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HUMMA Questions and Answers

Q1. How long has chemical warfare material been in coastal waters?
Q2. Where are they nationwide?
Q3. What has been done to date in terms of locating and studying the disposal sites in Hawai‘i?
Q4. What do we know about the sites and the condition of munitions?
Q5. What risk do they pose to ocean recreation users? The food chain?
Q6. Will they be removed? If so, how?
Q7. How risky is removal?
Q8. If CWM was recovered, where would they then be disposed?
Q9. Does it make any sense to leave them in place? If so, why and for how long?
Q10. Why was UH selected to conduct this work?
Q11. What is UH’s responsibility?
Q12. What is Environet’s responsibility?
Q13. Where is the study site?
Q14. What is the purpose of the assessment?
Q15. Is it possible that the chemical munitions will not be found?
Q16. Why are there munitions in the ocean?
Q17. Did they know the contents would be released?
Q18. Are these items dangerous?
Q19. What is being done to mitigate the danger?
Q20. Is the study being conducted near where the three individuals were burned in 1976?
Q21. What are the clean up options?
Q22. How will the assessment be conducted?
Q23. When will survey results be available?
Q24. What types of recommendations will the report make?
Q25. Where are the other disposal sites in Hawai‘i?
Q26. How much control will DoD have over UH’s work?
Q27. What decisions will be made from the study effort?
Q28. Who will decide?

Q1. How long has chemical warfare material been in coastal waters?
Between 1919 and 1970, the Armed Services disposed of excess, obsolete or unserviceable conventional or chemical military munitions, and containers of bulk chemical agent in coastal waters of the United States. (Chemical munitions and bulk containers of chemical agent are collectively referred to as chemical warfare material or CWM.) Known sea-disposals of CWM occurred off O‘ahu between 1933 and 1946. While the Armed Services discontinued sea-disposal in 1970, it was not formally banned by Congress until 1972, with the passage of the Marine Protection, Research and Sanctuaries Act. Although the 1972 Act allows the Environmental Protection Agency to issue permits for disposal of certain types of waste, neither the DoD nor the Environmental Protection Agency knows of any permits issued under this Act for the disposal of conventional munitions or CWM. In 1975, the United States signed an international treaty, the “London Convention” prohibiting ocean disposal of chemical weapons. (Internationally, chemical weapons includes some delivery systems (e.g., missiles); chemical munitions; munitions designed for chemical warfare; chemical agents; and other material.)

Q2. Where are they nationwide?
The Armed Services conducted sea-disposal operations that involved U.S. and foreign CWM. The CWM was deposited in both U.S. coastal waters and off foreign shores (Congressional Research Service, 2007). The Department of Defense has identified 19 CWM sea-disposal sites in U.S. coastal waters (Defense Environmental Program, Annual Report to Congress Fiscal Year 2007). Known disposals in U.S. coastal waters occurred in the Atlantic and Pacific Oceans, the Gulf of Mexico, off the coasts of Hawai‘i and Alaska and two instances in the Mississippi River, near Louisiana.

Q3. What has been done to date in terms of locating and studying the disposal sites in Hawai‘i?
The Department of Defense (DoD) has been reviewing records including those in the National Archives for the past several years to locate disposal sites in U.S. coastal waters. In 2007 and 2008, DoD’s Defense Environmental Programs Annual Report to Congress included an appendix titled Sea-Disposal of Military Munitions (Appendix R in the Fiscal Year (FY) 2006 report, Appendix S in the FY 2007 report, and Appendix Q in the FY08 report). In 2007, this appendix provided DoD’s initial interim report on the sea-disposal of CWM in U.S. coastal waters. In 2008 and 2009, DoD provided updates of this information. The information provided included CWM sea-disposal locations in and around Hawai‘i. It also provided disposal locations, munitions types and quantities, and an estimate of the net chemical agent weight disposed of at each location. This report is available on the Defense Environmental Network & Information Exchange (DENIX) website at https://www.denix.osd.mil.

The Hawai‘i Undersea Military Munitions Assessment is the first study of a CWM site in Hawai‘i and will be the most comprehensive study ever done for any CWM site in U.S. waters. This study is expected to significantly expand knowledge of the condition of munitions on the seafloor and their effects, if any, on environmental quality.

Q4. What do we know about the sites and the condition of munitions?
From historical records, we know that the Armed Services sea-disposed of chemical munitions at three sites in Hawaiian waters. Two are in waters at depths of 6,000 feet or more and one is at approximately 1,000 feet. The shallower sea-disposal site is about 5 miles south of Pearl Harbor (outside the entrance). It is quite possible that both chemical and conventional munitions were disposed of at the same sites. Therefore, corrosion and biological growth may make it difficult to distinguish between these types of munitions. We know seawater at these depths is cold, in the range of 5.5 to 6 degrees Celsius (42 to 43 degrees Fahrenheit), and completely void of light. At this point, we cannot speculate as to the current condition of munitions casings or whether any chemical agent fill or other munitions constituents have been released into the seawater. We do know, however, that at the time of their disposal many of the mustard bombs disposed of at this site had begun to leak and were posing a potential hazard on land. Complicating matters is the fact that other entities (e.g., municipalities, industry) may have used these sites for disposal of non-DoD material (dredge material, municipal or industrial wastes).

Q5. What risk do they pose to ocean recreation users? The food chain?
The CWM in Hawai‘i were disposed in waters about 1,000 feet deep or more and based on physical and chemical characteristics, are not expected to reach the surface. Thus, direct contact with undiluted chemical agents that could pose a serious threat to humans is very unlikely. Most of the chemical agents used in the military munitions or in bulk containers that were sea-disposed are alkylating agents that degrade to less toxic compounds, or are completely neutralized by seawater. The University of Hawai‘i (UH) will test for these degradation products in seawater, sediment and human food species. Sulfur mustard, a blister agent, can form a hard polymer layer that shields the bulk of the compound from hydrolysis (reaction with water) and slows its neutralization. For this reason, sulfur mustard may be present on the seafloor in a stable form.

In Europe, commercial and recreational fishing occurs in several areas where CWM were sea-disposed. Neither mustard nor any other chemical agents has been detected in edible fish or any other type of edible seafood. Although the potential exists for arsenic from the degradation of some chemical agents to bioaccumulate, the amount of arsenic that has been found at European sea-disposal sites has not been a significant concern, and there is no known threat to the human food chain.

The Hawai‘i Undersea Military Munitions Assessment by the UH will, with technical and chemical safety assistance from the U.S. Army’s Edgewood Chemical and Biological Center, collect sediment samples during this assessment from the site where CWM is documented as having been sea-disposed. As part of this assessment, the UH will also collect and assess biota samples. Analysis of these samples will help determine whether chemical agents or other munitions constituents have been released to the environment and whether any release could potentially impact human health.

Q6. Will they be removed? If so, how?
The DoD currently does not plan to remove any CWM because there is no data to indicate that any CWM present poses a threat to human health or the environment. Absent such a threat, the risk to workers and the public associated with removal is considered too great.

The focus of the Hawai‘i Undersea Military Munitions Assessment by the UH is to attempt to determine the boundaries of the sea-disposal site and determine the impact, if any, of sea-disposed CWM on the ocean environment and gather information to help determine the effect of the ocean environment on sea-disposed CWM. It was not until 1969 that the National Academy of Sciences released recommendations to modify the disposal of chemical weapons. Until then, sea-disposal was considered the safest and most cost effective method to discard of excess, obsolete or unserviceable munitions and materials. The feasibility of recovering material from depths in excess of 1,000 feet is highly uncertain because of the lack of experience in performing this type of remediation (Congressional Research Service, 2007).

Q7. How risky is removal?
The DoD currently does not plan to remove any CWM because there is no data to indicate that any CWM present poses a threat to human health or the environment. Absent such a threat, the risk to workers and the public associated with removal is considered too great.

The focus of the Hawai‘i Undersea Military Munitions Assessment by the UH is to attempt to determine the boundaries of the sea-disposal site and determine the impact, if any, of sea-disposed CWM on the ocean environment and gather information to help determine the effect of the ocean environment on sea-disposed CWM. It was not until 1969 that the National Academy of Sciences released recommendations to modify the disposal of chemical weapons. Until then, sea-disposal was considered the safest and most cost effective method to discard of excess, obsolete or unserviceable munitions and materials. The feasibility of recovering material from depths in excess of 1,000 feet is highly uncertain because of the lack of experience in performing this type of remediation (Congressional Research Service, 2007).

Q8. If CWM was recovered, where would they then be disposed?
There are currently no plans to recover sea-disposed CWM. There are a number of safety, technical and legal matters that would need to be addressed before any decision could be made regarding the recovery of this material, the type of technology that would be used for its demilitarization, or the location where demilitarization would occur.

Q9. Does it make any sense to leave them in place? If so, why and for how long?
International consensus appears to support a preferred long-term approach that seeks to limit encounters with CWM and other sea-disposed munitions. This approach includes documenting munitions disposal sites on nautical charts, restricting access and activities at these sites, and providing safety education to maritime and coastal communities. These actions have proven effective for reducing inadvertent encounters with munitions or CWM and potential effects of such encounters.

Collectively, the findings of European studies conclude that the risk to human health remains relatively small if CWM or any persisting contamination on the seafloor, including sulfur mustard, remains undisturbed. On the other hand, human disturbances, such as dredging, trawl fishing, or work on underwater pipelines may, unless controlled, significantly increase any risk posed.

These European studies focused on sea-disposal sites located in much shallower waters—less than 500 feet in depth—than those in U.S. coastal waters. They also linked instances of human exposure to underwater munitions primarily to such disturbances, rather than to ocean currents moving CWM or chemical agent-related contamination ashore.

Q10. Why was UH selected to conduct this work?
The University of Hawai‘i (UH) is a recognized leader in the field of underwater research and has successfully partnered with the Department of Defense (DoD) on previous research efforts, including playing a key role in working with the National Oceanic and Atmospheric Administration (NOAA) as it conducted a survey of a near-shore, shallow water—less than 120 feet of depth—conventional munitions disposal site off O‘ahu.

Q11. What is UH’s responsibility?
UH will survey the area where military munitions were sea-disposed to determine the boundaries of the disposal site for the Project. UH will map the seafloor at the disposal site with high resolution SONAR. UH will also attempt to confirm the presence of CWM by direct observation using remotely operated underwater vehicles and manned research submarines.

During the assessment, seafloor sediment, water, and biological samples (e.g., fish) will be collected in the vicinity of sea-disposed CWM and any other munitions present. Samples will also be taken at control sites, up-current and away from the munitions disposal sites. A chemical analysis will be performed on all samples collected.

DoD personnel trained in explosives and chemical agent safety will provide support to UH throughout the survey process.

Q12. What is Environet’s responsibility?

Environet will:
• Design and write the Project Sampling and Analysis Plan (SAP), to include a Field Sampling Plan (FSP), Quality Assurance Project Plan (QAPP), and a Health and Safety Plan (HASP). Such plans are typically required by the Environmental Protection Agency for similar DoD, Army, and Navy project contractors. Once approved, Environet will monitor compliance with these plans.

• Document biota present at selected areas within the Hawai‘i Undersea Military Munitions Assessment study area and compare the observations against control sites within the area to qualify the differences between the areas and potential risk of the disposal sites.

• Compile and analyze data obtained from the Project and present findings in the final report.

• Provide the primary interface with the community, opening lines of communication with the public, while targeting specific interest groups. Environet will facilitate public meetings to open dialogue, solicit community concerns and ensure transparency. Environet will also work to identify issues that may arise, and most important, work to control misinformation associated with the assessment.

Q13. Where is the study site?
The span of the study site is a historic CWM sea-disposal site about 5 miles south of Pearl Harbor in waters greater than 1,000 feet deep.

Q14. What is the purpose of the assessment?
The primary objective of the Hawai‘i Undersea Military Munitions Assessment is to develop a process for use in evaluating this and other sea-disposal sites in U.S. coastal waters where military munitions are known to be present. This assessment is being conducted to (a) determine whether disposed military munitions have caused or are causing contamination of the ocean waters or sea beds; and (b) to investigate both the long-term effects of seawater exposure on disposed military munitions, particularly chemical munitions, and the impacts any such contamination may have on the ocean environment and those who use it, including public health risks. UH’s assessment will achieve these objectives by testing the process at the Pearl Harbor study site.

Q15. Is it possible that the chemical munitions will not be found?
Yes. Available historical documentation indicate that “dumping of the bombs [16,000 bombs (each being 4 1/3 feet long and 3/4 foot in diameter)] took place approximately (5) miles off O‘ahu.” Previous work identified numerous individual munitions in the area; however, the description of all of these munitions does not appear to match the description of the chemical bombs that historical documentation provides.

UH conducted a SONAR survey of a 27 square mile area (an area about one-forth the size of Honolulu) between 4 and 6 miles south of the mouth to Pearl Harbor to begin to determine the boundaries of the location of the sea-disposed CWM. Several features identified will be further investigated by UH during its assessment. It is possible that the features identified are either not munitions or may be conventional munitions.

It is possible that UH will not find any sea-disposed chemical munitions during its assessment because these munitions may have become buried in the sediment, corroded away or the disposal location in the records may not be correct. Even when munitions are found, it may not be possible to positively identify them as chemical filled. If munitions are found, the assessment will proceed regardless of whether the munitions can be confirmed as chemical. Either way, this assessment will provide valuable information concerning the effect of the oceans on munitions and the effect of munitions on ocean environment and those who use it.

Q16. Why are there munitions in the ocean?
Sea-disposal of excess, obsolete, unserviceable and captured enemy CWM was an accepted international practice through the 1970s. The safe disposal of CWM has always posed a significant challenge. At the time sea-disposal practices were used, the disposal alternatives were generally limited to burial on land or at sea, or burning. Though the DoD stopped sea-disposals in 1970, Congress did not formally ban it until 1972 with the passage of the Marine Protection, Research and Sanctuaries Act. In 1975, the United States signed an international treaty prohibiting ocean disposal of chemical weapons.

Q17. Did they know the contents would be released?
Yes, when disposed it was realized the containers could rupture or would most likely degrade over time, releasing the contents. It was also realized that chemical agents are subjected to a variety of chemical and physical processes in seawater that reduce or eliminate the toxicity and dilute the residuals. Because of these factors, sea-disposal was an internationally accepted disposal practice.

The rate of degradation varies from minutes to years based on the chemical agent involved and environmental conditions. Bioaccumulation, or the build-up of the degradation products in the food chain, was not considered a threat until the late 1960s, the implications of which are still not entirely understood. There are only a few constituents that could potentially bioaccumulate; however, the conditions of the study area are extreme in relation to those under which bioaccumulation studies have been conducted so the study will consider the possibility of bioaccumulation.

Q18. Are these items dangerous?
All munitions should be considered dangerous, with no exceptions. When encountered, unexploded ordnance may pose an immediate explosive hazard and should never be disturbed (touched, moved or picked up). Learn and follow the 3Rs of Explosives Safety if you encounter or suspect you have encountered a munition: Recognize—you have or may have encountered a munition and the potential danger it poses; Retreat—Leave it alone. Do not touch or disturb it, but carefully move away, leaving the area in the same direction from which you entered; Report! Call 911 and report what you saw and where you saw it. Local law enforcement authorities will secure the area and notify trained explosive ordnance disposal personnel who will dispose of the item. The Army’s UXO Safety Education Program can be found at: https://www.denix.osd.mil/uxosafety.

DoD is reviewing past scientific studies, both U.S. and international, for the effects of seawater on chemical munitions and the potential impacts of sea-disposal on marine environments. Should the UH’s assessment identify an imminent and substantial endangerment to the public, DoD will, in consultation with state and federal agencies, take immediate action to address the situation.

Q19. What is being done to mitigate the danger?
Other countries (e.g., Japan and Australia) have determined that the best approach to minimizing risk is to document locations on nautical charts, restrict access and activities at these sites, and conduct safety education for maritime and coastal communities. In Hawai‘i, the sites where CWM were sea-disposed are at depths (in excess of 1,000 feet) that are not normally accessible to the public. Because these areas are marked on nautical charts and deep, they are not trawled. This assessment should generate data that will allow the boundaries of the disposal area to be more accurately depicted on the nautical charts.

The DoD developed its Unexploded Ordnance (UXO) Safety Education Program in 2000 to inform the public about the dangers associated with military munitions and the actions to take should a munition or suspect munition be encountered. DoD hosts this program on its Defense Environmental Network & Information Exchange (DENIX) website at https://www.denix.osd.mil/uxosafety. DoD has expanded this program to address the sea-disposed munitions.

Q20. Is the study being conducted near where the three individuals were burned in 1976?
Yes, the ship-board incident to which you refer occurred about 3.3 miles off Pearl Harbor. In this incident, three individuals who were conducting a biological survey for DoD in deep water (about 1,000 feet in depth) using specialized equipment were exposed to mustard from containers brought to the surface.

Q21. What are the clean up options?
There are many challenges with attempting recovery of such material. These include, but are not limited to, the potential for release of any chemical agent present, the safety of personnel involved in recovery and ship-board operations and the public, and how to dispose of any CWM recovered safely. The University of Hawai‘i’s Hawai‘i Undersea Military Munitions Assessment will provide information that may help the nation better understand whether the presence of this material currently poses or may pose a risk to human health or the environment. It will also provide information to better understand the potential risks with attempting to recover this material.

Q22. How will the assessment be conducted?
A wide array of state-of-the-art technologies owned and operated by UH Manoa’s School of Ocean Earth Science and Technology (SOEST) will be employed during this assessment. UH will survey the area south of Pearl Harbor where military munitions were sea-disposed and determine the boundaries of the disposal site UH will map the seafloor at the disposal site with high resolution SONAR. UH will also confirm the presence of military munitions by direct observation using remotely operated underwater vehicles and three-man research submarines. During the survey, seafloor sediment, water and biological samples (e.g., fish) will be collected in the vicinity of sea-disposed CWM and other munitions present, and at control sites, up-current and away from the munitions disposal sites. Chemical analysis will be performed on all samples collected. DoD personnel trained in explosives and chemical agent safety will provide support to UH through the survey process.

Q23. When will survey results be available?
If the assessment proceeds as planned, UH will complete its assessment in 2009. It should, however, be understood that there are a number of challenges with conducting such surveys in deep water, and this is the first survey of this nature. As part of this assessment, Environet will keep the public informed via an informational website. Environet will also work to identify issues that may arise, and most important, work to control misinformation associated with the assessment.

Q24. What types of recommendations will the report make?
The purpose of UH’s assessment is to determine the facts and present these to the DoD. After review of the study’s results, DoD will, in coordination with state and federal agencies and with input from any affected communities, determine what if any actions are required.

Q25. Where are the other disposal sites in Hawai‘i?
DoD’s initial research of sea-disposal in Hawaiian waters indicates the Armed Services sea-disposed conventional munitions in Hawaiian waters between 1920 and 1951, and chemical munitions between 1933 and 1946. The National Oceanic and Atmospheric Administration (NOAA) nautical charts currently indicate four explosive material disposal sites off the Hawaiian Islands. A November 14, 1945, memorandum from the Commandant of the14th Naval District, Pearl Harbor, established these locations as disposal sites for “explosives, ammunitions and chemicals.”

The Army has documented the use of two of these sites for the disposal of CWM. As part of its initial research, the Army determined the type and quantity of material sea-disposed at these sites. To comply with the John Warner National Defense Authorization Act for Fiscal Year 2007, Public Law No. 109-364 (2006), Section 314, the DoD (Army and Navy) are working to determine and verify the locations in U.S. coastal waters where conventional military munitions were sea-disposed. This effort includes Hawai‘i.

Q26. How much control will DoD have over UH’s work?
UH is acting as an independent contractor and not as an agent for the DoD. UH is a recognized leader in the field of underwater research and is working in partnership with the DoD, and in conjunction with NOAA to collect data to allow defensible, scientifically sound conclusions concerning significant impacts to human health and the environment. Once DoD reviews and approves the required plans, UH will be required to execute the plans outlined. DoD is committed to ensuring transparency and open communication with the public during the course of this effort and with information obtained as a result of the assessment, especially regarding public health and the environment. UH takes its responsibilities to the scientific, academic and local community seriously and the report from this work will meet the highest standards.

Q27. What decisions will be made from the study effort?
The primary objective of the Hawai‘i Undersea Military Munitions Assessment is to develop a process for use in evaluating this and other sea-disposal sites in U.S. coastal waters where military munitions are known to be present. However, the DoD, with state, federal, and other agencies and, as appropriate, stakeholders will evaluate the data obtained during the assessment to determine whether additional assessment is required to understand the conditions at this site.

Q28. Who will decide?
Any decisions will be made in collaboration between the DoD, federal and state agencies, and with input from affected communities.

Hawai’i Undersea Military Munitions Assessment Project | Department of Defense | University of Hawai’i | Environet, Inc.