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Dan Nance
Deputy Public Affairs Officer
JRTC and Fort Polk
(337) 531-7203

Dear Concerned Citizen,

We have received and recorded your comments regarding the proposed aerial release of the biological simulant Bacillus subtilis for Biological Integrated Detection System (BIDS) training.

The information below is provided in response to questions about the proposed training.

Copies of the document, entitled "Environmental Assessment for Aerial Release of Biological Simulant for Biological Integrated Detection System Training, Fort Polk, Louisiana", will be available for review at Beauregard Parish Library in DeRidder, the Vernon Parish Library in Leesville, and the Rapides Parish Library - Main Branch in the near future. You may also obtain a copy of the EA from the Fort Polk Public Affairs Office, located at 7073 Radio Road, Fort Polk. We will provide a copy of the EA to you upon request.

Thank you for your interest in this action.

As of 1046 13 SEP 00

Key Facts about the Aerosol Release of the Biological Simulant, Bacillus subtilis

The proposed training activity poses virtually no risks to human health or the environment. It involves the use of a simulated biological agent so that soldiers of the 7th Chemical Company can train with the Biological Integrated Detection System (BIDS) - an air monitoring system mounted on a HUMVEE that is designed to provide early detection of biological hazards.

The simulant to be used is a dead form of the bacterium Bacillus subtilis - a non-pathogenic bacterium commonly found in soils, water and decomposing plant residue. This substance has been tested extensively and is not considered toxic to humans, plants or animals.

This simulant has been used at Dugway Proving Ground, Utah for more than 40 years and at Fort McClellan, Alabama for over six years under conditions similar to those proposed at Fort Polk. During the period of use, no environmental or health effects have been documented at those installations.

The release of the simulant poses virtually no risk to the public or environment. It would be released in water in an aerosol spray through an agriculture-type sprayer to allow the BIDS system operating in the vicinity to detect the simulated agent. The only effect it will have will be to trigger a response in the BIDS system.

The spores to be used would be irradiated with gamma radiation rendering it dead before it arrived at Fort Polk. The use of gamma radiation is a common sterilization process used by the food industry to make food safer and by the medical industry for instrument sterilization. Spores will then be tested to insure that the radiation procedure was effective and that the spores are in fact dead.

Only three areas at Fort Polk will be used for this training and it will only be conducted in weather conditions favorable to prevent off-post drift of the release. This training would occur only 12 times a year. The 7th Chemical Company has prepared a detailed Standard Operating Procedure (SOP) to govern the use of the simulant and assure that training is conducting under appropriate guidelines and conditions. All training events at Fort Polk involving the simulant will follow the requirements of the SOP.

"With the measures described above, Fort Polk has taken strong precautions to minimize potential risks to human health and the environment. In considering risk to human health, both the potential for exposure and the level of severity of effects must be considered. The proposed training considers both factors. First, Fort Polk has limited the probability that civilians on and off-post will be exposed to the simulant by restricting the locations and conditions of use. Second, we have essentially eliminated any potential for adverse health effects by using non-viable spores. The potential for adverse effects to human health and the environment would be very minimal even with use of live spores; use of dead spores makes the potential for such effects virtually non-existent."

Questions and Answers

Q1: Exactly what is Bacillus subtilis?
A1: The simulant to be used is a dead form of the bacterium Bacillus subtilis - a non-pathogenic bacterium commonly found in soils, water and decomposing plant residue. This substance is not considered toxic to humans, plants or animals.

Q2: What are the risks to human health?
A2: Virtually none. The simulant used on Fort Polk will be a dead form of the bacterial spore. It will have been irradiated by the use of gamma radiation - a common sterilization process used by the food and medical industries. The substance is not considered toxic to humans.

Q3: Will you or your family stand under if when it is sprayed?
A3: No - the only people in the vicinity of the training will be the soldiers conducting the training event. But even they will not be at risk from this training. Again the simulant to be used on Fort Polk is not a live bacteria spore.

Q4: What are the long-term effects of this Bacillus subtillis?
A4: Virtually none. The use of irradiated B. subtilis spores precludes any potential issues that would have been raised by the use of viable spores. The CDC lists live B. subtillis as a non-pathogenic organism in humans. The US Environmental Protection Agency has concluded that industrial us of live B. subtillis presents low risks of adverse effects to human health or the environment. The live bacterium is used in agricultural applications to control fungus on crops. It is also widely used in industry for the production of various enzymes. There have been rare cases where the live microorganism has been isolated from infection sites in persons with severely compromised immune systems. However, the use of dead spores precludes any such problems.

Q5: Exactly what strain are you using?
A5: The name Bacillus globigil was initially assigned to these bacteria. Later scientific advances allowed the distinction of the organism to be used here as Bacillus subtilis, variation niger. Again - the spores to be used will not be live.

Q6: Will Fort Polk be willing to pay the medical bills of people affected by this training?
A6: No human health or environmental problems are expected as a result of this training.

Q7: What are the risks to the environment of this training?
A7: Virtually none. The training will involve the use of dead spores of this bacterium. Live B. subtillis is found naturally in the environment. The live bacterium is used in agricultural applications to control fungus on crops. It is also widely used in industry for the production of various enzymes. There have been rare cases where the live microorganism has been isolated from infection sites in persons with severely compromised immune systems. However, the use of dead spores precludes any such problems.

Q8: Why is this training necessary?
A8: This simulant will provide a response in the BIDS unit and provide soldiers with realistic training in detecting biological hazards on the battlefield. Our soldiers must be prepared to detect and defend themselves from biological attacks. The use of an aerosol simulant will provide soldiers of the 7th Chemical Company the opportunity to operate the BIDS and detect the simulant. This realistic training meets the Army's objectives to "train as you fight."

Q9: What do you mean by "aerial" release of the simulant? Will an aircraft be used to release it?
A9: No aircraft will be used to release the simulant. It would be released in water in an aerosol spray through an agriculture-type backpack sprayer to allow the BIDS system operating in the vicinity to detect the simulated agent. The only effect it will have will be to trigger a response in the BIDS system.

Q10: How will you be sure the bacteria spore is dead?
A10: The spores to be used would be irradiated, rendering it dead before it arrived at Fort Polk. The use of gamma radiation is a common sterilization process used by the food industry to make food safer and by the medical industry for instrument sterilization. The commander of the 7th Chemical Company will be responsible for ensuring that each batch of irradiated B. subtilis spores received at Fort Polk is accompanied by laboratory documentation certifying that it is non-viable (dead) prior to use for training.

Q11: How will you be sure that there will not be any off post drift?
A11: Prior to the start of a BIDs field training exercise, the unit will check meteorological conditions from Fort Polk Range Control and/or Fort Polk Army Airfield to determine whether suitable weather conditions exist for release of the simulant. The sites for this training were selected to minimize the possibility of off-post drift. Acceptable wind speed and direction conditions must be met before the simulant release would occur.

Q12: Where are these sites where this training will occur?
A12: Geronimo Drop Zone in the Fort Polk training area; Tiger Drop Zone in the Peason Ridge Training Area and the Forward Landing Strip at Peason Ridge.

Q13: How often will this training occur? How much substance would be released.
A13: A total of 12 such training events would occur each year. The unit would conduct two field training exercises per quarter per platoon. Each FTX would occur over four consecutive nights. Each dissemination would take approximately 15-30 minutes to complete. Not more than one dissemination would occur in an hour's time. Simulant use would involve dissemination of 400 grams of irradiated (dead) B. subtilis spores in 8 to 10 liters of water each night.

Q14: Why use this spore at all? Why not use water or some other non-bacterial substance?
A14: This simulant will provide a response in the BIDS unit and provide soldiers with realistic training in detecting biological hazards on the battlefield. Use of water or an inorganic substance would not trigger a similar response in the BIDS. Our soldiers must be prepared to detect and defend themselves from biological attacks. The use of an aerosol simulant will provide soldiers of the 7th Chemical Company the opportunity to operate the BIDS and detect the simulant. This realistic training meets the Army's objectives to "train as you fight."

Q15: I'm told federal law prohibits the military from using the public as guinea pigs for chemical or biological testing. How can you expose us to this bacteria if this is true?

A15: This training has nothing to do with chemical or biological testing.
The proposed action involves the release of a dead spore of the bacterium Bacillus subtilis into certain areas of the Fort Polk and Peason Ridge training areas. This bacterium is non-pathogenic and is commonly found is soils, water and decomposing plant residue. This training would use a dead form of the spore resulting in virtually no risks to human health or the environment.

Q16: Tell me about the 7th Chemical Company.
A16: The mission of the 7th Chemical Company is to conduct biological surveillance operations across Corps or joint task force theaters of operation. The unit consists of five platoons totaling approximately 180 soldiers and 35 vehicles with trailers. The unit is equipped with the Biological Integrated Detection System (BIDS) - a system mounted on a HUMVEE that is designed to provide early detection of biological hazards.

Q17: Has this training been conducted at Fort Polk before now?
A17: Not at Fort Polk because the use of this simulant required environmental documentation which is in the process of being completed. This simulant has been used at Dugway Proving Ground, Utah for more than 40 years and at Fort McClellan, Alabama for over six years under conditions similar to those proposed at Fort Polk. During the period of use, no environmental or health effects have been documented at those installations.

Q18: When would this training occur at Fort Polk?
A18: Following completion of the environmental assessment. The EA will be completed after the public comment period ends Oct. 6, 2000.

Q19: What is the status of the environmental assessment?
A19: The assessment has concluded a Finding of No Significant Impact. A public comment period ends Oct. 6, 2000. Comments can be made to the Public Affairs Office, 7073 Radio Road, Fort Polk, LA 71459-5342. Copies of the EA are available through the Fort Polk Public Affairs Office.

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