Issue Date: May 5, 2008
Incineration of VX hydrolysate
The article regarding the incineration of VX hydrolysate (VXH) at the Veolia Environmental Services incinerator several miles outside the city of Port Arthur, Texas, suggests that the operation could be harmful to public health and the environment (C&EN, March 24, page 29). As an expert witness during the hearing before Judge Larry J. McKinney last summer, I satisfactorily addressed all the incineration issues raised in the article. C&EN could have contacted me regarding these issues to determine the merits of its concerns, rather than raising scientifically indefensible fears in the article.
VX readily decomposes at high temperatures. The Veolia incinerator has demonstrated the ability to incinerate 1,2-dichlorobenzene (a difficult-to-incinerate compound) with a destruction and removal efficiency (DRE) of greater than 99.99999%. VX (a more easily incinerated compound) would have a much higher DRE in the Veolia incinerator.
To date, the Army has destroyed more than 2,000 tons of VX via incineration. VX has never been detected in the incinerator stack gas effluent. VX in VXH exists at zero or near-zero levels. Even if present, VX in Veolia incineration emissions would be too low to measure by current monitoring technology. There is no scientific basis to justify continuous monitoring of VX in stack emissions as suggested in the article.
Concerns expressed at the end of the article about dioxin emissions also lack foundation. Dioxins are created in the natural environment from many combustion sources, including forest fires. The optimal temperature for dioxin formation is approximately 450 °F. At the Veolia facility, incineration gases leave the secondary combustion chamber at around 2,100 °F and are rapidly cooled to approximately 185 °F in the quench tower. There is minimal opportunity for dioxins to form. The most recent trial burn for the Veolia facility demonstrated that emission of dioxins is extremely low; approximately one-sixteenth the facility’s regulatory limit, as expected.
Worldwide, the majority of chemical warfare agents have been safely destroyed by incineration. The Veolia facility is a modern hazardous waste incinerator that is compliant with both the Resource Conservation & Recovery Act and Maximum Achievable Control Technology. The facility is stringently regulated by the state and federal governments and is highly effective in destroying aqueous feeds, including caustic VXH that may contain trace concentrations of VX. Contrary to C&EN’s speculations, the public and the environment have not unwittingly “been put at risk of exposure to some of the most toxic and lethal chemical substances ever devised.”
Richard S. Magee
The article concerning destruction of VX hydrolysate at the Veolia Port Arthur, Texas, incinerator contains several misstatements and fails to include critical information:
1. The article claims that the Army signed the waste disposal contract “with no public notification.” Though not required by our operating permits, Veolia briefed numerous community leaders and elected officials about the project well before signing this contract.
2. The article states that “the Veolia facility is located in a low-income minority community...” Our incinerator is actually located in the countryside; the nearest resident is approximately 3 miles away; the nearest point in Port Arthur is 3.5 miles away, while central Port Arthur is about 10 to 12 miles away.
3. Opponents asserted this project threatens human health and the environment. After two-and-a-half days of hearings, a federal judge rejected these claims.
4. After hydrolysate shipments began, no one, including the plaintiffs, opposed the issuance of the incinerator’s Title V air permit.
5. The discussion about using an on-site supercritical water oxidation (SCWO) unit to destroy hydrolysate overlooks several problems:
a. SCWO technology has never been a commercially viable technology.
b. Constructing SCWO would cost $300 million to $500 million, not including operational costs, with no guarantee that it would work. Incineration is a proven technology and costs are much lower.
c. SCWO would generate large amounts of process effluent that would require disposal. Public and regulatory acceptance of disposal of this process waste stream would be required.
6. Before shipments began, the Army briefed emergency response and safety officials of every state through which shipments would travel. None has opposed the shipments, then or now.
7. The Army’s work at the Newport site is overseen or has been reviewed by several state, federal, and international agencies; many reviewed the analytical procedures used by the Newport facility carefully and found them acceptable.
8. The speculations about harmful emissions of dioxins and VX are especially baseless and constitute scare tactics of the worst sort. There is not a single shred of scientific evidence to support the reporter’s speculations. Veolia has more than 10 years of test data showing the incinerator’s effectiveness in destroying hazardous materials.
We are proud to have helped the U.S. Army in its efforts to destroy these chemical weapons. Regrettably, the C&EN article fails to give an objective and unbiased account of this important topic.
Mitch Osborne, General Manager
Veolia ES Technical Solutions LLC
Port Arthur, Texas
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