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Comments Submitted to the National Research Council

Posted by tmanney on March 8, 2012

Comments Submitted to the National Research Council Committee on the Updated Site-Specific

Risk Assessment for the National Bio- and Agro-Defense Facility in Manhattan, Kansas

William L. Richter, Ph.D.

Professor Emeritus, Kansas State University

February 24, 2012

            I wish to thank the Committee for the excellent public hearing held at Kansas State University on Friday, January 27, 2012. The two-hour session was exceptionally fair, transparent, and considerate of all points of view.  This is in contrast to the way in which most prior discussion of NBAF has taken place – with attempts to maintain a political “united front” in support of NBAF and to stifle, dismiss or deride any criticism of that position.

            There was some concern from interested university faculty that the January 27 meeting was held 8:00-10:00 on a Friday morning, when many had teaching commitments, but I thought most of the relevant arguments both for and against NBAF were aired. I realize that your Committee is not responsible for dealing with some of the substantive objections to NBAF that were raised in the meeting, and appreciate your willingness to listen to each submission. I did not offer oral testimony at the session because I perceived that time was limited and that others had important points to make. If it is not too late to do so, I wish to submit the following written comments for your consideration because I think they are relevant to your review of the site-specific risk assessment (SSRA) and because I did not hear them presented in the oral testimony.

1.         Risk, Other Values, and Organizational Culture

            The Committee raised some important questions in the first hour of the hearing about existing Kansas State University procedures to minimize risk of accidental or intentional release of deadly pathogens. The organizational cultures of large organizations can have serious consequences, as NASA found with both the Challenger and Columbia space-shuttle disasters. The Columbia Accident Investigation Board (2003) “searched for causal principles that would explain both the technical and organizational system failures [that] were needed to explain Columbia and its echoes of Challenger….” A significant factor, the Board found, was NASA’s organizational culture.

Leaders create culture. It is their responsibility to change it. Top administrators must take responsibility for risk, failure, and safety by remaining alert to the effects their decisions have on the system…. The past decisions of national leaders–the White House, Congress, and NASA headquarters–set the Columbia accident in motion by creating resource and schedule strains that compromised the principles of a high-risk technology organization. The measure of NASA’s success became how much costs were reduced and how efficiently the schedule was met….

At least two sets of questions flow from this observation that are relevant to the Kansas NBAF enterprise: (a) What has been Kansas State University’s record in dealing with other health and safety situations? (b) How have the proponents of NBAF dealt with risk issues to date?

 

1(a)      Kansas State University’s Record of Dealing with Risk

 

            On September 22, 2010, the Topeka Capital-Journal online edition carried a story on a toxic landfill lying just west of the NBAF construction site and north of the K-State football stadium. (http://cjonline.com/news/state/2010-09-22/ksu_to_clean_toxic_landfill) “As many as 175 chemicals of varying concentration and toxicity were tossed into the university’s landfill cocktail.” “Tritium, carbon-14 and other radioactive elements were placed into the ‘Atomic Waste Burial Plot’ adjacent to the Wildcats’ football stadium from 1961 to 1987, according to a consultant’s report prepared for K-State and submitted to the Kansas Department of Health and Environment in August.” Kansas State University is spending around $4 million to remediate the site.

            About a decade earlier, in November 2001, my wife (Professor Linda K. Richter) was sickened by poisonous fumes released in Waters Hall, where she was teaching that day and where her office was located. Subsequent inquiry found that the Entomology Department had contracted with Cheney Construction to paint lab tables with substances that would make them impervious to chemical spills. The substances used in the painting were themselves highly toxic, however, and should have been used with adequate precaution when the building was not in use. Instead, Cheney Construction subcontracted the job to a local auto-painting company and that company’s workers proceeded on a day when classes were in session, without even protective masks for themselves. My wife went to the hospital emergency room. It is our understanding that at least 200 people were sickened by the fumes, that the campus safety officer did not visit the site until three days after the event, and that no action was taken against those responsible for the accident.

            Following this incident, Professor Richter checked with other departments in the building and found that most were concerned about other environmental issues, including a seemingly high incidence of cancer among faculty with offices in the building and water quality in the drinking fountains. Most departments bought bottled water because they did not trust the water fountains, but there were no signs to warn students not to drink the water. When this was reported to central administration, a survey of the water fountains in the building was conducted and it was found that 17 of the 31 machines did not have potable water. The tests were conducted after letting the water run for four minutes, something a casual user was not likely to do. The polluted machines were simply removed from the building without fanfare.

            Our neighbor, Professor Torry Dickinson found herself getting sick in Leasure Hall. When the soil in front of Leasure was tested it was found to have high concentrations of heavy metals, apparently from the nearby coal-fired power plant.  We are not aware of any remedial actions that have been taken in that part of the campus.

            Certainly, the university’s risk and safety record is mixed.  As K-State’s first Associate Provost for International Programs I initiated and oversaw in the mid-1990s the development of health and safety procedures for our study abroad participants. But I also know that proactive procedures (such as predeparture orientation) were missing or uneven before that time. The university does have a safety officer but I wonder whether the SSRA has included a careful review of his files. The question is not whether such an officer exists but the extent to which the university has procedures in place to maximize safety and minimize risk, and to what extent those procedures permeate the university.

1(b)     NBAF Proponents and Risk

            It is difficult for avid proponents of a project like NBAF to build broad-based political support for the project and at the same time deal openly with questions of risk. To welcome serious public discussion of risk would undermine the boosterism involved in the political campaign to win and pursue the project. If NASA placed concern over cost and schedule above safety, the proponents of NBAF appear to have placed institutional prestige and community economic development concerns over open discussion of risk.

 

            Several university faculty have been willing to speak out against NBAF, but several have privately confided that they are afraid to do so for fear that their grant funding will be jeopardized (given the fact that the Vice-Provost for Research has been the leading proponent of NBAF). I wonder whether those preparing the SSRA have made any attempt to get anonymous input from K-State scientists. It might be reassuring if one could find memos inviting input from faculty on risk and safety issues, but I suspect that such an invitation would have been seen as a sign of weakness in K-State’s competition with other potential NBAF sites. Any adverse comments might have been viewed as disloyalty to the “team.”

            You might find it instructive to review university news releases on the subject of NBAF over the past few years to see the lack of balance between boosterism and coverage of any of the risk issues raised by critics.

2.         Closing Comments

            Given the “team loyalty” issue mentioned above, I think it is important to offer some brief personal comments. I was a faculty member at Kansas State University for 42 years prior to my retirement in 2008. For more than half of that time I served also as an administrator in various positions from department head to associate provost. I am grateful for the many benefits and opportunities K-State has provided my wife and myself, and we have been loyal university supporters. In short, our criticism of NBAF and our raising of questions concerning the potential risk it represents to our community do not derive from any animosity to the university.  Moreover, we regard many of the proponents as friends.

            Indeed, I think it is a deeper loyalty to the institution that many are willing to offer criticism that might help avert disaster, even in the knowledge that such criticism is not welcomed by the proponents. I also think that some of the most significant improvements in the design of NBAF, such as upgrading the level of tornado that the building might withstand, would not have come about without persistent raising of risk and safety questions by NBAF critics.

            Thank you all for your Committee’s important work.         

_______________

References: Columbia Accident Investigation Report, vol. 1 (August 2003). Washington, D.C.: Government Printing Office, 2003, ch. 8, sections 8.4, 8.6, quoted selections reprinted in William L. Richter and Frances Burke, eds., Combating Corruption, Encouraging Ethics (2nd ed.  Lanham, MD: Rowman & Littlefield, 2007), p. 153. The report should also be available online at www.caib.us/news/report/default.html.

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NBAF Risk Assessment is a Theory With Limited Predictive Value

Posted by tmanney on March 8, 2012


Our Kansas congressional delegation has hailed the recently released updated Site Specific Risk Assessment for the proposed National Bio and Agro-Defense Facility (NBAF) as a confirmation of its safety.  As stated on Senator Moran’s web site, “I am pleased by the updated assessment’s confirmation of what we always knew, Manhattan is the safest and best place for this facility to be built,” Sen. Roberts said. “The de minimis risk of outbreak should help allay concerns from any opposition, in the public or Congress.”

So, as a vocal member of that opposition, I wish to share my thoughts on the updated NBAF risk assessment for release of foot-and-mouth disease virus, or any of the NBAF germs that are actually deadly to humans.  After studying the ca. 1000-page statistical modeling analysis, I cannot question its findings; it seems to be a legitimate response to Congress’s mandate. Colleagues more authoritative in their knowledge of probability theory and statistical analysis agree. But I do question and doubt the legitimacy of incomplete, uninformed, and apparently disingenuous public interpretation of the report’s findings by the administrators and politicians who seem singularly focused on bringing this facility to Manhattan at any cost.  KSU officials and the Kansas Congressional delegation, as reported nation wide, have dwelled almost exclusively on the risk of an FMD outbreak during the NBAF’s 50-year operating life being down from 70 percent to 0.11 percent.

But these interpretations have ignored 1) the caveat stated repeatedly throughout the report that the calculated probabilities cannot be taken as absolute values, 2) that statistical models are only theories and are no more accurate in predicting actual events than the assumptions that are plugged into them, and 3) the uncertainty of many of the input assumptions, and therefore of the conclusion, are extremely large.  These too are clearly stated in the report.

For example, on page 403: “it is fundamentally a modeling‐based approach and therefore has limited ability to predict the absolute probability of an outbreak occurring and the corresponding consequences.”  Statistical analysis is highly technical, intensely mathematical, and universally mysterious to ordinary people.  I have yet to read, even in the DHS report itself, an intelligible statement of what a risk of 0.11 percent actually means in the real world. Yet Senator Pat Roberts has declared that the risk is “de minimis”, which is even more obscure. One highly knowledgeable scientist explains that it means, for example, that if 10,000 identical NBAFs were built, then 10 of them would be certain to release FMD viruses over their 50-yr life times.  But as with all such probability estimates, it predicts absolutely nothing about any single case – a single NBAF.  It is just a theory.  What is worse is that the problem of understanding what a probability of 0.11 percent means in real life carries over to understanding what the uncertainty of such a value means.  The same computer model that calculated the value of 0.11 percent also calculated that there is a 95 percent chance that it could be as high as 2.5 percent.  What does that mean to you?  De minimis?

Perhaps in an attempt to help ordinary people understand these obscure, theoretical concepts, the authors converted from percent to dollars based on the economic consequences of an FMD release.  In these units they conclude, “The uncertainty (standard deviation) in the 50-year cumulative risk was found to be approximately $15B, regardless of whether catastrophic events are included.”  To me, this says the economic risk is somewhere between 0 and $15 Billion.  De minimis?

We hope that the National Research Council commission has a more realistic grasp of limits of a statistical model based on limited and uncertain input data.

Tom Manney

Professor Emeritus, Physics & Biology

Kansas State University

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