STOPPER

Raymond Proffitt Foundation
July 2004

The Proposal to Treat and Discharge
VX Nerve Agent Hydrolysate into the Delaware River

by Rich Myers

The U.S. Army is proposing to pre-treat stockpiles of VX nerve agent at its Newport Chemical Agent Disposal Facility in Newport Indiana, and then transport the resulting hydrolysate across the country to the DuPont Chambers Works facility at Carney’s Point, Salem County, NJ for final treatment and disposal into the Delaware River.

The Chemical Weapons Convention, in force as of April 29, 1997, requires destruction of chemical weapons by the year 2007.  The US stopped production and shipment of chemical agent and weapons in the late 1960’s.  For nearly 40 years chemical weapons have been stored at the Newport Chemical Depot.  Originally the Army agreed with its Indiana Citizens’ Advisory Commission and planned to destroy and dispose of the VX nerve agent stored at the Depot on site, at the Newport Chemical Agent Disposal Facility.  Following the attacks of September 11, 2001 the Army changed its mind, and decided to partially treat the nerve agent on site, turning it from VX nerve agent to VX hydrolysate, and then transport it to an alternative facility for final treatment and disposal.

The Newport Indiana community has repeatedly voiced its preference that the VX nerve agent be treated, destroyed and disposed of on site in Newport as originally agreed to by the Army.  But the Army has, unilaterally, decided to veer from that agreed upon course of action.

First the Army proposed to ship the VX hydrolysate to a company in Ohio for further treatment and disposal.  A strong public outcry against the proposal forced the Army to abandon it.  By August 2003, the Army was already proposing to instead ship the VX hydrolysate to DuPont along the Delaware River although the proposal was only noticed publicly in December 2003.  

The Army is proposing to “neutralize” the VX nerve agent stored at the Newport, Indiana facility using a chemical neutralization process.  The neutralization process results in a solution called VX hydrolysate or VXH.  While VX hydrolysate is said by the Army to be much less toxic than VX, they agree that additional treatment is needed in order to meet requirements for disposal.  Additional treatment is also necessary to meet the requirements of the Chemical Weapons Convention.   

There are a number of concerns associated with VX hydrolysate.  VXH is highly caustic and could be harmful to humans and materials.  VXH has a very strong odor. It is possible that under the right conditions (if the pH were decreased below the 13 to 14 range) VX could be reformed.  And the organic layer in VXH is flammable; therefore VXH must be kept sealed from the environment at all times. (1)  

Chemical neutralization of other chemical weapon agents such as mustard and nerve agents also produce hydrolysates.  But the composition of each hydrolysate and the potentially viable treatment alternatives for each hydrolysate varies.  Therefore, DuPont’s history with treating mustard agents at this Chambers Works facility does not necessarily translate into a capability to handle VX hydrolysate.  

The Army asserts that prior to transport the VX hydrolysate will “be analyzed and certified that it contains no detectable nerve agent before it leaves the destruction site in Indiana.”  (2)  This does not mean that the VX hydrolysate will not contain any VX.  The detectable limit being used by the Army is 20 ppb, therefore the Army will allow VX nerve agent to be shipped off site and to New Jersey as long as the VX in the hydrolysate is less than 20 ppb. .  

According to an Ohio EPA study, VX at a level of 20 ppb after 17.4 hours killed half of the striped bass exposed.  As a result of this and numerous other concerns, an agency toxicologist “strongly recommended” against discharge of treated VX hydrolysate into the local POTW and waterbody until there was “more information about the possible toxic effects of the treated hydrolysate discharge on aquatic life”. (3)  Further, in an August 26, 2003 article in Chemical & Engineering News, Terry Arthur, a Newport spokeswoman said that while the Army committed not to ship VX hydrolysate off-site unless the VX levels were less than 20 ppb, it couldn’t now honor such a commitment.  She went on to say, “As measured, caustic neutralization produces a hydrolysate containing 40 to 80 ppb of VX.” (4)  

After neutralization, the VX hydrolysate contains Ethylmethylphosphonic acid (EMPA), mehylphosphonic acid (MPA), 2-(diisopropylamino) ethanethiol (thiolamine), and EA2192.  (3)   EMPA and MPA are “schedule 2 precursors” in the Chemical Weapons Convention, meaning they could potentially be reconverted to nerve agent.  (5)  EMPA and MPA are resistant to biological treatment.  (3)   EA2192 is as toxic as VX and is the most toxic degradation product from VX hydrolysis.  (3)  Little is known about most VX hydrolysis degradation products – the products that result from neutralizing VX as proposed.  (3)  

There are no bioassay toxicity data for EA2192.  But it is known that while EA2192 does not bioaccumulate it “retains its anticholinesterase [nerve-agent] activities and. therefore is a potential toxic threat to aquatic life”.  (3) (1) (6)  There do not appear to be any studies on the impacts of MPA, EMPA or EA2192 on the environment or aquatic resources.  The toxicity effects of these chemical compounds needs research as all three compounds may be present in the discharge that enters the Delaware River as a result of DuPont’s proposed treatment method.  

In a May 6 letter, Carol Collier, Executive Director of the Delaware River Basin Commission (DRBC) notified the DuPont Company that they would not be permitted to treat the nerve agent hydrolysate at their Deepwater, New Jersey facility under the facility's 1991 permit until the DRBC has reviewed and gives approval to the proposal.  The DRBC is now also questioning whether DuPont has the right to treat Mustard gas waste products from the chemical weapons stockpile at the Aberdeen Proving Ground in Maryland under the 1991 DRBC permit. (7)

Both New Jersey Governor James McGreevey and Delaware Governor Ruth Ann Minner sent a letter to the Army opposing the plan to treat the VX waste at the New Jersey facility.  Regulatory agencies in Delaware and New Jersey are also looking a DuPont's current permits and reviewing them to determine if the VX proposal and other chemical weapon disposal contracts undertaken by DuPont comply with existing permit requirements. (7)

The Delaware Riverkeeper Network recommends that the Army should revert back to its original plan to treat and dispose of the VX Nerve Agent on site, at the Newport, Indiana facility.  The Newport, Indiana community has been vocal in supporting this option and through an advisory committee worked for many years with the Army on devising a safe and effective process acceptable to all.  This option also avoids the dangers that accompany a long transport of VX hydrolysate which contains dangerous constituents and can contain any amount under 20 ppb of VX nerve agent. 

To review Dupont studies on the proposal go to www.set.dupont.com. (click on SET-U.S. Dept. of Defense Initiatives); to review the Army’s Draft Revised FONSI, contact S. Gilman, Newport Stockpile Outreach Office 765-492-4445.  

(1)     Final Report, Treatment of VX Hydrolysate by PermaFix of Dayton, Report prepared for 
Montgomery County (OH) Commissioners by Dr. Bruce E. Rittmann, John Evans Professor of
Environmental Engineering, Northwestern University

(2)     Letter from Colonel Jesse L. Barber, Department of the Army to Maya van Rossum, the Delaware

      Riverkeeper, January 16, 2004.

(3)     Interoffice Memo from John F. Estenik, DSW, Toxics Advisor, Subject Treated VX Hydrolysate
Discharge Recommendation Technical Report, October 10, 2003, Ohio EPA

(4)     August 26,2003 Chemical & Engineering News "Destroying Chemical Weapons, Army’s Problem-

      Plagued Program More Costly than Originally Planned”, Lois R. Ember  

(5)     Using Supercritical Water Oxidation to Treat Hydrolysate from VX Neutralization, 1998,

      Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Board on   

      Army Science and Technology, Commission on Engineering and Technical Systems (CETS), National

      Research Council, National Academy Press, 1998, also found at

      www.nap.edu/openbook/0309060435/html/7-10.htm

(6)     Report prepared for Montgomery County (OH) Commissioners by Dr. Bruce E. Rittmann, John
Evans Professor of Environmental Engineering, Northwestern University

(7)  The News Journal May 13, 2004 article by Jeff Montgomery, Staff Reporter

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