Environmental Assessment for
Bacillus subtilis
Particles toChallenge Bio-Detection Sensors in Subway StationsPrepared for Department of Homeland Security Science andTechnology DirectorateJanuary 12, 2012Version 15
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EXECUTIVE SUMMARY
This Environmental Assessment (EA) documents the analysis of the potentialeffects of a proposal by the Department of Homeland Security (DHS) Science &Technology Directorate (S&T) to conduct tests and experiments involving therelease of low concentrations of particles at certain stations within theMassachusetts Bay Transit Authority’s (MBTA’s) Subway ‘T’ System. Noconstruction, permanent land disturbance, or land use changes would occur withimplementation of the Proposed Action or the Alternatives.DHS S&T has been developing technologies and sensors needed to rapidlydetect a potential biological attack on the Nation’s transportation infrastructure inorder to minimize public exposure and strengthen security. To validate theperformance of the technologies, it is necessary to perform field tests in a real-world environment. Subway systems provide one of the most challenging andharsh indoor settings that sensors of this nature would be exposed to in real-world deployment, due to the temperature and humidity extremes that oftencharacterize these types of indoor environments. In order to understand the truedetection capabilities of the biological sensor networks, challenge tests with amaterial must be performed. Since a portion of the technologies rely on thedetection of genetic or proteinaceous materials to positively identify a particularthreat agent, the simulant must be of biological origin.
Bacillus subtilis,
or
B.subtilis,
a soil bacterium which is not pathogenic to humans, has been studiedextensively for human, animal, and environmental safety, and has ultimatelybeen approved by the United States Environmental Protection Agency (EPA) forday of harvest use on produce as a bio-fungicide. For these reasons
B. subtilis
has been chosen to serve as the particulate material for the proposed tests.There are four action alternatives presented in this assessment to evaluatetradeoffs in test procedures, which would either fully or partially meet the needsof DHS S&T; additionally there is a no action alternative, which would involve noparticulate releases:The first alternative is to conduct an aerosol release of known quantities of
B.subtilis
within the subway system to demonstrate a positive detection of thematerial by the sensor network installed in several underground stations. Thesestudies, to be performed at peak operational capacity for trains and passengers,are designed to most closely simulate the conditions that would likely exist in theevent of a true bio-terrorist attack.The second alternative is to conduct an aerosol release of nonviable (killed)
B.
subtilis
particles for testing the sensors during revenue hours. The killedmaterial, because it is no longer an active biological substance, is considered asa particulate or dust nuisance. This alternative would alter the test material, butnot the test conditions or the test release as described in Alternative 1.
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The third alternative is to conduct an aerosol release of nonviable (killed)
B.
subtilis
spores for testing sensors during non-revenue hours for the subway. Thetrains would be operated to mimic a peak schedule, but no passengers would bepresent in the stations. This alternative would alter the test conditions, but notthe test material or release as described in Alternative 2.The fourth alternative would be the direct injection of viable
B.
subtilis
sporeaerosol into a single sensor during operational hours for the subway, and captureall of the test material within the sensor such that it does not enter the subwaystation environment at all. This alternative would not alter the proposed testmaterial, but would alter the test release and conditions as described inAlternative 1.Due to the potential human health and safety risks posed by the presence ofsensitive populations, to include immune-compromised riders during operationalhours, the aerosolization of viable spores to challenge the biosensor system, asoutlined in Alternative 1, is not recommended. Implementing the use ofnonviable material, as outlined in Alternatives 2 and 3, will ensure the health andsafety of all subway riders including sensitive populations without compromisingthe results of the testing activities. Alternative 4 presents no potential adversehuman health or safety impacts; however the procedure as outlined does notfulfill the purpose of the aerosol tests.The indirect environmental effects caused by the potential exposure of terrestrialwildlife by movement of the material out of subway tunnels and into the open airwere also evaluated. The environmental consequences posed by any of thealternatives as outlined will not have an adverse effect on terrestrial wildlife.In accordance with Executive Order 12898,
analysis of the environmental effectsmust also include effects on minority communities and low-income communities,when such analysis is required by the National Environmental Policy Act of 1969(NEPA), 42 U.S.C. section 4321 et esq. Overall, populations using the subwayas well as those living in and around the effected subway stations do notdisproportionally represent minority and low-income populations; implementationof alternatives has no adverse impact on resources, human health or theenvironment.As a commercial biofungicide, the
B.
subtilis
test material has undergonerigorous studies to evaluate the potential health effects and safety of the materialfor the general public, workers and environments surrounding the commercialuse, and no adverse health effects from low level exposure to
B.
subtilis
inhealthy populations have been documented. The quantity of material proposedfor these tests is well below the dose rates for the toxicology testing of thesebiofungicides and the reported results provide a conservative comparison.Therefore, Alternative 1 would be the preferred test condition to provide the mostrealistic challenge to the system. However, taking into account any health-
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Environmental Assessment for Bacillus subtilis Particles to Challenge Bio-Detection Sensors in Subway Stations
A 28-page environmental assessment, prepared by the U.S. Department of Homeland Security, reviewed data from the U.S. Environmental Protection Agency (EPA) and other published studies for any potential harm associated with this bacterial strain. Studies cited…
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