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  5. Approach

Approach

    Report for Congress: Review of the U.S. Army Proposal for Off-Site Treatment and Disposal of Caustic VX Hydrolysate From the Newport Chemical Agent Disposal Facility

    Approach

    This comprehensive evaluation of the CVXH disposal plan included examination of several critical aspects, including (1) potential health hazards associated with the waste produced at NECDF, (2) potential risks associated with transportation of the material from Indiana to New Jersey, (3) ability of the DuPont facility to adequately treat the CVXH in addition to the ability of NECDF to produce caustic VX hydrolysate meeting Army-defined clearance criteria while also meeting DuPont acceptance requirements, and (4) potential ecologic impact associated with discharge of the DuPont-treated material into the Delaware River. Each aspect of the shipment, treatment, and disposal were evaluated as described below.

      In conducting this evaluation CDC partnered with several organizations, including the Agency for Toxic Substances and Disease Registry, the Environmental Protection Agency and Carmagen Engineering, Inc.

    • DuPont’s report, Health Hazard Considerations for Safe Management of Newport Caustic Hydrolysate, along with original referenced studies and supplemental material provided by DuPont and the U.S. Army, were reviewed and evaluated in a collaboration between CDC and the Division of Toxicology of the Agency for Toxic Substances and Disease Registry (ATSDR). Because the primary scientific studies cited in support of DuPont’s report were not peer-reviewed, ATSDR/CDC had these studies independently peer-reviewed before examination. The final ATSDR evaluation was peer reviewed external to the government in addition to the usual approval process for CDC/ ATSDR documents.

       

    • DuPont’s transportation report, Transportation Safety Assessment and Risk Management Plan, was reviewed and evaluated by CDC in collaboration with the Department of Transportation (DOT). This evaluation comprised two aspects. The first aspect was to determine whether the plan is consistent with DOT regulations for shipping hazardous materials. Representatives from DOT assisted CDC in making this determination. The second aspect involved examination of the transportation plan with respect to the specific hazards associated with caustic VX hydrolysate. CDC conducted this evaluation directly. The entire CDC evaluation of the transportation plan was reviewed by DOT, peer-reviewed external to the government, and subjected to the normal approval process for CDC documents.

       

    • DuPont’s treatability report, Treatability of Newport Caustic Hydrolysate, and DuPont’s subsequent Basic Data Report were reviewed and evaluated in close collaboration between CDC and a contractor, Carmagen Engineering, Inc., of Rockaway, New Jersey. Carmagen assembled a group of experts knowledgeable in the requisite disciplines to assist CDC in this review and assessment. The group consisted of a former chairman of the National Research Council Stockpile Committee, a retired assistant director for the CDC Division of Laboratory Sciences, a retired Program Manager for Chemical Demilitarization, a professor at Stevens Institute of Technology, a retired regional laboratory director for EPA, and a former environmental health and safety manager/process design manager for ARCO Chemical. Because the reliability of the DuPont process partly depends on the ability of NECDF to produce CVXH in a consistent manner that meets DuPont acceptance criteria, Carmagen also evaluated the NECDF process to produce CVXH. The Carmagen report was peer-reviewed external to the government in addition to the normal clearance process for CDC documents.

       
      • This report was peer-reviewed by subject matter experts in toxicology, ecology and engineering.

    • Because CDC did not have the expertise to review DuPont’s ecologic report, Screening Level Ecological Risk Assessment for Discharge of Effluent from the Treatment of Newport Caustic Hydrolysate, CDC requested assistance from the U.S. Environmental Protection Agency (EPA), Region II. EPA agreed to independently evaluate the ecologic risk associated with discharge of SET-treated CVXH in the Delaware River. EPA internally peer-reviewed their evaluation, and CDC had the EPA assessment peer-reviewed external to the government.

    Each of the evaluations is attached in its entirety (attachments 2-5), along with a list of abbreviations (attachment 1). The external peer-review comments are available upon request. Because of data gaps, the complexity of issues examined, and interrelations between the different aspects of the proposal, several lengthy rounds of formal questions and requests for information were submitted to DuPont, the U.S. Army, and Army contractors. The findings from this evaluation are based primarily on data requested by and provided to CDC. Each evaluation itemizes the pertinent materials reviewed. CDC cannot guarantee the completeness or accuracy of all information used to complete this evaluation. Therefore, significant new information that may become available after publication of this report could change CDC’s findings and conclusions.


    Finally, in the interest of ensuring technical accuracy, the Department of Health and Human Services provided officials at the Department of Defense (DoD) with a draft copy of this report in December 2004. Comments were received from DoD officials in January 2005 and were addressed by CDC and EPA. A final external peer-review of the entire report, plus EPA’s findings and the responses to comments from DoD officials was conducted, and the results of each of these efforts are available upon request. Once the report was completed, the DoD requested to provide official comments.

     

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