Environmental Assessment for Proposed Outdoor Testing at Chilocco
The Department of Homeland Security Science and Technology Directorate announced a collaborative scientific study with OSU-University Multispectral Laboratories, L.L.C. (UML) that will include low level outdoor release of inert chemical and biological simulant materials at the Chilocco (former) Indian School Campus outside of Newkirk, OK, during winter 2018 and again in summer 2018.
The purpose of this study is to gather data that enhances our predictive capabilities in the event of a biological agent attack.
Specifically, this work will help in predicting the extent to which an intentional release of a biological agent may penetrate single family and multi-family structures.
These tests will release inert chemicals and biological materials that will be used to measure the amount of material that penetrates the buildings under varied conditions.
FREQUENTLY ASKED QUESTIONS on the proposed studies to be performed under the Hazards of Dynamic Outdoor Releases Project
Why are they doing these tests?
A strategic goal of the U.S. Department of Homeland Security (DHS) is to prevent, detect, protect, and recover from biological attacks. Characterizing the impact of biological weapons on infrastructure is a key element to achieving this goal. Current models are based on penetration of natural particulate matter (largely road dust, pollen, and exhaust), which is not representative of scenarios in which a terrorist might release a biological agent. To address this gap, the DHS Science and Technology Directorate (S&T) will conduct an outdoor release of inert chemicals and biological materials in order to estimate the fraction of spores that penetrates into buildings representative of both a typical single and multi-family residence to support consequence and risk assessment modeling.
This testing seeks to enhance resiliency and preparedness of the nation by increasing our ability to predict the extent to which an intentional release of a biological agent may penetrate single family and multi-family structures. The results from this testing effort will further inform and advance preparedness for bioterrorism events in critical infrastructure for future response and recovery planning decisions and actions by local, state, and federal emergency managers.
What is being released?
Testing will be conducted through the release of (2) different non-hazardous, nontoxic, and non-reactive powders and a harmless biological particulate. These materials are meant to simulate the behavior of harmful biological materials as they move from the outdoors into buildings.
These are:
- Inert Particle 1 is titanium dioxide (TiO2), a white odorless, non-hazardous, non-flammable, and non-reactive powder that does not dissolve in water. Titanium dioxide is commonly used in paints, food, cosmetics, and insecticides. As an example, sunscreens containing titanium dioxide are recommended by medical experts to effectively block certain harmful UV rays. (https://www.webmd.com/beauty/features/whats-best-sunscreen#1)
Titanium dioxide is not regulated or defined as a toxic or hazardous material.
- Inert Particle 2 is a 90:10% mixture of urea powder with CL Fluorescent Brightener 220. Urea is the main chemical found in human and mammalian urine and is used worldwide as a fertilizer. CL Fluorescent Brightener 220 is a non-hazardous optical brighter found in toothpastes and laundry detergents to make whites appear brighter.
- The Biological Particulate will be a preparation of Bacillus thuringiensis subsp kurstaki (Btk) spores that have been “barcoded.” Bacillus thuringiensis kurstaki is a microbe found on plants and in soils everywhere, is nonhazardous to humans, and used widely by farmers nationally to kill specific crop destroying insects, particularly those employing organic gardening practices. These spores can be purchased for home-use at stores selling gardening supplies, and are considered safer than traditional chemical pesticides. The “barcode” in these materials will allow DHS and our performer to conclusively identify the material we use from any that might occur naturally or be used by a farmer on nearby fields. This material simulates the kind of material that might be used in a bioterrorist attack on U.S. citizens.
Are these materials safe?
Yes.
The particles are colorless, odorless and non-toxic materials. They have been used in numerous other studies both indoors and outdoors to assess airflow and contaminant spread. The direct, indirect, and cumulative environmental effects caused by the potential exposure of terrestrial wildlife, vegetation, water resources, and air quality by movement of the material by any of the particulates will not have an adverse effect. This is due to both selection of the test materials and limited quantity that will be used.
Native Btk, sold under the commercial name of Dipel, is used extensively as a bioinsecticide and is not considered a hazard by the U.S. Environmental Protection Agency (EPA). The barcoded variant provides much more specific detection and identification from background than the native organism, as it contains a barcode that does not affect any physiological function or phenotypic expression of the organism. It will be dispersed in a similar manner to that of native Btk when used as an insecticide. However, release will be at much lower concentrations than typical insecticidal application rates. The use of the barcoded Btk has been approved for use in this program by the State of Oklahoma’s Department of Agriculture, Food, & Forestry.
If these materials being used in testing are safe, why are the workers wearing goggles, gloves, masks, and other personal protective equipment (PPE) during testing?
These standard precautions are recommended by OSHA for all individuals who are working in conditions that may result in exposure to particulates, as such exposure could cause irritation of the eyes or skin. Examples include painters, individuals who may be sanding drywall or painted surfaces, or farmers or other professionals applying fertilizers and pesticides.
Despite the extremely low hazards posed by the materials we propose to test, the individuals who will conduct the actual release will be required to work with the materials in their most concentrated form. They are therefore at the highest risk of an accident such as splashing into the eyes, or being irritated by exposure to the particulate sprays. These are also standard safety recommendations found on the labels of similar commercial products.
Why are these tests being performed at Chilocco?
The Chilocco campus and surrounding land is under the ownership of the Council of Confederated Chilocco Tribes (CCCT) which include the Kaw Nation, the OtoeMissouria Tribe, the Pawnee Nation, the Ponca Nation, and the Tonkawa Tribe.
DHS S&T and OSU-University Multispectral Laboratories L.L.C. (UML) have been in communication with the Bureau of Indian Affairs and CCCT and have determined that the implementation of the preferred alternatives has no adverse impact on resources, human health or the environment.
The buildings on the Chilocco campus used in this program include characteristics that are representative of residential and apartment buildings within the United States. Additional characteristics desired for test buildings include:
- Minimal proximity to the public
- Unoccupied from daily use
- Have release positions in the predominant wind direction
- No obstructions within 20 meters of the building
- Centrally located to campus to ensure plume dissipation below permissible exposure limits prior to migration off campus.
Access to the site will be restricted to UML, Government staff, and contractors supporting this study.
Why did you choose to do these in a populated area of Newkirk, OK?
DHS chose the performer, OSU-University Multispectral Laboratories, over other performers and other locations on the strength of their proposal to conduct testing desired by DHS. DHS has conducted similar activities in major metropolitan areas for the same purpose of understanding how we can best protect U.S. citizens and ensure the resiliency of our communities to respond to acts of WMD terrorism.
Who is paying for these tests?
These tests are sponsored by DHS S&T, in collaboration with the EPA.
When and where will these releases occur?
The release activities would take place at the abandoned Chilocco campus in rural Oklahoma during February 2018 and then again during June/July, 2018. This site is closed to the general public under an exclusive use agreement between the site’s tribal owners, the CCCT, and UML.
Particulate release at the site is designed to mimic that of an actual biological release and will be bound by strict conditions. These release conditions were developed to ensure that the aerosol cloud generated, with both inert and biological simulants, would provide a measurable signature that would then rapidly decrease below the Occupational Safety and Health Administration (OSHA) permissible exposure limits (PEL) values before reaching the property boundary, thereby these releases would pose no risk to public and minimal risk to the surrounding environment.
Was this study evaluated under the National Environmental Policy Act?
It will be. The Environmental Assessment that has been published by DHS, and available for review at https://www.dhs.gov/national-environmental-policy-act, is part of the process to comply with requirements of the National Environmental Policy Act. Assuming that after public comment, a finding of no significant impact is found, the proposed tests will have complied with the requirements of the law.
FULL ENVIRONMENTAL ASSESSMENT
Pursuant to the National Environmental Policy Act (NEPA) of 1969 42 U.S.C. 4321 et seq., the Department has completed a Draft EA to identify any potential environmental impacts associated with the use of these test materials. DHS invites comments on the Draft EA during the 30-day comment period beginning on November 8, 2017. You may submit comments using only one of the following methods:
- By email to biotest@hq.dhs.gov
- By mail to DHS:
S&T CBD Mail Stop 0201
245 Murray Ln SW
Washington, DC 20528-0201
When submitting comments, please include your name and address, and identify the comments as regarding the Outdoor Testing at Chilocco. To ensure consideration, comments must be received by December 8, 2017. Once the final environmental and decision documents are complete, they will also be posted on this site.