industry? We will stop this incinerator!