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Environmental Assessment of Proposed Tracer Particle and Biological Releases for the Hazards of Dynamic Outdoor Release (HODOR) Project
Prepared for Department of Homeland Security Science and Technology Directorate
This Environmental Assessment (EA) documents the analysis of the potential effects of a proposal by the Department of Homeland Security (DHS) Science & Technology Directorate (S&T) to conduct tests during January/February 2018 and then again during June/July, 2018 involving the release of low concentrations of particles at two buildings within the Chilocco Indian Agricultural School (Chilocco campus) in Newkirk, Kay County, OK. The S&T program is entitled the Hazards of Dynamic Outdoor Releases (HODOR). No construction, permanent land disturbance, or land use changes would occur with implementation of the Proposed Action or the Alternatives.
The HODOR program supports DHS’s strategic goals to detect and recover from biological attacks and inform and support biodefense planning, response, and restoration, particularly in consequence/risk assessment modeling of the indoor hazards posed by outdoor aerosols. Characterizing the impact of biological weapons on infrastructure is a key element to achieving this goal. One indicator of a building’s ability to withstand the effects of a biological weapon is the building protection factor (BPF). The BPF is the degree to which a building’s occupants are protected from biological materials as compared to a person located outside the building. Dispersion models have been created to help in these endeavors and are actively used by agencies within DHS for both pre- and post-attack planning. Pre-attack planning includes identifying strategies for response in the event of a biological attack. Post-attack planning includes determining the source location for attribution, identifying exposed people, and aiding the remediation effort (e.g., mapping, decontamination). While the dispersion models are critically important for homeland defense, the lack of quantitative evidence and understanding of the BPF is a significant gap. Selection of specific buildings that are representative of U.S. construction for homes and apartments was conducted to support this effort. This EA is being conducted in accordance with the National Environmental Policy Act (NEPA) in 40 CFR 1500- 1508, and DHS Directive 023-01, Implementation of the National Environmental Policy Act. In support of these tests, aerosol biologists from Sandia National Laboratory, aerosol engineers from the National Biodefense Analysis and Countermeasures Center (NBACC), scientists from the OSU-University Multispectral Laboratories (UML), and other supporting state and federal agencies have partnered for the proposed testing. The assembled team has conducted a thorough review of available literature to assess the potential for environmental hazards associated with the proposed program. Specifically, an analysis of alternatives was conducted to select appropriate buildings for testing, best inert materials, and optimal biological material for release to successfully meet program objectives.
Buildings to be used for testing were selected based on the DHS-desired characteristics, as well as the ability to release materials at a distance from these buildings that minimize environmental impact and public exposure.
Action alternatives were considered for testing location and testing materials. A total of five abandoned residential and apartment buildings within the Chilocco campus were evaluated
against two main criteria: conformance to typical US building standards; and potential testing obstructions (e.g. vegetation, proximity to other buildings).
Residential Building Alternative 1 (Building 53) and Residential Building Alternative 2 (Building 56) both contain numerous vegetation and building obstructions and would require major renovations to meet current typical building standards. Residential Building Alternative 3 (Building 58) has the fewest number of potentially obscuring structures and required minor renovations.
Apartment Building Alternative 1 (Building 10) did not realistically represent current apartment building design or utilize standard heating, ventilation, and air conditioning (HVAC) systems. Apartment Building Alternative 2 (Building 60), more realistically simulated a typical apartment structure with multiple HVAC systems, thus allowing more accurate testing conditions. The No Action Building Alternative would result in no real-world testing scenario, and would not meet the stated purpose and need.
The use of inert particulate materials provides extremely valuable information toward the overall objectives of the HODOR program. Inert materials will be used to monitor gross particle movement around and into each building, in real time, using relatively simple and straightforward sensors. The data collected with inert particle materials will be used to optimize sensor placement for subsequent biological particulate releases. Two different inert particulates were selected to be employed for use in gross characterization of particle penetration into buildings. Alternative Inert Particle 1 would utilize titanium dioxide (TiO2), a white odorless powder that is chemically insoluble in water, nonreactive, nonflammable, and nonhazardous. This material is not regulated or defined as a toxic or hazardous material.
Alternative Inert Particle 2 is a 90:10% mixture of urea powder with CL Fluorescent Brightener 220. Urea serves an important role in the metabolism of nitrogen-containing compounds by animals and is the main nitrogen-containing substance in the urine of mammals. CL Fluorescent Brightener 220 is a finishing reagent in textiles, and up to 2% by weight in laundry detergents.
Both aerosol particulates would be released and detected by sensors located outside and inside the preferred buildings. At the concentrations resulting from the proposed releases, all materials are considered nontoxic and nonhazardous. The No Action Alternative would result in no release of aerosol particulates. This alternative would result in possible missed biological sensors detections, reducing the likelihood of program success. In addition, it would increase the number of barcoded biological material releases and would require additional labor to decontaminate each site between releases. These factors would increase both programmatic cost and time and is not a preferred alternative.
To understand the true detection capabilities of the biological sensor, challenge tests with a material must be performed. Since a portion of the technologies rely on the detection of genetic or proteinaceous materials to positively identify a particular threat agent, the simulant must be of biological origin. Three alternatives were considered in order to evaluate tradeoffs in test procedures, which would either partially meet the needs of DHS S&T; additionally there is a no action alternative, which would involve no particulate releases.
Alternative Biological Particulate 1 would employ the use of Bacillus thuringiensis subsp kurstaki (Btk) barcoded spores, which are the preferred biological material to be employed for sensitive characterization of building penetration. 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) when handled appropriately. The barcoded variant provides much more specific detection and identification from background than the native organism, as it contains a genetic 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.
Alternative Biological Particulate 2 would utilize native Btk, without barcoding. Native Btk is an approved biopesticide under the commercial name of Dipel. This alternative would require much more time and labor to execute. Alternative Biological Particulate 3 would employ a tagged, inert, fluorescent particle known as DNATrax. The safety of DNATrax particles cannot be assumed, therefore, its use presented unknown risks not conducive to testing objectives. The release of all three biological particulate alternatives would result in slow application rates and low concentrations. No Action Biological Particulate Alternative would still allow the primary objectives of the tests to be met through use of inert particles only, but would require larger quantities of inert powder to overcome the natural background of particulates internal and external to the building. In order to simulate real world data that more closely matches, releases of an actual biological nature is needed.
The Chilocco campus and surrounding land is under the ownership of the Council of Confederated Chilocco Tribes (CCCT) which include the Kaw Nation, the Otoe-Missouria Tribe, the Pawnee Nation, the Ponca Nation, and the Tonkawa Tribe. The campus is abandoned, thus reducing the risk of potential human health and safety risks posed by the presence of sensitive populations. S&T and 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 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 alternatives would not have an adverse effect. This is due to both selection of the test materials and limited quantity that will be used. The Chilocco campus is listed on the National Register of Historic Places. Consultation with the appropriate Tribal Historic Preservation Officers has been initiated, and no adverse effect is anticipated.
This EA details the approach and reasoning the team would employ to minimize environmental impacts. As can been seen in the body of this document, the buildings to be used, their location, the release locations and the amounts and types of materials to be used all serve to minimize impact to the surrounding environment. S&T has determined that the proposed testing would have no potential for significant impact on the human environment and that an environmental impact statement is not needed.