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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Summary This report responds to a request by the director of the U.S. Army Chemical Materials Agency (CMA) for the National Research Council to examine and evaluate the ongoing planning for closure of the four currently operational baseline incineration chemical agent disposal facilities and the closure of a related testing facility. The report evaluates the closure planning process as well as some aspects of closure operations that are taking place while the facilities are still disposing of agent. These facilities are located in Anniston, Alabama; Pine Bluff, Arkansas; Tooele, Utah; and Umatilla, Oregon. They are designated by the acronyms ANCDF, PBCDF, TOCDF, and UMCDF, respectively. Although the facilities all use the same technology and are in many ways identical, each has a particular set of challenges. Initially, the Committee to Review and Assess Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System was requested to use the programmatic closure plan developed for the TOCDF as the basis of this study. When the CMA first commissioned this study, the TOCDF was expected to be the first of the four facilities to close. However, the anticipated order of closure has since changed based on when each facility is now expected to complete agent disposal operations. At the present time, it is expected that PBCDF will close first, with UMCDF, ANCDF, and TOCDF to follow. It became clear both to the committee and the Army that it would be advisable to examine planning for all four facilities and the pilot testing facility near the TOCDF known as the Chemical Agent Munitions Disposal System (CAMDS). The committee prepared an initial letter report that looked at overall closure planning as well as closure operations in progress at CAMDS. This was followed by several committee meetings to gather information and evaluate how closure planning for each of the facilities had progressed. Meetings by subgroups of the committee were also held with contractor personnel responsible for data resources relevant to closure such as the “lessons learned” program. A subgroup of the committee attended a coordination meeting of the closure managers from each facility. The committee found that closure planning is progressing under the competent leadership of the closure managers and that the facilities were sharing information and experiences with each other. However, each facility was found to be developing closure plans independently of the other facilities but within the broad guidance provided by the CMA program office and using, as appropriate, the experience of the other three facilities. Information is also being used in the planning process that was gained from the previous closure of a baseline incineration facility on Johnston Island in the Pacific Ocean near Hawaii, the Johnston Atoll Chemical Agent Disposal System (JACADS), and the more recent closures of two chemical agent disposal facilities that used chemical neutralization (hydrolysis) to destroy bulk mustard agent and VX nerve agent—the Aberdeen Chemical Agent Disposal Facility (ABCDF) in Maryland, and the Newport Chemical Agent Disposal Facility (NECDF) in Indiana. In its evaluation, the committee found that there appeared to be only limited coordination and
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities policy guidance from the senior CMA and contractor leadership. An exception is a CMA document, “Strategic Plan Fiscal Years 2010–2015,” that defines the goals of having safe closures while minimizing cost and schedule (CMA, 2009). In order to achieve this goal, the CMA document encourages the use of mass demolition wherever possible. As discussed below, the committee agrees that these are appropriate goals, but it believes that additional policy guidance from CMA in key areas is required. Finding 2-1. The closure managers and their teams appear to be highly competent and to coordinate their needs and approaches well through frequent contacts and meetings. Each site is taking its own approach to the planning activities because of differing end use, facility, and regulatory situations. There does not appear to be sufficient senior policy guidance in key issues such as the critical unventilated monitoring test. Recommendation 2-1. Senior Chemical Materials Agency management should provide policy guidance for closure in critical areas such as the unventilated monitoring test to ensure that these critical activities are planned and executed in a uniform manner across all facilities. The committee expended significant effort to evaluate the various regulatory and stakeholder challenges pertaining to closure at each of the facilities. While many of the requirements are common to all four sites, there are significant differences in both the intended end use of each site and the permit and regulatory requirements to which each site is subject. Thus, each facility will have to develop its own particular plan to meet these varying challenges. Nevertheless, the overriding principle of achieving a safe closure that meets the criteria necessary for the eventual end use does not really change from site to site. Closure is an entirely different type of operation from the agent disposal operations that have been carried out for much of the past decade and with which the staff is comfortable. Closure and demolition will require workers having different skills in addition to those residing in the current operations staff. In order to have a safe operation, both groups will have to be knowledgeable in their particular operations, especially with regard to the safety challenges involved. Closure activities will occur over a much shorter duration than will disposal operations. In order to achieve the goals of a safe closure while minimizing cost and schedule, it will be necessary for managers to set goals for a number of new management parameters and to use leading indicators to become aware of potential problems before they actually happen. The committee has provided a number of suggested parameters and metrics for the Army to consider that could help it to achieve its stated goals for the closure of these facilities. Finding 3-2. Tracking and reporting parameters and metrics will facilitate the safe and successful management of the closure of the Army’s baseline incineration chemical agent disposal facilities. Recommendation 3-2a. At a minimum, the Army should track parameters and metrics used for disposal facility closure at two levels: the program level and the project level. Thereafter, it should determine whether additional parameters and metrics are required. Recommendation 3-2b. The Army should ensure that appropriate and timely management reports are developed that enable tracking results for parameters and metrics to be used to make management decisions and take necessary actions. The Army, through its systems contractor, has developed an improved lessons learned program. This is available to all staff, both those at CMA headquarters and those at the facilities. Unfortunately, not all the lessons learned applicable to closure are in searchable form. This is particularly true of some of the lessons learned during the JACADS closure. It also seems that while there is prompt verbal communication and coordination of lessons learned concerning agent disposal operations, this may not be as true for those involving closure. It is therefore important that lessons learned relevant to closure be promptly entered into the system and be adequately highlighted to bring them to the attention of the working staff. The Army contractor for both disposal operations and closure administers an electronic database, the “eRoom,” that is a repository for plans, drawings, and reports. Access to this database is limited in that it must be requested, and a person’s access is terminated if he or she has not used the database in 60 days. The committee recognizes the sensitivity of providing access to this corporate database, yet it believes arrangements should be made to make access easier for a broader group of staff members.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Finding 4-2. Lessons learned over the course of conducting closure operations at chemical agent disposal facilities will be helpful to completing without incident future closure activities within the chemical stockpile disposal program, and they will minimize costs by reducing the time and effort needed for learning curves and training. Recommendation 4-2. The Army should continue to support the closure lessons learned processes and to encourage the prime contractor for closure operations to strengthen the timeliness and manner in which the lessons learned are shared. In this regard, it is important that all contractors on-site have access to or knowledge of the lessons learned applicable to their specific site activities. Finding 4-6. The eRoom is a very powerful information sharing and management tool, both for developing new documents and for allowing users to find information that is pertinent to a particular issue or problem. Recommendation 4-6a. The committee strongly supports the concept of the eRoom and encourages its use as often as possible. Recommendation 4-6b. The committee suggests that the Army and its contractor examine current eRoom usage and, if appropriate, develop procedures to increase its usage, including the development of new documents and determining who should have access during closure and dismantling activities. The restrictive practices that state regulatory agencies have used to address agent disposal operations at the baseline stockpile facilities were developed as operations began to destroy the chemical agents. During closure, in contrast with disposal operations, there will not be any significant amount of agent present, and there will be no munitions. Potential minimal amounts of agent can remain in occluded spaces or, even less likely, in pockets on floors and walls. Thus, the risks to human health and the environment from agent and munitions will be significantly reduced during closure from those that existed during disposal processing. This difference in risk represents a fundamental change from disposal operations to closure operations. It should provide the basis for considering less restrictive practices. Finding 5-1. The risk of exposure to chemical agents during closure operations is expected to be significantly lower than what potentially could be encountered during agent disposal operations. The regulatory standards and practices used by some states for controlling agent-contaminated materials were developed early in the program, when there was little experience with managing the risks of materials exposed to agent. These practices and regulations may be more restrictive than necessary considering the nature of the closure operations. Recommendation 5-1. The Army should evaluate the reduced risk of exposure to chemical agents and their degradation products from closure operations and waste materials in view of restrictive regulatory practices. It should also consider negotiating with the regulatory community to obtain less restrictive, but still safe, regulatory practices that allow for more efficient closure operations. The Army, in setting overall goals for the program for facilities’ closure, has opted to use mass demolition wherever possible. This depends on ensuring that all the spaces to be demolished are safe and essentially agent free, as determined by meeting agent clearance levels that provide for an environment that is safe for workers and the public. Two protocols are essential for mass demolition to be used successfully: first, the occluded space survey, followed by, second, the unventilated monitoring test (both discussed more fully in Chapter 6). Mass demolition, which enables the use of mechanical deconstruction using conventional construction equipment to remove structures and minimizes human actions required for deconstruction, should not take place until management is assured that these tasks have been accomplished properly and successfully. The committee examined both of these protocols and believes that they should be uniformly applied at every site. Further, the committee believes that a second survey should be done to verify the results of the first. In addition to uniformly applying the occluded space survey and unventilated monitoring test protocols at every site, the committee believes that guidance from senior CMA and site leadership to ensure that these protocols and steps are carried out very carefully is warranted to ensure safe operations.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Finding 6-1. The occluded space survey is a key component of the overall monitoring strategy for closure, and it requires occluded space survey teams with a high level of expertise and significant training for proper execution. Recommendation 6-1. Occluded space survey protocol should be standardized across the entire enterprise, and training should be strengthened, standardized across the program, and continually updated. Finding 6-4. Unventilated monitoring testing—conducted in sequence with site exposure and spill histories, ventilated monitoring, and occluded space surveys—is appropriately designed to ensure protection of workers and the general population from agent exposure via airborne pathways. It is the final “critical step” in clearing a site for mass demolition. Recommendation 6-4a. The Army should ensure both that the unventilated monitoring testing (UMT) protocol is uniform throughout the enterprise and that the information gained by the UMT sequence is aggressively communicated to subsequent closure sites. Recommendation 6-4b. Locations of prior exposures and spills should be compared with the results of the unventilated monitoring testing (UMT) measurements. Correlation (or not) of past exposure events with UMT release rates could provide valuable insight into residual contamination, effectiveness of occluded space surveys, and UMT efficacy. REFERENCE CMA (U.S. Army Chemical Materials Agency). 2009. Strategic Plan Fiscal Years 2010–2015 Revision 0. Aberdeen Proving Ground—Edgewood Area, MD. Washington, D.C.: Chemical Materials Agency.