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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summary The committee prepared an initial letter report that This report responds to a request by the director of the looked at overall closure planning as well as closure U.S. Army Chemical Materials Agency (CMA) for the operations in progress at CAMDS. This was followed National Research Council to examine and evaluate the by several committee meetings to gather information ongoing planning for closure of the four currently opera- and evaluate how closure planning for each of the tional baseline incineration chemical agent disposal facilities had progressed. Meetings by subgroups of facilities and the closure of a related testing facility. The the committee were also held with contractor person- report evaluates the closure planning process as well as nel responsible for data resources relevant to closure some aspects of closure operations that are taking place such as the “lessons learned” program. A subgroup of while the facilities are still disposing of agent. These the committee attended a coordination meeting of the facilities are located in Anniston, Alabama; Pine Bluff, closure managers from each facility. Arkansas; Tooele, Utah; and Umatilla, Oregon. They are The committee found that closure planning is pro - designated by the acronyms ANCDF, PBCDF, TOCDF, gressing under the competent leadership of the closure and UMCDF, respectively. Although the facilities all use managers and that the facilities were sharing informa - the same technology and are in many ways identical, tion and experiences with each other. However, each each has a particular set of challenges. facility was found to be developing closure plans Initially, the Committee to Review and Assess Clo- independently of the other facilities but within the sure Plans for the Tooele Chemical Agent Disposal broad guidance provided by the CMA program office Facility and the Chemical Agent Munitions Disposal and using, as appropriate, the experience of the other System was requested to use the programmatic closure three facilities. Information is also being used in the plan developed for the TOCDF as the basis of this planning process that was gained from the previous study. When the CMA first commissioned this study, closure of a baseline incineration facility on Johnston the TOCDF was expected to be the first of the four Island in the Pacific Ocean near Hawaii, the Johnston facilities to close. However, the anticipated order of Atoll Chemical Agent Disposal System (JACADS), closure has since changed based on when each facility and the more recent closures of two chemical agent is now expected to complete agent disposal opera- disposal facilities that used chemical neutralization tions. At the present time, it is expected that PBCDF (hydrolysis) to destroy bulk mustard agent and Vx will close first, with UMCDF, ANCDF, and TOCDF to n erve agent—the Aberdeen Chemical Agent Dis- follow. It became clear both to the committee and the posal Facility (ABCDF) in Maryland, and the New - Army that it would be advisable to examine planning port Chemical Agent Disposal Facility (NECDF) in for all four facilities and the pilot testing facility near Indiana. In its evaluation, the committee found that the TOCDF known as the Chemical Agent Munitions there appeared to be only limited coordination and Disposal System (CAMDS). 

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES policy guidance from the senior CMA and contractor schedule, it will be necessary for managers to set goals leadership. An exception is a CMA document, “Stra- for a number of new management parameters and to use tegic Plan Fiscal years 2010–2015,” that defines the leading indicators to become aware of potential prob- goals of having safe closures while minimizing cost lems before they actually happen. The committee has and schedule (CMA, 2009). In order to achieve this provided a number of suggested parameters and metrics goal, the CMA document encourages the use of mass for the Army to consider that could help it to achieve its demolition wherever possible. As discussed below, the stated goals for the closure of these facilities. committee agrees that these are appropriate goals, but Finding 3-2. Tracking and reporting parameters and it believes that additional policy guidance from CMA in key areas is required. metrics will facilitate the safe and successful manage- ment of the closure of the Army’s baseline incineration Finding 2-1. The closure managers and their teams chemical agent disposal facilities. appear to be highly competent and to coordinate their Recommendation 3-2a. At a minimum, the Army needs and approaches well through frequent contacts and meetings. Each site is taking its own approach to the should track parameters and metrics used for disposal planning activities because of differing end use, facil- facility closure at two levels: the program level and the ity, and regulatory situations. There does not appear to project level. Thereafter, it should determine whether be sufficient senior policy guidance in key issues such additional parameters and metrics are required. as the critical unventilated monitoring test. Recommendation 3-2b. The Army should ensure that Recommendation 2-1. Senior Chemical Materials appropriate and timely management reports are devel- Agency management should provide policy guidance oped that enable tracking results for parameters and for closure in critical areas such as the unventilated metrics to be used to make management decisions and monitoring test to ensure that these critical activities take necessary actions. are planned and executed in a uniform manner across all facilities. The Army, through its systems contractor, has devel- oped an improved lessons learned program. This is The committee expended significant effort to evalu- available to all staff, both those at CMA headquarters ate the various regulatory and stakeholder challenges and those at the facilities. Unfortunately, not all the pertaining to closure at each of the facilities. While lessons learned applicable to closure are in searchable many of the requirements are common to all four sites, form. This is particularly true of some of the lessons there are significant differences in both the intended end learned during the JACADS closure. It also seems that use of each site and the permit and regulatory require- while there is prompt verbal communication and coor- ments to which each site is subject. Thus, each facility dination of lessons learned concerning agent disposal will have to develop its own particular plan to meet operations, this may not be as true for those involving these varying challenges. Nevertheless, the overriding closure. It is therefore important that lessons learned principle of achieving a safe closure that meets the cri- relevant to closure be promptly entered into the system teria necessary for the eventual end use does not really and be adequately highlighted to bring them to the change from site to site. Closure is an entirely different attention of the working staff. type of operation from the agent disposal operations The Army contractor for both disposal operations that have been carried out for much of the past decade and closure administers an electronic database, the and with which the staff is comfortable. Closure and “eRoom,” that is a repository for plans, drawings, and demolition will require workers having different skills reports. Access to this database is limited in that it must in addition to those residing in the current operations be requested, and a person’s access is terminated if he staff. In order to have a safe operation, both groups will or she has not used the database in 60 days. The com- have to be knowledgeable in their particular operations, mittee recognizes the sensitivity of providing access especially with regard to the safety challenges involved. to this corporate database, yet it believes arrangements Closure activities will occur over a much shorter dura- should be made to make access easier for a broader tion than will disposal operations. In order to achieve group of staff members. the goals of a safe closure while minimizing cost and

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 SUMMARY Finding 4-2. Lessons learned over the course of conduct- Finding 5-1. The risk of exposure to chemical agents ing closure operations at chemical agent disposal facili- during closure operations is expected to be significantly ties will be helpful to completing without incident future lower than what potentially could be encountered closure activities within the chemical stockpile disposal during agent disposal operations. The regulatory stan- program, and they will minimize costs by reducing the dards and practices used by some states for controlling time and effort needed for learning curves and training. agent-contaminated materials were developed early in the program, when there was little experience with Recommendation 4-2. The Army should continue to managing the risks of materials exposed to agent. support the closure lessons learned processes and to These practices and regulations may be more restrictive encourage the prime contractor for closure operations than necessary considering the nature of the closure to strengthen the timeliness and manner in which the operations. lessons learned are shared. In this regard, it is important Recommendation 5-1. The Army should evaluate that all contractors on-site have access to or knowledge of the lessons learned applicable to their specific site the reduced risk of exposure to chemical agents and activities. their degradation products from closure operations and waste materials in view of restrictive regulatory Finding 4-6. The eRoom is a very powerful informa- practices. It should also consider negotiating with the tion sharing and management tool, both for developing regulatory community to obtain less restrictive, but still new documents and for allowing users to find informa- safe, regulatory practices that allow for more efficient tion that is pertinent to a particular issue or problem. closure operations. Recommendation 4-6a. The committee strongly sup- The Army, in setting overall goals for the program ports the concept of the eRoom and encourages its use for facilities’ closure, has opted to use mass demolition as often as possible. wherever possible. This depends on ensuring that all the spaces to be demolished are safe and essentially agent Recommendation 4-6b. The committee suggests that free, as determined by meeting agent clearance levels the Army and its contractor examine current eRoom that provide for an environment that is safe for workers u sage and, if appropriate, develop procedures to and the public. Two protocols are essential for mass increase its usage, including the development of new demolition to be used successfully: first, the occluded documents and determining who should have access space survey, followed by, second, the unventilated during closure and dismantling activities. monitoring test (both discussed more fully in Chapter 6). Mass demolition, which enables the use of mechani- The restrictive practices that state regulatory agen- cal deconstruction using conventional construction cies have used to address agent disposal operations equipment to remove structures and minimizes human at the baseline stockpile facilities were developed as actions required for deconstruction, should not take operations began to destroy the chemical agents. Dur- place until management is assured that these tasks ing closure, in contrast with disposal operations, there have been accomplished properly and successfully. will not be any significant amount of agent present, and The committee examined both of these protocols and there will be no munitions. Potential minimal amounts believes that they should be uniformly applied at every of agent can remain in occluded spaces or, even less site. Further, the committee believes that a second sur- likely, in pockets on floors and walls. Thus, the risks vey should be done to verify the results of the first. In to human health and the environment from agent and addition to uniformly applying the occluded space sur- munitions will be significantly reduced during closure vey and unventilated monitoring test protocols at every from those that existed during disposal processing. site, the committee believes that guidance from senior This difference in risk represents a fundamental change CMA and site leadership to ensure that these protocols from disposal operations to closure operations. It and steps are carried out very carefully is warranted to should provide the basis for considering less restrictive ensure safe operations. practices.

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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 compo- Recommendation 6-4a. The Army should ensure nent of the overall monitoring strategy for closure, and it both that the unventilated monitoring testing (UMT) requires occluded space survey teams with a high level of protocol is uniform throughout the enterprise and expertise and significant training for proper execution. that the information gained by the UMT sequence is aggressively communicated to subsequent closure Recommendation 6-1. Occluded space survey proto- sites. col should be standardized across the entire enterprise, Recommendation 6-4b. Locations of prior exposures and training should be strengthened, standardized across the program, and continually updated. and spills should be compared with the results of the unventilated monitoring testing (UMT) measurements. Finding 6-4. Unventilated monitoring testing—con- Correlation (or not) of past exposure events with ducted in sequence with site exposure and spill his- UMT release rates could provide valuable insight into tories, ventilated monitoring, and occluded space residual contamination, effectiveness of occluded space surveys—is appropriately designed to ensure protec- surveys, and UMT efficacy. tion of workers and the general population from agent exposure via airborne pathways. It is the final “critical reFereNce step” in clearing a site for mass demolition. 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.