text:
GreenLaw Preliminary
Risk Analysis of the
Army Chemical Weapon
Incineration Program
Mick Harrison J.D.
Program Director
Washington, DC
September, 1996
(This publication was made possible by a grant from the Educational Foundation of America)
As of this writing, the Department of Defense (DOD) and the Army continue to pursue a
large scale incineration program for disposal of chemical weapons. The Chemical
Weapons Working Group (CWWG) has expressed concerns publicly and to the Army and
the Environmental Protection Agency (EPA) that the Army chemical weapons incineration
program poses an unacceptable risk to public health and the environment. The Army has
taken the position to date that their chemical weapons incineration program is safe and does
not pose an unacceptable health or environmental risk. The purpose of this GreenLaw
report is to present a preliminary analysis of recent risk assessment work to determine the
extent to which the Army's position is consistent with available scientific evidence.
EPA Administrator Carol Browner has implemented a new "combustion strategy" or policy
for hazardous waste incinerators which requires the preparation of comprehensive multi-
pathway risk assessments prior to permitting hazardous waste incinerators or renewing
permits. Such risk assessments are explicitly required to address dioxin-like compounds
emitted, as well as the other toxic emissions, and the extent human and ecosystem exposure
to these chemical poisons will occur via direct (e.g. inhalation) and indirect (e.g. food
chain) exposure pathways.
Multi-pathway risk assessments have recently been performed regarding the on-going
Army chemical weapons incineration program at Johnston Atoll (JA) in the Pacific, and
such risk assessments have been performed for the planned incineration programs in Utah,
Alabama and Oregon. Arkansas, Kentucky, Indiana, Maryland and Colorado, which are
also proposed sites for Army chemical weapoons incinerators, do not have risk
assessments completed, but work on the risk assessment protocols is proceeding in
Arkansas, Kentucky and Colorado. The Army has been incinerating chemical weapons in
the Pacific for several years and constructed the Utah incineration facility and proceeded
with trial burns in the absence of a risk assessment. Analysis of risk from the chemical
weapons/nerve gas incineration project, particularly food chain and dioxin related exposure
and risk, has largely been an afterthought forced on the Army by EPA and public concerns.
GreenLaw has reviewed the Army's risk assessments for the Utah (Tooele), Alabama
(Anniston), Oregon (Umatilla), and Johnston Atoll incinerators and states that these risk
assessments support two conclusions:
1) that the Army chemical weapons incineration program does pose an
unacceptable risk, and
2) that the Army is knowingly failing to disclose significant risks and scientific
evidence relating to risks involved in their incineration program. This
GreenLaw risk analysis report was prepared on behalf of CWWG and is based
not only on the Army's risk assessment documents but also on EPA reports on
dioxin, incineration and risk assessment.
Risks to Public Health and the Environment from
Release of Toxic and Bioaccumulative Dioxin-like
Chemical Combustion By-products from Chemical
Weapons Incineration
One of the most disturbing aspects of the Army's 1995 Anniston Screening Risk
Assessment (Anniston RA) and the more recent risk assessments regarding JA (Army),
Umatilla (Oregon DEQ) and Tooele (Utah DEQ) is the Army's total avoidance of the
issue of the substantial risk of non-cancer adverse health effects resulting from the
incinerators' emissions of dioxin and dioxin-like compounds. Dioxin is one of the most, if
not the most, potent chemical poison and carcinogen ever studied.
The Army and Oregon and Utah Departments of Environmental Quality (DEQ) totally
ignore dioxin non-cancer risk without justification. This is remarkable in light of EPA's
1994 Dioxin Health Assessment report (dioxin reassessment) which evidences harm to,
inter alia,the reproductive and immune systems from very low level dioxin exposures.
The old agency and industry practice of focusing exclusively on dioxin cancer risk has been
shown by the EPA 1994 dioxin reassessment to have been a serious mistake. It is now
understood that non-cancer adverse effects are a more sensitive endpoint for dioxin
exposure than cancer. It is clear, notwithstanding the avoidance of the issue by the Army,
that non-cancer adverse effects are expected to result from the Army chemical weapons
incineration program. The basis for this conclusion is explained infra.
Based on EPA data on dioxin emissions from hazardous waste incinerators, considered
together with the EPA's new dioxin reassessment report (EPA, 1994), which reports
research and analysis on the levels of toxicity and carcinogenicity of dioxin, the Army
nerve agent and chemical weapons incineration program is expected to emit enough dioxin
and related compounds to be capable of causing adverse health effects in millions of people
if the dioxin-like compounds are captured in the food chain and consumed. The same
conclusion results from a review of the Army's dioxin emissions estimates, as presented
infra. Thus, the accurate performance of a risk assessment is critical to determine what
portion of this massive amount of chemical poison will be captured in the food supply (and
to determine the fate of the remainder of the dioxin that is concluded will not be captured in
the food chain).
Indisputable scientific evidence confirms that incinerator emitted dioxins and other
persistent poisons are transported hundreds of miles and accumulate in sensitive aquatic
and terrestrial ecosystems and food chains. The capture in the food chain of even a small
percent of the Army incinerator emitted dioxin-like chemical poisons, and resulting human
exposure, would cause serious harm via both cancer and non-cancer adverse health effects.
The risk of harm from dioxin emissions from the Army incinerators is transformed into
virtual certainty of harm by the findings of the EPA dioxin reassessment that national
exposure to dioxin from existing sources, primarily incinerators, is already 1-2 orders of
magnitude greater than any virtually safe dose or reference dose (RfD) EPA might
calculate for dioxin (EPA 1994, pp. 9-84).
The Army and Oregon and Utah DEQs, when pressed regarding their failure to assess the
risk of non-cancer adverse effects from dioxin exposure, assert that this major omission is
due to a lack of toxicity information on dioxin. The Army takes the position that this
alleged lack of toxicity data prevents determination of a reference dose (RfD) or similar
benchmark to use in assessing the significance of dioxin exposures resulting from the
Army incineration program. The Army's omission of any RfD in its appendix risk tables
and in its appendix summarizing the toxicological profiles for the various chemicals
including dioxin; the reference in the text of the Army's Anniston RA to omitting
consideration of chemicals for which toxicity information was not available; and the
reference NA (meaning "not available") in the table on page P-5 of Appendix P Toxicity
Data, confirms that this is the Army rationale. The recently initiated litigation by the
CWWG, Sierra Club and the Vietnam Veterans of America Foundation against the Army
regarding dangers from planned operation of the Tooele facility has confirmed that both the
Army and the DEQ have adopted this rationale. However, this is not a credible reason for
the Army's and the DEQ's complete omission of analysis of dioxin non-cancer risks.
The 1989 Agency for Toxic Substances and Disease Registry's (ATSDR) toxicological
profile for dioxin, which the Army summarizes in an appendix to the Anniston RA, clearly
states the ATSDR conclusion that 1 picogram per kilogram of body weight per day (pg/kg-
bw/day) of 2,3,7,8 Tetrachlorodibenzo-p-Dioxin (TCDD) is a minimal risk level (MRL) for
non-cancer adverse effects. The Army could have calculated the hazard quotient for non-
cancer risk from incinerator dioxin emissions (exposure divided by RfD) using the ATSDR
MRL of 1 pg/kg-bw/day. An EPA risk assessment for the Times Beach, Missouri
Superfund site recently did just that. The Army's expert witnesses, Dr. Finley and Dr.
Guzelian, both of whom testified at the hearing for a preliminary injunction regarding the
Tooele facility acknowledge this ATSDR RfD of 1 pg/kg-bw/day. Instead, the Army,
conveniently, ignored the MRL for dioxin reported in the ATSDR toxicological profile.
The Army summarizes this ATSDR profile in Appendix Q of the Anniston RA along with
other such ATSDR profiles (pp. 68-9), but makes no mention of the MRL reported therein.
This omission is inconsistent with the detailed information the Army extracted from the
ATSDR toxicological profiles on numerous other chemicals of concern in Appendix Q, and
inconsistent with the Army's awareness of the MRL concept in the context of its acute
exposure assessment (Anniston RA, pp. 68-9 & Appendix Q).
The Army also conveniently ignores the EPA's 1994 dioxin reassessment which notes in
chapter nine that current national average background (existing) dioxin exposures exceed
any RfD that might be calculated by EPA, by one or two orders of magnitude. This 1994
EPA analysis, while not explicitly reporting an EPA identified RfD, clearly states that the
RfD would be 10-100 times the current dioxin exposures reported in the same EPA dioxin
reassessment report as 3-6 pg/kg-bw/day (TEQs). Thus EPA's 1994 report clearly
supports a RfD for dioxin in the range of .03 to .6 pg/kg-bw/day.
The Army's apparent ignorance of the 1994 dioxin reassessment analysis of dioxin non-
cancer adverse health effects is surprising given that the Army notes in its reference list in
the Anniston RA the 1994 EPA Estimating Exposures to Dioxin-Like Compounds multi-
volume report. This Estimating Exposures report was released by EPA simultaneously as a
companion to the EPA dioxin reassessment which the Army omits from its reference list.
This omission of the EPA's 1994 Dioxin Health Assessment report is surprising also
because the Army purports to have included the "most current chronic toxicity data" in the
Anniston RA, Appendix P (p. 67). The GreenLaw analysis that follows shows why the
Army may not be anxious to address dioxin non-cancer risks from its chemical weapons
incineration program and why the Army does not wish to draw attention to the EPA's
recent dioxin reassessment.
The Army estimates, based on emissions data from the Johnston Atoll Chemical Agent
Disposal System (JACADS), that dioxins will be emitted from the Anniston facility at a rate
of 3.360375 E-09 grams per second (g/s) TCDD toxic equivalent quotients (TEQs)
(Anniston RA, TEF table, p. 70 & Appendix G, Emission Rates). Making no corrections
for errors noted in Greenpeace scientist Pat Costner's analysis of the JACADS emissions
test results, or for factors noted infrasuch as upsets and unidentified products of
incomplete combustion (PICs), and using the .03 and 1.0 estimates of a RfD for dioxin
supported by ATSDR and EPA reports noted supra, the amount of dioxin expected to be
emitted from the Army incinerators in terms of how many people the emissions are capable
of harming if the emissions are captured in the food chain and consumed is as follows:
Using 1 pg/kg-bw/day RfD, # toxic doses = 4,838,940
[this is for ANCDF (Anniston Chemical Disposal Facility) only, not
CMDFS (conventional munitions combustor)]
Using .03 pg/kg-bw/day RfD, # toxic doses = 161,298,000
Tooele (Anniston x 43/7):
Using 1 pg/kg-bw/day RfD, # toxic doses = 29,724,917
Using .03 pg/kg-bw/day RfD, # toxic doses = 990,830,571
Total Army incineration program (Tooele x 100/43):
Using 1 pg/kg-bw/day RfD, # toxic doses = 69,127,714
Using .03 pg/kg-bw/day RfD, # toxic doses = 2,304,257,143
If the Army dioxin emission rates are adjusted to account for just those non-conservative
assumptions noted herein, such as emergency condition upsets and unidentified PICs, the
number of potential toxic doses emitted would be 20 times greater than the numbers stated
The Army estimates, in the Anniston RA, a dose of dioxin consumed for purposes of
estimating cancer risk for the subsistence farmer. This dose is 1.37 pg/day, which for a 60
kg adult would be .02283 pg/kg-bw/day. The Army's estimated dose is, however, an
underestimate of dioxin exposure resulting from the chemical weapons incineration
program by a factor of at least 60 because it does not adequately account for upset
emissions (a factor of at least 2), additional food sources such as game, eggs and poultry (a
factor of at least 1.5) and unidentified dioxin-like PIC emissions (a factor of 10), and is
based on several non-conservative assumptions regarding factors such as percent of dietary
beef and milk that is locally produced (a factor of at least 2), as noted infra. Thus, a more
realistic dioxin dose estimate for Anniston would be approximately 1.3698 pg/kg-bw/day
TCDD TEQs, which exceeds all RfDs supported by the current EPA and ATSDR reports.
Even without these corrections, however, the Utah DEQ January, 1996 Health Risk
assessment (HRA) showed unacceptable non-cancer risks for the nursing infant of the
subsistent farmer. The Utah DEQ January, 1996 HRA for the Tooele facility reported a
dioxin dose of 50 pg/kg-bw/day for the nursing infant of the subsistence farmer. The DEQ
addressed this alarming result by excluding the infant and the subsistence farmer from the
final February, 1996 version of the Tooele HRA. However, in federal court the Army's
risk assessment expert, Dr. Finley, admitted that an infant of the non-subsistence farmer,
the adult version of which was included in the final DEQ HRA, based allegedly on a site
specific survey of farming practices, would, based on DEQ's methods and assumptions,
receive a dioxin dose from the Tooele facility of 4.2-9.8 pg/kg-bw/day. This infant dioxin
dose acknowledged by the Army's Dr. Finley was not reported in the final DEQ HRA
because only the adult non-subsistence farmer was addressed. The DEQ apparently
assumed that farmers are born adults and never experience infancy or childhood.
Even if the dose of dioxin actually consumed by persons living near (or far) from the Army
chemical weapons incinerators as a result of the incinerators' emissions was less than an
appropriate RfD or threshold value, because of the existing background exposures from
other sources, additional harm to human health would still be expected as a result of dioxin
emissions from the Army incinerators. EPA's 1994 dioxin reassessment makes clear that
the population nationally has an average exposure that exceeds any conceivable reference
dose for dioxin. The EPA reassessment also makes clear that the individual members of
our population are widely spread in regards to dioxin exposure, with some being
considerably higher in exposure than the average and some lower.
Those at the average exposure and above are clearly in the danger zone from a public health
and risk assessment standpoint, having an exposure that exceeds the RfD. The additional
dioxin exposure to these individuals that results from the Army incineration program must
be presumed to cause additional harm to their health. Further, for those who are below the
average and may be below the RfD, some will be close to the RfD and the additional
exposure from the Army incinerator emissions will cause their total exposure to exceed the
RfD and place them in the danger zone where harm would be expected. Even if the RfD,
because of its incorporation of certain safety factors, is not actually the threshold for
harmful exposures, the highest exposed members of the population are likely at or over the
actual threshold given that the average US dioxin exposure is 10-100 times higher than
the reference dose. The fact that humans are already in the danger zone for dioxin exposure
is made clear in a recent EPA report in the science journal, Environmental Health
Perspectives (DeVito, et al, September 1995). In that report, EPA's Linda Birnbaum and
others report that humans in the US have an average exposure that has been known to be
high enough to cause adverse immune system effects in animal studies.
The toxicity of the total emissions of products of incomplete combustion (PICs) from
chemical waste incinerators is expected to be, and from a public health standpoint, must be
presumed to be, at least 5-10 times greater than the toxicity of the small percentage of PICs
that have been identified to date by EPA and industry stack testing. EPA incineration
studies show that the organic chemical PIC emissions from chemical waste incinerators
have yet to be fully characterized with only 12% on average of the PIC emissions having
been identified to date. EPA guidance on how to make incineration emissions estimates for
risk assessment purposes recommends that a prorata procedure be employed to estimate
total PIC emissions based on the assumption that the unidentified PICs are at least as toxic
as the identified PICs.
The Army's Anniston RA alludes to the need for this adjustment in emissions estimates and
suggests that an initial adjustment was made in the screening assessment and that a final
more complete adjustment will be made after the trial burn in the final risk assessment (pp.
31-32). A reasonable adjustment of dioxin and PIC emissions estimates for risk
assessment purposes based on this 80-90% of historically unidentified PICs (including
dioxin-like PICs) at this stage of the Army's assessment would be to assume 90% of such
emissions are unidentified and to correspondingly multiply the Army emission estimates
(and risk estimates for dioxins and PICs) by 10 to account for these unidentified
compounds. The Utah and Oregon DEQs' RAs make an adjustment for unidentified
compounds based on the total organic carbon emissions but it is not clear that dioxin
emissions were included in the adjustment.
Upsets during chemical weapons incineration are expected to increase PIC emissions
considerably compared to emissions during normal operations. EPA's 1985 Science
Advisory Board report on incineration confirms that occurrence of upsets and the
potentially significant impact of upsets on emissions. EPA's current guidance on
incineration emissions estimates for risk assessments recommends, in the absence of actual
site specific data on frequency of upsets and upset emissions, that the following
assumptions be used.
1) The incinerator will operate under "poor combustion" conditions 20% of the
2) Emissions during poor conditions will be 10 times greater than during normal
3) Emissions during "emergency conditions," such as bypass or failure of
pollution controls, or major combustion upset, will be 100 times greater than
during normal operation.
The Army, the Utah DEQ and the Oregon DEQ do calculate the EPA recommended default
adjustment for upset emissions from poor operating conditions by multiplying the normal
emissions by a factor of 2.8. This 2.8 default factor of the EPA is based on the assumption
of poor operation 20% of the time but does not consider the occurrence of "emergency"
conditions referenced above. Thus, this 2.8 factor may not adequately reflect total
increased emissions from upsets during incineration of chemical weapons. The
problematic experience at JACADS and recent disclosures by the former chief safety officer
of numerous safety violations at the Tooele facility suggest that emergency conditions will
occur at Tooele, Anniston and the other planned incineration operations.
The effort to demilitarize chemical weapons thus far at JACADS, and to prepare to do so at
Tooele, has been accompanied by myriad problems, ranging from basic design flaws, and
repeated mechanical failures to releases of actual live nerve agent and retaliation against
whistleblowers. As an example of the serious nature of the problems encountered, there
were eight occasions where tracking of munitions failed resulting in improperly processed
chemical munitions at JACADS. As noted by the National Research Council (NRC), the
Resource Conservation and Recovery Act (RCRA) permit only allows the JACADS metal
parts furnace (MPF) to process parts having 5% or less of the chemical agent originally in
the projectile (5% or less residual contamination). However, the Army fed undrained
agent-filled projectiles into the metal parts furnace on several occasions, which is a major
incident of non-compliance (NRC 1994, p. 53).
While achieving 500 hours of demilitarization and incineration, the JACADS workforce
accumulated 1,944 hours of lost-time accidents, i.e., every hour of active demilitarization
was accompanied by 3.9 hours of injury-related lost-time among the workers. While no
OSHA inspections have been reported for JACADS, during 62 inspections of 29 other
hazardous waste incinerators, OSHA inspectors identified 320 violations. More than 66
percent of these were regarded by the agency as "serious."
A more recent Occupational Safety and Health Administration (OSHA) inspection of a
federally run incinerator in Arkansas resulted in a finding of numerous serious and some
willful violations by the federal contractors there who are responsible for incineration of
dioxin contaminated agent orange waste. OSHA imposed fines of approximately one
quarter of a million dollars. At the Vertac EPA-run and State Agency-run dioxin
incinerator, dioxin waste was observed routinely burning on the outside of the
incinerator. In April 1996, an EPA-run dioxin incinerator in Times Beach, Missouri
experienced emergency conditions--a major failure of the combustion and pollution systems
as well as the back up burner in the by-pass stack, resulting in the emission of unburned
and unfiltered dioxin contamination directly into the environmental. This record at JACADS
and at incinerator facilities nation-wide supports the inference that violations, errors and
accidents will occur during the Army nerve agent incineration program resulting in the
increased release of PICs, dioxin-like compounds and nerve agent.
In 1994 a whistleblower employee was fired at the Army's Tooele, Utah chemical
weapons/nerve gas incineration facility by Army contractor EG&G. This whistleblower,
Steve Jones, who was the chief safety officer, has presented highly credible testimony to
the effect that the Army and/or its contractor at the Tooele facility have attempted to rush
operations, disregarding environmental, worker and public safety requirements in the
process, and when confronted with safety violations attempted to sweep them under the rug
by firing Jones who refused to sign off on the attempted whitewash. Jones has brought an
environmental statute employee protection complaint before the US Department of Labor
making these allegations and alleging that he was retaliated against because of federally
protected activities, in violation of RCRA, 42 U.S.C. sec. 6971. His case is pending.
Hazardous waste incinerators unfortunately frequently experience fires, explosions and
accidental releases of hazardous chemicals as illustrated recently at the WTI incinerator in
Ohio, the Vertac incinerator in Arkansas, and the ThermalKEM incinerator in South
Carolina, to name a few. Records from other incinerators nationwide reflect that
combustion upsets are common and that even emergency conditions requiring use of dump
or bypass stacks or vents that allow combustion gases to entirely bypass pollution controls
are common. Two recent cases of incinerators illustrating this phenomena are the
ThermalKEM hazardous waste incinerator in South Carolina and the EPA/Morrison
Knudsen dioxin incinerator at the Vertac site in Arkansas. The performance record at
JACADS and at incinerator facilities nationwide supports the inference that operations
during the Army nerve agent incineration program will not always go as planned and that
upsets, including what EPA terms emergency conditions, will occur.
The Army's use of EPA's 2.8 upset emission factor to reflect poor operating conditions is
laudable but the apparent unstated assumption by the Army that the Tooele, Anniston and
other incineration facilities will never experience emergency operating conditions is
inconsistent with past experience at other incinerators and non-conservative. Further, given
the JACADS experience, a 20% assumption for the period of operation in poor combustion
conditions may, in itself, be underestimating the occurrence of upsets.
An occurrence of emergency operating conditions during 1% of the operating time--during
which, consistent with EPA guidance, it is assumed emissions are 100 times greater than
normal--would result in an effective doubling of emissions even after adjustment for the
2.8 factor for poor operating conditions. Specifically, a more realistic and conservative
adjustment of emissions estimates to account for all types of upsets would involve
assuming normal operation 79.2% of the time, poor operating conditions 19.8% of the
time, emergency operating conditions .8% of the time, and overlap of poor and emergency
conditions (e.g. a modest combustion upset, poor operating condition, occurring during a
pollution control failure, an emergency operating condition) .2% of the time.
The total emissions under this scenario in relation to normal would be .792+ (.198 x 10) +
(.008 x 100) + (.002 x 1000) = 5.572, that is the emissions would be 5.572 times greater
than normal. Thus the Army use of the 2.8 upset factor is non-conservative and a potential
underestimate of emissions by a factor of about 2.
The Army and state agencies use the EPA standard for unacceptable non-cancer risk from
chronic exposure to combustor emissions which is the .25 hazard index. The hazard index
is simply a sum of hazard quotients. Hazard quotients are simply fractions made up of a
numerator which is the predicted or measured quantity of exposure or dose divided by a
denominator which is the quantity of exposure or dose considered virtually safe. The
virtually safe dose is often called the reference dose (RfD) or minimal risk level (MRL).
Historically, a hazard index of 1.0 was used as the non-cancer risk standard. This meant
that for a source of toxic emissions to be considered unacceptably dangerous, the exposure
caused by that source alone would have to exceed the reference or virtually safe dose.
Recently EPA, in response to concerns from grassroots citizen and environmental groups,
has established a new combustion policy which, among other new requirements such as
food chain risk assessments and dioxin emission tests, has established the .25 hazard index
standard. This change made the standard four times more protective and was intended to
partially account for the existence of multiple combustion facilities in the same community
or area that would exert a combined impact on the local environment and public health. The
EPA established the .25 standard as a default standard. That is, EPA established the .25 as
a standard to be used where site specific (or national background) information does not
indicate that the presence of multiple sources, such as existing incinerators, makes the
default standard not adequately protective. Such circumstances could occur given that non-
cancer risk is currently thought by EPA and industry to be determined by whether the total
combined dose from all sources of a chemical poison exceeds a threshold.
In some cases for some pollutants, the presence of multiple existing incinerators creates
such a toxic burden in the community that allowing a new incinerator to emit pollutants up
to the .25 hazard index standard would allow the total exposure to community members to
exceed the old 1.0 standard and be at real risk of exceeding the threshold for non-cancer
adverse health effects. EPA's 1994 dioxin reassessment shows this problem clearly, and
on a national scale, for dioxin. Reports from various states such as New Jersey and
Florida show that the same dangerous situation is already widespread for mercury.
National studies also confirm this to be the case for lead exposure.
The Army uses the .25 hazard index non-cancer risk standard in the Anniston assessment
for chronic exposure (pp. 73, 97). The Army's use of the EPA .25 default hazard index
standard, while certainly more appropriate than using the 1.0 standard, may nonetheless be
non-conservative in the case of several pollutants including dioxin because of the existence
of multiple incinerators near the Army's proposed chemical waste incinerator sites in, for
example, Utah and Arkansas. On a national basis, the Army's use of the EPA .25 default
hazard index standard is clearly non-conservative and inappropriate in the case of dioxin
given the national background dioxin exposure from multiple sources, primarily
combustion sources, already documented by EPA in the 1994 dioxin reassessment report.
The Army makes no attempt to come to grips with the fact that the EPA has confirmed that
dioxin exposures from existing sources already exceed any conceivable virtually safe dose
(EPA 1994, Vol. III, Chap. 9, pp. 9-84). In such circumstances, operating a new source
of dioxin emissions such as the Army chemical weapons incinerators would cause
additional non-cancer adverse health effects given that the threshold for such effects has
already been exceeded. This should have been acknowledged in the Army risk assessment
and should have been a basis for concluding that the Army incineration program poses an
unacceptable risk to human health.
Simple application to dioxin of the non-cancer risk method used by the Army in the
Anniston RA for other pollutants would have resulted in this conclusion that non-cancer
risk from dioxin was unacceptable in light of existing exposures. Under these
circumstances, the Army's omission of any analysis of dioxin non-cancer risk and
omission of any reference to the EPA 1994 dioxin reassessment findings substantially
undercuts any Army claim of objectivity and comprehensiveness in the Army risk
assessment effort. The same is unfortunately true regarding the Utah DEQ's omission not
only of dioxin non-cancer effect but of the breast feeding infant and subsistence farmer.
This error of omission is not cured by the mere notation by the Army in the uncertainty
analysis section of the Anniston RA that "toxicity assessment generally contributes the most
uncertainty to an RA, including this SRA (screening risk assessment)" and that the
"primary uncertainties associated with the toxicity assessment include: "limited or no
toxicological studies and/or values: for many SOPCs [substances of potential concern]
(e.g., PCDDs/PCDFs) ..." (p. 82). This is not just a whopping understatement; it is a
gross misrepresentation considering the volumes of dioxin [PCDDs/PCDFs] toxicity
studies and data reviewed by EPA in the 1994 reassessment reports and considering that
the US. ATSDR's Minimum Risk Level for dioxin has been published since 1989 in the
Toxicological Profile for 2,3,7,8 TCDD.
The Army, in the Anniston RA, addresses cancer risk from dioxin emissions but, via key
omissions and non-conservative assumptions, underestimates the dioxin cancer risk
considerably. For the subsistence farmer the Army estimates in the assessment a 1.67 per
million cancer risk from dioxin emissions from the ANCDF--the two liquid incinerators
(LIC), metal parts furnace (MPF), deactivation furnace (DFS), and dunnage incinerator
(DUN), all of which deal with some components of chemical weapons disposal--and
estimates a 0.654 per million cancer risk from dioxin emissions from the CMDFS (p. 94,
Appendix O).
The likelihood that the Army underestimated the cancer risk for the subsistence farmer in
the Anniston HRA is reflected in the Utah DEQ's January 1995 and January 1996 HRAs
which report a cancer risk to the subsistence farmer of more than 900 per million--some 90
times higher than EPA's 10 per million risk standard. The Utah DEQ omitted the subsistence
farmer from the February 1996 final version of its HRA based on the alleged site
survey of farming practices. Apparently Utah DEQ has taken the position that if a farmer
chooses currently to not rely entirely on his or her own food production, that farmer is giving up the right to do so in the future.
There is also an immediate reason to be concerned that the Anniston facility dioxin cancer
risk is unacceptable. The operation of the ANCDF will be 6 years, the operation of the
CMDFS will be 34 years following those 6 years, and the length of exposure to dioxins
emitted at Anniston is assumed by the Army to be 40 years (Anniston RA, p. 19).
However, the Army compares the resulting risk estimate to a lifetime exposure acceptable
risk standard (70 year standard).
GreenLaw believes it inappropriate as a matter of policy to allow a facility that will operate
for a limited number of years to emit chemical poisons that in essence use up all of a person
or community's allowable lifetime risk in the space of a few years. This approach creates
the possibility that future uses of the location or facility, possibly several short term or
segmented projects, will be approved, each on the basis that the risk from that segment or
short term project creates a risk just under the 10 per million risk standard. The result from
approval of ten 5 year projects, each creating a risk of 9 per million, would be a 90 per
million risk, 9 times the federal standard for 70 year exposures, for projects totaling only
50 years in the same location.
This is not protective and circumvents the intent of the federal standard in a way similar to
the past illegal practice of some federal agencies of segmenting major federal projects to
make it appear that a National Environmental Protection Act (NEPA) Environmental Impact
Statement (EIS) is not required or that impacts are insignificant. This inappropriate use of a
lifetime standard for a short-term exposure can be cured two ways--either prorating the risk
standard down from 10 per million to 0.857 per million for the ANCDF 6 year operation
(10 x 6/70) or arbitrarily multiplying the estimated risk by a factor of 70/6 for ANCDF and
by 70/34 for CMDFS. The Army dioxin cancer risk estimate for ANCDF with no
adjustments by GreenLaw, 1.674 per million is clearly higher than the six-year adjusted
risk standard of 0.857 per million. Therefore, the dioxin risk from ANCDF should be
considered unacceptable without further analysis.
Beyond the inappropriate use of a lifetime standard for a six-year project, however, the
initial dioxin cancer risk estimate by the Army for Anniston is a non-conservative
underestimate. The Army makes several non-conservative assumptions for values for
factors used in the risk calculation, in part based on the Army's interpretation of EPA
guidance. These factors are addressed individually below. Adjusting the risk estimate for
those factors discussed below, the Anniston dioxin cancer risk estimate for the subsistence
farmer of 2.238 per million would become approximately 150 per million. The 10 per
million borderline cancer risk estimate for the non-subsistence farmer in the Utah DEQ's
2/96 HRA would be well beyond the EPA risk standard when those adjustments not
already made by DEQ are implemented. If the dioxin cancer potency estimate in EPA's
1994 dioxin reassessment report which is based on human rather than animal data is
correct, these cancer risk estimates must all be increased by a factor of 20. (EPA 1994, Ch.
8) That is, for example, the Anniston GreenLaw cancer risk estimate of 150 per million
would be instead 3,000 per million.
The Army assumes that the body weight of the person(s) exposed is 70 kilograms (kg), or
155 pounds, which is the average weight of adult males (Anniston RA, p.66). 60 kg is a
more reasonable estimate of average adult (all adults) body weight for risk assessment
purposes, particularly in light of the purpose, acknowledged by the Army, of protecting the
most sensitive populations. The risk estimate can be adjusted for this body weight factor
by multiplying by 70/60 (or dividing by 60/70).
The Army assumes that the subsistence farmer uses his/her own farm produced beef and
milk for only 40-45% of his/her beef and milk needs. That is, the Army assumes, as EPA
guidance allows as a default assumption in the absence of site specific information, that
even though a farmer is raising beef cattle and dairy cattle and using some of it for his/her
family needs, that nonetheless the farm family still goes to the supermarket and buys more
than half of their milk and beef from some distant source shipped to their supermarket.
This assumption, as far as it is represented to be conservative for risk assessment
purposes, is contrary to common sense and contrary to information GreenLaw has obtained
on other incinerator cases.
GreenLaw has been told directly by a former farmer living in the vicinity of a South
Carolina hazardous waste incinerator that when he farmed he used his own beef cattle for
100% of his family consumed beef. He said that he occasionally went out to eat at a
restaurant but did so to order something different that he did not raise on the farm such as
seafood. The farmer's attitude was, why would he buy beef from a store when he had
fresher, tastier, and cheaper beef available to him from the farm. That logic is inescapable
and GreenLaw does not believe that his is the only farm family that shares this point of
view. There is no evidence that the Army consulted local farmers around Anniston to
determine if any of them held similar views. Testimony of Utah farmers presented in the
Tooele litigation supports the conclusion that farmers who raise beef or dairy cows are
likely to rely on their own production for 80-100% of their beef and dairy needs.
There is another critical reason why the Army is mistaken in its assumption, for risk
assessment purposes, that only a fraction of the beef and milk consumed by the subsistence
farmer comes from her/his own farm. This reason centers around the obvious, and
unfortunate, fact that there is not only one incinerator proposed or operating in the nation or
in any given state. Where does the farmer's out of town beef and milk come from? New
Jersey? Florida? California? Michigan? Arkansas? Ohio? Missouri? All of these states
have their share of incinerators operating or proposed, as do many other states, which is
one primary reason that the 1994 EPA dioxin reassessment notes that our national dioxin
exposure is already dangerously too high.
The Army's assumption, when applied on a national scale as the Army and EPA are at risk
of doing at this time, leads to a silent and invisible, but government approved, poison
trade. One farmer in community A produces his beef cattle near an incinerator in that
community. Another farmer in community B produces her beef cattle near an incinerator in
that community. Both ship part of their beef out of town (to each other's markets) and, on
the Army's assumption, get part of the beef in their diet from their farm and buy part at the
store from the other community's farmer. All the meat they eat is contaminated from
incinerator emissions, but the government tells them both incinerators are safe because a
risk assessment done on each concluded, based on the assumption that only 44% of their
beef was local grown, and therefore only 44% was contaminated, that the risk in each case
was only 7-9 per million cancer risk, or more important that they were consuming only
50% of the non- cancer adverse effects reference dose.
The poison they traded with each other did not count by the Army's and EPA's method.
But the farmers, and their families, will be just as poisoned as if the agencies had
acknowledged all the poison that was actually there. It does not matter whether the
government admits that the exposure is higher than the RfD, or admits that the cancer risk
is greater than their 10 per million standard. Chemical poisons obey only the laws of
nature, not the arbitrary laws and policies of human governments. The Army's use of the
assumption that the farmer gets more than half of his meat and milk from out of town
sources must be rejected as what it is--a reckless encouragement for the silent and invisible
trade of chemical poisons in the food supply. This factor can be approximately adjusted for
by multiplying the Army's risk estimate (which had a small contribution from vegetables as
well as a large contribution from beef and milk) by 2.
The Army uses the current EPA dioxin cancer potency (slope factor) in its Anniston
Assessment (1.56 x 10E+5 /mg/kg-bw/day). However, the Army fails to note the
considerable scientific uncertainty surrounding this cancer potency figure, uncertainty
acknowledged by EPA in its 1994 dioxin reassessment reports.
In the 1994 EPA dioxin reassessment, two estimates of dioxin cancer potency were
produced by the scientists drafting the report. One, based on animal dioxin exposure data,
was approximately 30% lower (a lesser estimate of potency or danger) than the current
estimate still in use. The other dioxin cancer potency estimate reported in the 1994 dioxin
reassessment, based on human dioxin exposure data, was 2,000% higher (a greater
estimate of potency or danger) than the EPA's 1985 estimate still in use.
The one recommended in the final chapter nine by the manager of the reassessment project
was the lower estimate based on animal data. That recommendation, along with the rest of
the reassessment, is still draft and under review. The EPA reassessment manager, in
chapter nine, in deciding to recommend the potency estimate based on the animal rather
than the human data, did not conclude that the estimate based on human data was wrong,
he merely concluded that the data were insufficient, in his view, to rely on it at this point.
That decision may be changed, and in GreenLaw's opinion should be changed, by EPA in
finalizing the reassessment. In the interim, use of the current 1985 EPA cancer potency
estimate, as in the Army's Anniston RA, results in a potential underestimate of dioxin
cancer risk by a factor of 20. The Army should have noted this uncertainty and reported a
range of estimated risks to account for it, but did neither.
As noted above in the consideration of non-cancer risk from dioxin, the Army's use of the
EPA 2.8 factor to account for upset emissions only partly implements the EPA guidance
and only partly accounts for upset emissions. A factor of 5.57 is more appropriate as
explained supra. Use of this 5.57 upset emissions factor results in an approximate
doubling of estimated dioxin and PIC emissions from the Army incinerators compared to
the Army's estimate in the Anniston RA.
As noted supra, in the discussion of non-cancer risk from dioxin emissions, in the absence
of definitive test data from the Army incineration facilities as to the percent of PICs that
have been identified and the percent unidentified to date, the EPA database on hazardous
waste incinerators supports use of the assumption that only 10-20% of PIC emissions have
been identified (80-90% unidentified). This would require multiplying PIC (and dioxin)
emission estimates by a factor of 5-10 to account for these unidentified compounds on the
assumption that the unidentified organic emissions are just as carcinogenic as the identified
organic compounds. The Utah and Oregon DEQ HRAs do make an effort to make this
adjustment but the calculations should be made prominent along with explicit narrative to
confirm that dioxin emissions were not ignored in these HRA adjustments given that
dioxin-like compounds would be expected to dominate the risk posed by the incinerators.
The Army relies on EPA guidance in its selective focus on certain food routes of exposure
such as beef and milk and in its exclusion of others such as poultry, eggs and wild game
(Anniston RA, p. 48). This limited view of the total food sources through which exposure
occurs, while allowing a simplification of the risk assessment task at the screening stage,
leads to an underestimate of exposure and risk. This omission of poultry and eggs is of
particular import given the acknowledgment in the Anniston RA that nearby counties
commercially produce significant quantities of broilers and eggs (pp. 7-8). It would not be
that difficult to add these other food sources to the analysis to ensure that the analysis is
conservative both in terms of total quantity of meat and vegetable intake and in terms of the
concentration of dioxin and other pollutants in the specific foods consumed. Deer and duck
hunters and consumers, for example, could receive higher concentrations of pollutants than
those who eat only domestic animals due to differences in grazing and foraging habits and
locations among wild versus domestic animals. This is likely in the Tooele, Utah area.
The Anniston RA notes hunting occurs at nearby parks and wildlife areas. Uncertainty in
the risk estimate arising from this limited focus on food sources was acknowledged by the
Army in the Anniston RA (pp. 76-7). In the absence of a more precise estimate, it would
not be unreasonably conservative to assume that the risk added from inclusion of these
omitted food sources is 50% that of the included sources (that is the risk estimate would be
adjusted by multiplying by 1.5).
Risk to Public Health and the Environment from
Emissions of Toxic Nerve and Blister Agents from
the Army Incinerators
Nerve and blister agents will be released via routine emissions from the stack due to less
than perfect destruction and removal efficiencies. Nerve agent will also be released as a
result of fugitive emissions from waste handling, notwithstanding the Army's optimistic
EPA recently fined the Army for release of chemical warfare agents into the environment.
Army spokespersons recently confirmed that the Army either does not know or has not
released a full accounting of all incidents during which live nerve agent was released from
the experimental incineration facility at JACADS. The Army has asserted that the releases
of nerve agent to the environment have occurred "only" three times at JA but Robert Perry,
head of safety for the Army's chemical weapons destruction program acknowledges that
other agent releases have occurred at JA (deposition, 1996).
At JACADS, active agent GB escaped from the LIC into corridors routinely used by
workers on fifteen to seventeen occasions. Also on fifteen occasions, agent GB was
detected in the life support air system (Menke et al., 1991). Apart from the admitted
releases of live nerve agent thus far, there have been a considerably greater number of
unexplained incidents in which monitors and alarms indicated release of agent.
The Anniston RA estimates the following emission rates and RfDs for chemical agents.
1.7665 E-06 g/s emissions,
RfD = 4.3 E-05 mg/kg-bw/day equivalently, emissions = 152,625,600 ng/day,
RfD = 43 ng/kg-bw/day # potential toxic doses emitted = 59,157
(assuming 60 kg adult)
2.0 E-04 g/s emissions,
RfD not reported
2.0 E-06 g/s emissions,
RfD = 4.3 E-05 mg/kg-bw/day equivalently, emissions = 172,800,000 ng/day,
RfD = 43 ng/kg-bw/day # potential toxic doses emitted = 66,976
(assuming 60 kg adult)
Total # potential toxic doses of GB and VX emitted = 126,133
This 126,133 number of potential toxic doses of agent emitted is unadjusted for non-
conservative assumptions in the Army estimates such as the complete absence of any upset
or emergency condition that would result in agent emissions exceeding the allowable stack
concentration theoretically ensured by the Army agent monitoring systems. A more
realistic assumption would be to apply EPA's default upset assumptions to agent emissions
as well as to PIC and dioxin emissions. This would result in increasing the emissions
estimates for agents by a factor of about 4. On this assumption, GreenLaw would estimate
the number of potential toxic doses of agents GB and VX emitted from Anniston to be
504,534. For Tooele, the estimate of number of potential toxic doses of agent emitted
would be 504,534 x 43/7 = 3,099,286. For the entire Army chemical weapons
incineration program, the estimated number of toxic doses of agent emitted would be
greater still by a factor of 100/43, or 7,207,642 toxic doses of agent released.
Rather than use a hazard index standard of .25 for the acute exposure risk assessment, as
was done for the Army's chronic exposure risk assessment, the Army adopts a less
conservative 1.0 standard for the hazard index in the Anniston RA when addressing acute
exposures (p.74). The Army estimates acute hazard indices, based on their emissions
estimates and exposure assumptions, of .1 for residents for HD/HT agent emissions from
each of the five ANCDF combustion units at Anniston (2 LICs, DFS, MPF and DUN), .5
for an on-site worker for toxic metal emissions from the CMDFS, .8 for an on-site worker
for HD/HT agent emissions from the DUN, and .9 for an on-site worker for HD/HT
emissions from each of the following ANCDF facilities: the 2 LICs, the DFS, and the MPF
(RA, p.97). The hazard indices calculated by the Army for acute exposure in the range of
.5 - .9 are particularly disturbing, and not just because they exceed the .25 standard used
for chronic exposure non-cancer risk assessment.
Perhaps one could, although GreenLaw would not, overlook the willingness of the Army
to ignore the threat to their workers that exists from the potential for simultaneous upset at
one of the other incinerators in the county such as the large Aptus hazardous waste
incinerator, which is not accounted for by the Army adopting a 1.0 hazard index standard
rather than the .25 standard used in the chronic exposure analysis. However, what is
impossible to overlook is the reckless assumptions used by the Army in calculating the
hazard indices themselves, many of which are already dangerously close to the Army's
non-conservative 1.0 standard. Those recklessly optimistic assumptions are:
1) that none of the five combustion units (the 2 LICs, the MPF, the DFS and the
DUN) would operate in the poor operating condition upset mode at the same
time, notwithstanding that there are five units each of which is assumed by
the Army and EPA to be in poor operating condition upset mode 20% of the
time; and
2) that none of the five combustion units at any time will ever be in "emergency
operating condition" upset mode (Anniston RA1994, pp. 42-43, 63).
These are not merely extremely non-conservative assumptions by the agency responsible
for handling chemical weapons and their disposal, they are serious misrepresentations that
alter the outcome of the risk assessment.
These factual misrepresentations, when corrected, reveal a clear, unacceptable risk to
workers, workers who do not lose their status as protected members of the public simply
because they took a job with the Army. Workers are not expendable commodities: they are
human beings no less than the residents and no less than the risk assessors and managers
making the decisions in the Army program. The central purpose of the Army's chemical
weapons disposal program is to prevent people from being harmed by exposure to a release
of chemical nerve or blister agent from the Army stockpile. This purpose is defeated by the
Army incineration program, as this risk assessment makes clear.
Consider first the assumption that none of the five combustion units will operate
simultaneously with any other in poor operating condition upset mode. As a matter of
simple mathematics, how can this be? The Army, pursuant to EPA guidance, assumes that
this poor operating condition upset mode will be experienced at each of the five combustion
facilities 20% or 1/5 of the time. Five units each operating in upset mode 1/5 of the time,
but somehow their upsets never overlap in time. Given that five units are each in upset 1/5
of the time, this would mean that to avoid overlap in upsets one and only one unit would
have to be in upset at any given moment, that is constantly, and the upsets occurring in
each of the five units would have to be perfectly orchestrated so that one stopped when
another started and vice versa. That is, the upsets would have to not be upsets but be
planned and controlled events. This is, in a word, ridiculous.
If the upsets are treated as true upsets, that is, unintended periods of poor operating
conditions resulting from malfunction, error, lightning or other such unpredictable events,
consistent with EPA guidance, then the probability of overlapping upsets would not be
zero, as the Army so disingenuously assumes. In fact, over a six-year period this overlap
of upsets in two or more of the five combustion units would be expected to occur hundreds
of times.
The Army's assumption that each of these overlapping upset events has a zero probability
of occurring because the pollution control devices on each of the five combustion units are
independent of each other, and thus, the Army implies, that an upset in one unit will not
trigger an upset in another, is mathematical and scientific nonsense. The Army may be
right that an upset in one unit will not trigger or cause an upset in another unit, putting aside
for the moment the unaddressed potential for a common external or internal event to cause
an upset simultaneously in more than one unit (power failure, lightning, hurricane,
munitions explosions, runaway rockets etc.). But causation is not the only phenomena that
can account for simultaneous occurrence.
Coincidence, that is the simultaneous occurrence of independent events, each having its
own distinct probability of occurring, is a well studied and analyzed aspect of the topic of
probability in the field of mathematics. The probabilities of the overlapping upset events
referenced above based on the assumption of independence of the upset events at the
various combustion units is substantial.
Given that there is, in fact, a significant likelihood that simultaneous upsets will occur, how
significant is this in regards to the Army's conclusion that the acute health risk is acceptable
based on a calculated hazard index of .8 or .9 for the various ANCDF combustion facilities?
Remember that these hazard indices for workers were based on the assumption of no overlapping
poor operating condition upsets. The short answer is that, in regard to HD/HT acute exposure,
while the Anniston Assessment is somewhat obtuse in providing the specific numbers required,
the occurrence of simultaneous poor operating condition upsets among two or more units will
almost certainly result in the previously estimated 0.9 hazard index exceeding the 1.0 Army risk
standard. This is true even accepting the Army's optimistic assumption that upset emissions
in regards to agent simply means emissions at the allowable stack concentration which the agent
monitoring system was designed to maintain.
If the monitoring system is not as infallible as the Army would have us believe, and EPA's
assumption of 10 times greater emissions during poor operating condition upset mode
which occurs 20% of the time applies to agent emissions as well as PIC emissions, then the
acute hazard index would be even higher, considerably above the 1.0 standard. Thus,
using the Army's chosen risk methodology, one must conclude that the incineration
program at Anniston, which handles only 7% of the stockpile compared to Tooele's 43%,
presents an unacceptable acute health risk from agent exposure.
This discussion concerning the Army's analysis of acute exposure to emission of nerve and
blister agent began with the identification of two recklessly optimistic assumptions made by
the Army, the first of which was just addressed. In addition to the assumption that none of
the five ANCDF combustion units would operate in the poor operating condition upset
mode at the same time , the Army also assumed that none of the five combustion units
at any time will ever be in "emergency operating condition" upset mode (Anniston RA, pp.
42-43, 63). This second Army assumption is also completely unjustified.
As explained supra, in the discussion of dioxin non-cancer risk from chronic exposure, the
Army assumption that emergency operating conditions will never occur at any of the
ANCDF units anytime is unrealistic and inconsistent with the experience at JACADS and
numerous other hazardous waste incinerators. The more realistic and conservative
assumption of occasional emergency operating condition upsets results in adjustment of
emissions estimates for acute exposure analysis to be 100 times greater than normal, which
will cause the calculated hazard index to clearly exceed the 1.0 standard.
The Utah DEQ and apparently the Oregon DEQ have chosen to omit any analysis of this
acute agent exposure and have thus avoided the awkward calculations of risk from
simultaneous upsets explained above. Someone should ask both DEQs to explain this
The Army places heavy reliance on the virtual infallibility of its agent air monitoring
systems to ensure no or minimal release of agents via fugitive and stack emissions
(Anniston RA, p. 43). History has shown that such complete reliance on any human made
technology is misplaced. The confirmed JACADS releases of agent and the numerous
unexplained air monitoring system alarms at JACADS do not inspire confidence in the
Army's optimistic assumptions about the performance of its air monitoring systems. While
acknowledging that the Anniston design is based on JACADS, (Anniston RA, p. 8) the
Army makes no attempt to assess the JACADS experience of releases and alarms in the
Anniston RA but addresses the issue of agent releases as if oblivious to the fact that
releases and alarms have occurred. Similarly ostrich-like is the Army's failure to note the
issues raised in the testimony of former chief safety officer Steve Jones regarding numerous
safety violations at Tooele that might affect agent release. These issues should be fully explored
in the Army risk assessments.
The Army relies on activated carbon filters to contain releases of agent but the Anniston RA
does not address the ultimate fate of the agent captured in the activated carbon filters. If the
carbon filters are ultimately incinerated or otherwise treated or disposed of, the potential
exists for some of this agent to be released at this later point. The Anniston RA should not
treat agent captured in the carbon filters as if it had magically disappeared without a trace
and without the potential for future release. A chemical poison captured by pollution
control devices has not been destroyed and still poses a threat.
The Anniston RA notes that numerous degradation and decomposition by-products of
chemical agents exist, including 53 with "no known toxicological information" (p. 71).
The RA further notes that "substances with no toxicity values were excluded from the SRA
[screening risk assessment]" (p. 71). The RA also notes that additional substances were
excluded "which cannot be stack sampled" (p. 71). These exclusions create considerable
uncertainty in the risk estimate and likely result in a significant underestimate of risk.
The Release into the Environment of Toxic and
Bioaccumulative Metals from the Incineration of
Chemical Weapons Poses an Unacceptable Risk to
Public Health and the Environment
The Army estimates that inhalation of chromium emitted from the CMDFS poses a chronic
exposure cancer risk to the adult resident of approximately 3.244 per million, considering
poor operating condition upsets but assuming no emergency condition upsets such as
pollution control failure (Anniston RA, p. 94). Adjusting this estimate to include emissions
during emergency conditions occurring 1% of the time, the estimate would approximately
double to approximately 6.45 per million for inhalation alone of chromium alone. If the
risk standard against which this risk is judged is not the 10 per million 70 year lifetime risk
standard but a more appropriate standard, as explained supra, for the shorter 34 year
operational period of CMDFS, that is a standard of 10 x 34/70 = 4.86, then the chromium
inhalation exposure alone poses an unacceptable risk.
The Army's failure to include emergency operating conditions in the acute exposure
analysis also affects the outcome of the risk assessment in regards to the toxic metal silver.
The Army estimates a hazard index for CMDFS silver emissions exposure to an on-site
worker as .5, apparently assuming poor operating condition upset mode (but no overlap in
upsets) but without any consideration of emergency operating conditions. Assuming
emergency conditions upset would increase silver emissions at least by a factor of 10 and
increase the hazard index to 5.0 or more, greatly exceeding the standard of 1.0.
The Release into the Environment of Toxic Nerve
Agent-like Combustion By-products from Chemical
Weapons Incineration Poses a Significant but
Unknown Threat to Public Health and the
The combustion by-products of the incineration of nerve agent have yet to be fully
identified. However, hundreds of organic chemicals would be expected to result from the
incineration of nerve agent and chemical weapons consistent with EPA findings from
hazardous waste incineration tests. It is expected that combustion by-products from the
incineration of one particular chemical would lead to emission of closely related chemicals
as combustion by-products. This has been the case for incineration of hazardous waste in
general. For example, incineration of polychlorinated biphenyls (PCBs) leads to the
emission of polychlorinated dibenzo-furans, a very closely related chemical in terms of
structure and composition. PCB fires leads to creation of both furans and polychlorinated
biphenylenes, another closely related chemical. The incineration of dioxin also leads to
formation of dioxin as a combustion byproduct. Thus to some extent, an extent currently
unknown, the incineration of chemical weapons and nerve agents would be expected to
lead to the creation as combustion by-products of closely related chemicals that may be less
or more potent poisons than the original agents but dangerous nonetheless. In the absence
of thorough stack testing to fully characterize the emissions from chemical weapons
incineration, it is not conservative nor even reasonable to assume the PICs emitted contain
no agent-like substances.
Using the Army's and EPA's chosen methods of risk assessment and standards of
unacceptable risk, the scientific evidence supports the conclusion, considering just those
chemicals and routes of exposure that have been addressed quantitatively by the Army, that
the Army chemical weapons incineration program is an unacceptable risk. The Army
assessment also fails to quantify risk posed by several chemicals of concern via several
routes of exposure, including the mother's milk route for dioxin and including degradation
by-products of nerve agents which would otherwise make the Army risk effort essentially
useless for decision purposes. Had the Army reported the uncertainty in their risk estimate
quantitatively, as a range of potential risk, the upper end of that risk range would have been
beyond any conceivable standard of acceptable risk by orders of magnitude.
|Anniston Chemical Disposal Facility
|Agency for Toxic Substances and Disease Registry
|conventional munitions combustor
|Chemical Weapons Working Group
|Department of Environmental Quality
|deactivation furnace
|Department of Defense
|Environmental Impact Statement
|Environmental Protection Agency
|grams per second
|Health Risk Assessment
|Johnston Atoll
|Johnston Atoll Chemical Agent Demilitarization System
|liquid incinerator
|metal parts furnace
|minimal risk level
|National Environmental Protection Act
|National Research Council
|Occupational Safety and Health Administration
|polychlorinated biphenyl
|picogram per kilogram of body weight per day
|products of incomplete combustion
|virtually safe dose or reference dose
|slope factor
|dioxin cancer potency
|substance of potential concern
|screening risk assessment
|toxic equivalent quotient
DeVito, Michael J, Birnbaum, Linda S., Farland, William H. & Gasiewicz, Thomas A.
(1995, September). Comparisons of estimated human body burderns of dioxinlike
chemicals and TCDD body burdens in experimentally exposed animals.
Environmental Health Perspectives, 103(9).
Kearney, A. T., Inc. (1996, February). Screening risk assessment: Tooele Chemical
Demilitarization Facility, Tooele Army Depot South.EPA I.D. No.
UT5210090002. Salt Lake City, UT: State of Utah Department of Environmental
Quality, Division of Solid and Hazardous Waste.
Menke, J. S., Carlson, H. M., Flinn, M. H., MacRae, S. R., Medville, D. M. & Tripler,
D. J. (1991, June). Evaluation of the GB Rocket Campaign: Johnston Atoll
Chemical Agent Disposal System Operational Verification Testing.MTR-
91W00039. McLean, VA: Mitre Corp.
Perry, Robert. (1996, July). Deposition taken for Preliminary Injunction Hearing, US
District Court, District of Utah, Central Division. Chemical Weapons Working
Group, Sierra Club & Vietnam Veterans of America Foundation v. US Department
of the Army, US Department of Defense & EG&G Defense Material, Inc. Case
No. 2:96-CV-425(TC).
Raytheon Engineers & Constructors, Inc. (1996, May 28). Johnston Atoll Chemical
Agent Disposal System (JACADS): Human health & ecological risk assessment.
Draft. Aberdeen Proving Ground, MD: Commander, US Army Chemical
Demilitarization and Remediation Activity.
Science Applications International Corp. (1996, January). Draft Tooele Chemical Agent
Disposal Facility quantitative risk assessment.SAIC-96/2600. Edgewood, MD:
US Army Program Manager for Chemical Demilitarization.
US Department of the Army, Center for Health Promotion and Preventive Medicine.
(1995, March 27). Final screening risk assessment, RCRA Part B, Anniston
Chemical Demilitarization Facillity, Anniston Army Depot, Anniston, Alabama.
No. 39-26-1399-95. Aberdeen Proving Ground, MD: Commander, US Army
Chemical Demilitarization and Remediation Activity.
US Department of the Army. (1995, December). Disposal of chemical agents and
munitions stored at Umatilla Depot Activity, Oregon: Revised draft Environmental
Impact Statement. Aberdeen Proving Ground, MD: Program Manager for
Chemical Demilitarization
US Environmental Protection Agency. (1994, June & August). Health assessment
document for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and related compounds
(Vol. I, II, & III). EPA/600/BP-92/001c, External review draft. Washington, DC:
Office of Research and Development.
US National Research Council. (1994). Evaluation of the Johnston Atoll Chemical Agent
Disposal System Operational Verification Testing.Washington, DC: National
Academy Press.
CWWG Home Page
Contact us:
Chemical Weapons Working Group
Kentucky Environmental Foundation
P.O. Box 467
Berea, KY 40403
phone: 859-986-7565
fax: 859-986-2695
For comments about this WWW page contact Lois Kleffman.


text:
Reporting inappropriate content
You can use this form to report the content shown below as inappropriate.
If you disagree with a story or a comment please post your own view directly on the piece itself rather than making a complaint.
Please provide full contact details with your complaint, so we can reply or contact you for more details.
I want to complain about this content:
Very interesting and certainly would be a much more positive signing. Sporting Lisbon are pretty poor at present and he appears the only real goalscorer for them. Apparently the usual suspects are looking at him as well. OTBC
Friday, January 25, 2013

subset: commoncrawl


text:
Right now on Amazon, find huge savings on Juniors and Women's dresses for Spring, as low as $6.70 + FREE Prime Shipping!
Several really cute dresses are only $11.70 (Reg $40 – $50). Choose from brands like Hurley, O'Neill, Volcom and Fox for under $15.
If you change the price settings in the left hand sidebar, to include pricier dresses, you'll get results including dresses from Nine West, Anne Klein and more!
Please note that Amazon's prices fluctuate and can change at any time. Be sure to verify current price before placing your order. Find more great Amazon Deals in ourAmazon Category!


text:
I've seen the threads, from years ago with "We've started taking donations" and "we need to sell ads" and etc.
I actually think the way it's all handled here is fairly tasteful... I barely notice the ads, and there's nothing screaming "GIVE ME UR MONIES" which is great...
but there also isn't much information on how it all works, and since I'm nosy, I thought I'd ask!
I have lots of questions... stuff that's usually screamed at you on other sites, but I can't seem to find the answers here.
1) The amount needed for the year in the banner on the front page:
Is that what the site needs to run for a year in total, or the cost of running the site AFTER the ad revenue?
If the former, does the "amount received" include ad revenues?
2) What options are there for donating? All I see when I click the donate link is a link to PayPal, and I don't (and probably never will) have a paypal account. Is there still a way for me to donate to the upkeep of the site? One of the old threads said something about exploring other options, but nothing was ever said about it after that?
3) The "gracious donor" bar under avatar.. is that for any donations? or just a certain amount? or for yearly contributers? Curious D:
4) Does donating affect the number/type of ads on the page?
5) Does the site get paid "per click" on the ads, or a flat rate for the space?
6) Does anyone other than the site... owner? Administrator? have access to the payment information? Cause we had a guy leave another site once a few years back in a rage and pretty much take everything x.x so yeh.. what level of privacy when donating?
None of this is really a big deal, I guess, but I like to know details before I open my purse


text:
Silent Hunter: Wolves of the Pacific (PC)
Reviewed by: Wollf
Reviewed on: July 1, 2007
: Ubisoft
: Ubisoft
Price: $49.99 USD
Silent Hunter: Wolves of the Pacific, is the 4th title in a series of games where you get to take control of a submarine at the beginning of World War II. You start out in Pearl Harbor, fresh after the attack where almost everything is destroyed. Luckily, however, the Japanese somehow missed out on the subs, so it is up to you to start fighting for your country and pick up a career in the Navy! This excellent simulation allows you to take control of all aspects of your sub, including firing the main deck gun, or shooting down enemy aircraft trying to blow you back under the water. There are some choices to make for your realism settings and if you haven't played a game like this before, you might want to set them a little on the lower end until you can get the hang of it.
Closer Look:
Jumping into the game like I often do, I installed it and put the manual to the side (it is a nice thick one, so I figured I would probably need it soon). I jumped right into a mission and promptly got destroyed. Okay, maybe I jumped in a little too quick. This time around I decided to try out the training missions; everyone could use a little help, right? So I went through the five training sessions:
- Navigation Training ... Follow a course to a destination; fairly simple once you master your compass settings.
- Gunnery Training ... Use your AA gun and shoot down a plane...not tough and very nice explosions
- Torpedo Training ... A fairly simple shot with your torpedo, taking out an enemy cruiser that doesn't fight back very well.
- Sonar and Radar Training ... Pretty self-explanatory; use the sonar and radar and you're done
- Convoy Attack Training ... The most fun of the training missions; use all that you have learned to sneak up on a convoy, take out their defenses, and then take your time blowing very large holes through the nice slow moving targets, watching them slowly meet Davey Jones.
After running yourself through the training sessions and getting a small taste of how to control your sub and some of the more detailed workings of the ship, you can either jump into a nice career or pick up one of the quicker "Quick Missions."
Closer Look (continued):
I decided to start out my career as a ship commander. Looking around my office I see the usual items, as well as a steaming cup of coffee on the desk. There are books for saved games, a Captain's log book to keep track of victories, and a nice wooden box to hold future medals. By clicking on the large map on the wall, you get your first assignment, spy duty. You might think spy duty sounds a little dull, but in Silent Hunter, they don't care how many boats you sink on your way in, or even on your way out. My first thought was to take out everything on the way in and snap a few pictures end of mission. However, they don't end the mission until you are home; something I didn't count on, as I was sneaking around search party after search party that were looking for me on my way out.
The graphic realism in Silent Hunter is some of the best I have seen to date. Surfacing your sub in a storm cause waves to pour (yes, pour) over the deck. The water glistens in the sun and shimmers in the moonlight. Put up the periscope when you're a little deeper than periscope depth, and you can actually watch the waves flow over your lense, then they slowly pour down as it clears again. Take out a fishing boat with your deck gun and watch as flames spread and engulf the whole ship. People on the decks of enemy boats will duck as you fire on them or fall over dead with the explosions rattling their boat. Blow a hole in their bow big enough to drive your sub through and, as the boat starts to sink Titanic-style, you can watch the commanders scramble for a life raft. Score a direct hit and you may be graced with a gigantic explosion that fills your screen from the destroyer you just took out. Shoot the tail off a bomber flying overhead and watch the plane spin out of control with all the glorious flaming wreckage. If you're like me, you'll look for new ways to take out every single enemy, just so you can see what new graphical animation occurs.
Once back in your base for a refit after you have completed a mission, you have a few options:
- Upgrade weapons and/or move them around if you have enough points from sinking ships.
- Replace or move crewmen, if you sadly had a few lives lost. Your crew gets faster and more efficient the longer they are under your command, so avoid this if you can.
- Refill torpedo bays (this is not automatic, as I found out the hard way, heading out on my next mission with no torpedos).
Closer Look (Quick Missions):
Quick Missions are exactly that; quick. Hop in, find your target(s), and start the action. This is a much more ideal option for the person who just wants to get in there and do some damage, without all the hassle of travel times or reloading at docking stations. For the casual player, I recommend this option whole heartedly; it's a great way to get that little destruction fix we all need now and again.
Once you're ready and refit your boat, you're off on the next leg of your mission, whatever it may be. So let's take a look at some of the things that didn't seem to work.
First and foremost, was the time compression. Without it, you would be in for a very long trip. To get from Pearl Harbor to Japan in a sub would take days, at least, and there is no fun in that. To alleviate those long trips, you can hit the compression button. Sounds great, right? Yes and no. To take advantage of the fastest compression (8142x), you have to expand your map out (really far out) and that is like looking at a world map. Not a big deal, except that this is a very realistic game, and as such, that means there are small islands everywhere that you can't see when you are that far out. So you're flying along heading to Japan and all off a sudden your crew starts screaming; hull breached, tubes damaged, batteries destroyed. Then, you sink; no warnings. So you brush it off and figure you have to pay a little closer attention next time. So you try to zoom in a little bit, and you either can't keep up on the map due to the speed of your ship with the time compression, or you actually zoom too close and the compression wont let you go past 32x, at which point it will take hours to get anywhere. It is very hard to find a happy medium. I learned to find a clear course and not change it unless I was planning to slow right down to close to normal time.
Second thing that bothered me was the large map. When you are traveling the long road home or to your destination, you see a map of the Pacific and a small dot representing your sub. It's not very interesting or graphically intense, yes this was the laggiest part of the game. I quickly learned to not move my mouse off the directional compass and use the keyboard's + and - keys for the time compression, otherwise I wouldn't be able to react fast enough when needed. Ubisoft seems to have tried to fix the problems of smashing into enemy ships or missing something important you might want to sink with an automatic knockdown to 1x speed every time there is a ship, plane, or tanker near by. Heck, sometimes I wondered if even the birds were slowing me down. Try to get out of an enemy port using time compression and you will be hitting + for a long time to speed yourself up again and again. It becomes mildly frustrating very often, leading to a need to use every last bullet to try and take out the search planes, even when you know you don't have enough, just to stop them from slowing down your compression. Some kind of filtering system would be very handy in this area to help speed up your travels.
Last, but not least, is the load times. This is downright agonizing. Sometimes it takes as long as a minute as you sit there staring at the the load bar crawl along the screen. When it finally reaches the end, you think yourself "Yay!" only to see the next screen that says, "Please wait." Do we really need two load screens? Unfortunately, get used to those load screens, because I recommend saving often, especially before you think you might be making a mistake, like wondering if your deck gun can take out that gunship in the distance. Save, but pray you don't have to load it.
System Requirements:
- Windows XP / Vista only
- Processor: 2 GHz Pentium 4 or AMD Athlon
- Video Card: 128MB, DirectX 9.0c compatible video card capable of rendering Pixel Shader 2.0
- Sound Card: DirectX 9.0c compatible
- DirectX Version: DirectX 9.0c included
- Multiplayer: Local area network (LAN) and/or 128kbit Cable/DSL
- Rated: ESRB: Teen Mild Violence
My System Specs:
- AMD Athlon 64 Processor 3500+
- 2GB Ram
- 120GB Hard Drive
- nVidia GeForce 6800
- 350 Watt PSU
- WinXP Pro Service Pack 2
Silent Hunter 4 is an excellent game that looks like it got rushed to release just a little too fast. It has fluid gameplay when you can get to the dirty stuff, and the graphics are very well done, even though you cant get higher than 1024 x 768. The first day I installed it, I found myself in front of my monitor sinking enemy ships for hours at a time, watching them slowly sink away, still trying to shoot at you, even though their guns were pointing to the sky. Or I'd sit there watching them blowing up and sinking in pieces so fast, it was sometimes hard to even get a screenshot. Often I would even watch so long, I would forget to look behind me and get sunk myself by a remaining enemy ship. All in all, I would rate this game high on the to-buy list. Patch it first before playing and hope they have another patch soon to take care of the loose ends.
- Amazing environment and effects
- Realistic movements and controls
- Multiplayer options
- Simple method to control realism
- Stuff blows up! What else can you ask for?
- Time compression is too buggy
- Framerates and lag at high compression get old
- No control to filter some content
- Load times are very long, and there are 2 screens!


text:
Model: Samsung SSD 830 Series 128GB Solid State Drive
Manufacturer: Samsung Electronics
Provided By: Samsung America
Samsung Electronics has been a leader in the electronics industry for more than 30 years. Since the introduction of their first television in 1970, this Korean company has grown to become one of the world's leading electronics manufacturers, offering everything from tiny semiconductors to large home appliances. Samsung is no stranger to the storage industry either. Along with an assortment of DVD and Blu-ray Disc drives, the company offers both hard drive and flash based storage solutions for the portable and desktop computer markets
Like many other manufacturers, Samsung has set its sights on the growing solid-state drive (SSD) market. This past fall, the company launched its SSD 830 Series. Designed and built completely in-house, the SSD 830 is powered by Samsung's own triple-core MCX controller and features a SATA 6GB/s interface as well as wear-leveling and garbage collection algorithms for sustained performance and reliability. The 830 Series also packs 256MB of on-board cache and uses Samsung's 20nm-class Toggle DDR NAND flash memory to deliver up to 520MB/s read and 400MB/s write speeds.
The 830 Series is available by itself or as part of a user-friendly installation kit. For this review, Samsung sent us the 128GB desktop installation kit (MZ-7PC128D/AM). The 128GB version of the SSD 830 is capable of delivering up to 520 MB/s sequential read and 320 MB/s sequential write speeds as well as up to 30,000 random read and 80,000 random write IOPS.
|Samsung SSD 830 Series 128GB Solid State Drive
|General Specifications
Power Consumption
Dimensions and Weight
Other Features
Needless to say, this is only a taste of what the 830 Series has to offer. To give you an idea of what to expect, we'll take a closer look at Samsung's latest 128GB SSD and then see how well it performs. Does the SSD 830 have what it takes? Can it deliver the performance and features that we've come to expect from Samsung? Keep reading as we find out.
- OCZ Vertex 3 3.5" 120GB Solid State Drive
- Kingston SSDNow V+200 90GB Solid State Drive
- Plextor PX-256M3P 256GB Solid State Drive
- OCZ RevoDrive 3 120GB PCIe Solid State Drive
- SanDisk Extreme 240GB Solid State Drive
- Silicon Power Velox Series V30 120GB Solid State Drive
- OCZ Synapse Cache 64GB Solid State Drive
- Silicon Power 750GB Stream S10 USB 3.0 Portable Hard Drive
- Plextor PX-256M3S 256GB Solid State Drive
- Patriot Pyro SE 240GB Solid State Drive


text:
Dutton-Lainson SAE Class 1, 1-7/8-in Ball Size, 2-in Housing Width
$24.99 $14.99 You Save $10.00 or 40%
Item # 2034654
|Eligible for Free Shipping on Orders $39 or More! (see promotion details)
|Members of The League get 5% back when you spend $100! (see promotion details)
Product Details
The Dutton Laison® coupler is designed with a "Quick-Lock" ball clamp assembly that can be adjusted without the need of wrenches. The trigger-action release on the ball clamp assembly allows fast locking and unlocking of the ball clamp for convenient hitching.
- "Quick-Lock" ball clamp assembly
- Trigger-action release on the ball clamp assembly
- Safety lever snaps shut and cannot unlatch by itself
- Coupler housing meets all requirements of the SAE standards for Class 1, 2 and 3 couplers in the size required


text:
- Inhabitat – Green Design, Innovation, Architecture, Green Building - http://inhabitat.com -
THE MAGLEV: The Super-powered Magnetic Wind Turbine
Posted By Mahesh Basantani On November 26, 2007 @ 12:00 pm In Environment,Renewable Energy,Wind Power | 149 Comments
Renewable energy produced from the wind has garnered much attention and support in recent years but is often criticized for its low output and lack of reliability. But now a super power wind turbine has come along that may be just what the renewable energy industry needs. The MagLev [2] wind turbine, which was first unveiled at the Wind Power Asia [3] exhibition in Beijing, is expected take wind power technology to the next level with magnetic levitation.
Magnetic levitation is an extremely efficient system for wind energy. Here's how it works: the vertically oriented blades of the wind turbine are suspended in the air above the base of the machine, replacing the need for ball bearings. The turbine uses "full-permanent" magnets, not electromagnets — therefore, it does not require electricty to run. The full-permanent magnet system employs neodymium ("rare earth") magnets and there is no energy loss through friction. This also helps reduce maintenance costs and increases the lifespan of the generator.
Maglev wind turbines have several advantages over conventional wind turbines. For instance, they're able to use winds with starting speeds as low as 1.5 meters per second (m/s). Also, they could operate in winds exceeding 40 m/s. Currently, the largest conventional wind turbines in the world produce only five megawatts of power. However, one large maglev wind turbine could generate one gigawatt of clean power, enough to supply energy to 750,000 homes. It would also increase generation capacity by 20% over conventional wind turbines and decrease operational costs by 50%. If that isn't enough, the maglev wind turbines will be operational for about 500 years!
Construction began on the world's largest production site for maglev wind turbines in central China on November 5, 2007. Zhongke Hengyuan Energy Technology has invested 400 million yuan in building this facility, which will produce maglev wind turbines with capacities ranging from 400 to 5,000 Watts. In the US, Arizona-based MagLev Wind Turbine Technologies will be manufacturing these turbines. Headed by long-time renewable energy researcher Ed Mazur, the company claims that it will be able to deliver clean power for less than one cent per kilowatt hour with this new technology. It also points out that building a single giant maglev wind turbine would reduce construction and maintenance costs and require much less land than hundreds of conventional turbines. The estimated cost of building this colossal structure is $53 million.
Article printed from Inhabitat – Green Design, Innovation, Architecture, Green Building: http://inhabitat.com
URL to article: http://inhabitat.com/super-powered-magnetic-wind-turbine-maglev/
URLs in this post:
[1] Image: http://www.inhabitat.com/2007/11/26/super-powered-magnetic-wind-turbine-maglev/
[2] MagLev: http://magturbine.com/
[3] Wind Power Asia: http://www.windpowerasia.com/
Click here to print.
Copyright © 2011 Inhabitat Local - New York. All rights reserved.


text:
Chipotle is putting the "boo" in "boorito" this Sunday, October 31st. Just come in dressed as a processed food product and you can get a burrito, bowl, salad or tacos for just $2. Proceeds up to $1 million go to raise awareness for healthier eating.
Kids eat free at Qdoba from Friday, October 29th through Halloween. That's one free kids meal for every adult entree purchased.
Your children under the age of 12 can receive a free Scary Face Pancake on Friday, October 29th at participating I-Hops. Your children can even decorate the pancakes themselves.
And if you act fast, you can receive a free Chick-Fil-A breakfast on Friday morning, October 29th, at the Garden of the Gods location in Colorado Springs. You must become a Facebook fan of that location to receive it.
Please remember, all offers are subject to availability and product providers may end these offers at any time. Not all locations participate in all offers.
Sign up for our free E-Newsletter. We'll send deals like these to your in-box every week. Click Here To Sign Up For The Here's The Deal E-News Letter
KKTV firmly believes in freedom of speech for all and we are happy to provide this forum for the community to share opinions and facts. We ask that commenters keep it clean, keep it truthful, stay on topic and be responsible. Comments left here do not necessarily represent the viewpoint of KKTV 11 News.
If you believe that any of the comments on our site are inappropriate or offensive, please tell us by clicking "Report Abuse" and answering the questions that follow. We will review any reported comments promptly.powered by Disqus


text:
Revision as of 05:59, October 27, 2010 by Biggest gta fan ever (Talk | contribs)
| User:Jay phillips
Hi, welcome to GTA Wiki! Thanks for your edit to the User:Jay phillips page.
Please leave a message on my talk page if I can help with anything! -- ZS (Talk) 06:34, March 18, 2010


text:
KCG : Analysis & Opinions
Up/DowngradesNovember 26, 2012New York, November 26th (TradersHuddle.com) – Following are some of the upgrades and downgrades before the market open. Aeropostale ...
Knight Capital Lives To Fight Another DayAugust 8, 2012Knight took a tough deal to stay in business.
Short Interest Falls, But Not For EveryoneJuly 14, 2010Investors have reduced overall short positions slightly over the last two weeks, but several major stocks saw large increases ...
The Stock Market According To GARPJune 3, 2010With analysts predicting a sideways market for the next few months, investors may want to try their hands at GARP investing.
Trading Center


text:
Rock Climbing Photos : Comments
Hard alpine recovery
This is what I look like after a hard alpine climb. Or an evening of debauchery whose specifics still elude me. Please stop blinking so loud.Rating: | Votes: 2 | Comments: 4
Submitted by: petsfed on 2004-12-14 | Last Modified: 2007-05-02 | Views: 1803
You're a brave man, petsfed ;)
ahhh evenings of debauchery rock... drinking...strip clubs... : )
good god man!
go golom legs go!


text: WASHINGTON - JANUARY 20: U.S. President Barack Obama (L) kisses first lady Michelle Obama (C) as daughter Malia looks on in the Blue Room of the White House January 20, 2013 in Washington, DC. Obama and U.S. Vice President Joe Biden were officially sworn in a day before the ceremonial inaugural swearing-in. (Photo by Larry Downing-Pool/Getty Images)


text:
I was trying to connect my bluetooth headset to my laptop so that I can play music from the build-in speaker and play skype chat from the headset and it won't interfere each other. However, I wasn't able to achieve this goal.
I have a Lenovo W530, running Windows 7 64-bit. I have run Windows update so I believe the drivers are the most current.
When I try to connect my bluetooth headset, my laptop was able to pair with the headset, but it was not able to connect. When I click on the bluetooth icon in the tray, "Allow a Device to Connect" is greyed out and I can't click on it.
I go into Control Panel > Hardware and Sound > Sound, my headset show up in the list of devices, but it is also greyed out and show "disconnect", and I was not able to connect from there either.
Is there a way I can solve this issue?
Or is there some other free bluetooth software that I can use?
I tried BlueSoliel, but I ran into couple issue with that too. The first time I was able to connect my headset and use it as desire, but when I restart the program (or restart the computer, I can't really remember), it starts failing. The program says that the headset is connected, but I can not play any sound through the headset, or use the mic on the headset, and my headset is not showing up in Hardware and Sound anymore.
Any help is appreciated!!


text:
Local Moving Services
Twins Moving & Storage Inc. takes great satisfaction in knowing that we've helped make your relocation process go as smoothly as possible.
While moving homes, lofts, apartments and providing moving supplies, we are here for you by being open every day, regardless of the weather, we're open! When you need a reliable local mover call the reliable local professionals.
We pride ourselves on the quality of services we provide as well as offering you state of the art moving equipment to accommodate your moving needs.
Local moves are conducted by the hour. This is to ensure that the required labor of our dispatched crew members will perform as needed. Local moves consist of a radius of 100 miles or less, with travel time always included with your estimate.
Local moves also consist of our crew members arriving and assessing your inventory. Then, we will commence to load boxes and smaller items to ensure they are packed onto our state of the art moving truck. Once this process has been completed, our skills movers will disassemble any basic furniture that needs to be taken apart and then we will wrap your items using padded relocation blankets, shrink wrap and other necessary wrapping materials.
Once all furniture has been disassembled and wrapped, we will load these items onto the moving truck and pack everything as required by the Department of Transportation and or its procedures.
Once we arrive at the final location, our movers will again conduct a walk-through with you to know where specific items shall be placed. We will unload all items including furniture and place as designated. Of course our movers will un-wrap your belongings and reassemble your items to its manufactured specifications in the rooms that you wish.
After all items have been unloaded, un-wrapped and reassembled in your home, then your move is complete.
As per policy, we always provide you with a written estimate regarding your relocation. Most estimates consist of the following:
1. Pick-up Location & Destination
2. Hourly Rate
3. Number of Hours to Completion
4. Travel / Distance Time
5. Crew Member Size
6. Truck Size
7. Full Packing Services (OPTIONAL)
8. Fuel, Mileage, Taxes, Carriers Liability Insurance ($0.60 per lbs per item)
9. Minimum Total Charge of Estimate.
Estimated Local Labor Hours
Please refer to the list below to determine how many hours it will take (estimated) to complete your local move:
|Type of Residence
|Assigned Crew Members
|Number of Hours/Complete
|Bachelor/Studio Apartment
|Not Required
|One Bedroom Apartment
|3 hours labor + travel time
|Two Bedroom Apartment
|4 hours labor + travel time
|Two Bedroom House
|5 hours labor + travel time
|Three Bedroom Apartment
|6 hours labor + travel time
|Three Bedroom House
|6 hours labor + travel time
|Four Bedroom /Five Bedroom
|8 hours labor + travel time
Twins Moving & Storage, Inc has configured this estimation based off previous experience while onsite and conducting local relocations in your area.
However, actual hours to complete your type of residence will be determined upon completion of your assignment.
Call 1-800-876-8393 today!!!