Summary

As the result of disposal practices from the early to mid-twentieth century, approximately 250 sites in 40 states, the District of Columbia, and 3 territories are known or suspected to have buried chemical warfare materiel (CWM). Much of this CWM is likely to occur in the form of small finds that necessitate continuation of the Army’s capability to transport treatment systems to such locations for destruction.1 Of greatest concern for the future are sites in residential areas (e.g., the now urban Spring Valley section of Washington, D.C.) and large sites on legacy military installations such as Redstone Arsenal, Alabama, where over 5 miles of disposal trenches have been identified.

Neither the Chemical Weapons Convention (CWC) treaty (CWC, 1997) nor existing CWM domestic legislation requires recovery of buried CWM, but pressure to do so is becoming more intense. The cost of characterization, remedy selection, and even containment of these large buried CWM sites is likely to be significant. The upper-end estimate for completely recovering and destroying buried CWM at Redstone Arsenal in Alabama alone is estimated to be several billion dollars. Although it is impossible at this time to predict the ultimate cost of completely remediating all buried CWM, the Department of Defense (DOD) should initially plan for multi-billion-dollar costs over several years.

The Army mission regarding the remediation of recovered chemical warfare materiel (RCWM) is turning into a program much larger than the existing munition and hazardous substance cleanup programs. The organizational structure being used by the Army to achieve its original mission of handling ad hoc CWM finds consists of about a dozen organizations within the Army and several offices within the DOD. For example, different offices design and acquire the specialized CWM destruction and other equipment; other offices operate the equipment; another unit transports the equipment and personnel; and various offices within the U.S. Army Corps of Engineers (USACE) and the Offices of the Secretary of the Army and of the Secretary of Defense play significant roles in setting policy, obtaining federal funding, prioritizing sites for remediation, and participating in remedy selection decisions with regulators.

In the committee’s view, the Army asked the National Research Council (NRC) to examine this evolving mission in part because this change in mission is significant and becoming even more prominent as the stockpile destruction is nearing completion. One focus of the study has been the current and future status of the Non-Stockpile Chemical Material Project (NSCMP), which now plays a central role in the remediation of recovered chemical warfare materiel and which reports to the Chemical Materials Agency (CMA). The tasks that were presented in the statement of task inherently required a review of funding based on the committee’s interpretation of the statement of task, discussions with Army and Office of the Secretary of Defense (OSD) personnel, and the link between organizational efficiency and funding for DOD missions. In addition to examining the organizations and their roles and the funding, the NRC was asked to review the technology tools now used in the detection, excavation, packaging, storage, transportation, assessment, and destruction of buried CWM and the tools that may be needed in the future. The full statement of task is set forth in Chapter 1. The committee’s main responsibilities were as follows:

•  Survey the organizations involved with remediation of suspected CWM disposal sites to determine current practices and coordination.

•  Review current supporting technologies for cleanup of CWM sites.

•  Identify potential deficiencies in operational areas based on the review of current supporting technologies for cleanup of CWM sites and develop options for targeted research and development efforts to mitigate potential problem areas.

•  Suggest means by which the coordination among organizations involved in conducting investigations,

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1This rapid, short-term response is often called the “firehouse” function.



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Summary As the result of disposal practices from the early to mid- Secretary of the Army and of the Secretary of Defense play twentieth century, approximately 250 sites in 40 states, the significant roles in setting policy, obtaining federal funding, District of Columbia, and 3 territories are known or suspected prioritizing sites for remediation, and participating in remedy to have buried chemical warfare materiel (CWM). Much of selection decisions with regulators. this CWM is likely to occur in the form of small finds that In the committee’s view, the Army asked the National necessitate continuation of the Army’s capability to trans- Research Council (NRC) to examine this evolving mission port treatment systems to such locations for destruction.1 Of in part because this change in mission is significant and greatest concern for the future are sites in residential areas becoming even more prominent as the stockpile destruction (e.g., the now urban Spring Valley section of Washington, is nearing completion. One focus of the study has been the D.C.) and large sites on legacy military installations such as current and future status of the Non-Stockpile Chemical Redstone Arsenal, Alabama, where over 5 miles of disposal Material Project (NSCMP), which now plays a central role trenches have been identified. in the remediation of recovered chemical warfare materiel N either the Chemical Weapons Convention (CWC) and which reports to the Chemical Materials Agency (CMA). treaty (CWC, 1997) nor existing CWM domestic legisla- The tasks that were presented in the statement of task inher- tion requires recovery of buried CWM, but pressure to do ently required a review of funding based on the committee’s so is becoming more intense. The cost of characterization, interpretation of the statement of task, discussions with Army remedy selection, and even containment of these large bur- and Office of the Secretary of Defense (OSD) personnel, and ied CWM sites is likely to be significant. The upper-end the link between organizational efficiency and funding for estimate for completely recovering and destroying buried DOD missions. In addition to examining the organizations CWM at Redstone Arsenal in Alabama alone is estimated to and their roles and the funding, the NRC was asked to review be several billion dollars. Although it is impossible at this the technology tools now used in the detection, excavation, time to predict the ultimate cost of completely remediating packaging, storage, transportation, assessment, and destruc- all buried CWM, the Department of Defense (DOD) should tion of buried CWM and the tools that may be needed in the initially plan for multi-billion-dollar costs over several years. future. The full statement of task is set forth in Chapter 1. The The Army mission regarding the remediation of recovered committee’s main responsibilities were as follows: chemical warfare materiel (RCWM) is turning into a pro- • gram much larger than the existing munition and hazardous Survey the organizations involved with remediation substance cleanup programs. The organizational structure of suspected CWM disposal sites to determine cur- being used by the Army to achieve its original mission rent practices and coordination. • of handling ad hoc CWM finds consists of about a dozen Review current supporting technologies for cleanup organizations within the Army and several offices within the of CWM sites. • DOD. For example, different offices design and acquire the Identify potential deficiencies in operational areas specialized CWM destruction and other equipment; other based on the review of current supporting technolo- offices operate the equipment; another unit transports the gies for cleanup of CWM sites and develop options equipment and personnel; and various offices within the U.S. for targeted research and development efforts to Army Corps of Engineers (USACE) and the Offices of the mitigate potential problem areas. • Suggest means by which the coordination among organizations involved in conducting investigations, 1This rapid, short-term response is often called the “firehouse” function. 1

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2 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL recoveries, and cleanup activities concerning non- around the site is monitored for agent. Qualified personnel stockpile CWM can be made more efficacious and remove and evaluate the suspected CWM and package it in effective. a container approved for on-site transport to an installation bunker or an interim holding facility (IHF). The suspected CWM will then be removed from storage ORGANIZATIONS INVOLVED IN THE REMEDIATION OF and a mobile munitions assessment system (MMAS) sent to CWM DISPOSAL SITES the site to provide a nonintrusive assessment of its contents. The NSCMP is the key provider of services and equip- The key MMAS tools are these: ment for CWM destruction, both planned and in response to • emergencies. In planned response operations such as those Digital radiography and computed tomography in Spring Valley in Washington, D.C., and Camp Sibert in (DRCT), • Alabama, NSCMP would normally operate under the direc- Portable isotopic neutron spectroscopy (PINS), and • tion of a project manager from the USACE. In emergency Raman spectrometer. response operations, such as remediating the 75-mm chemi- cal munitions discovered at Dover Air Force Base, Delaware, The RCWM is again placed in interim storage to await it would operate under its own direction. review of the assessment by the MARB. In this scenario, the The NSCMP is responsible for managing all projects for IHF may be off-site. If transport is required, the RCWM is the assessment and disposal of RCWM. Activities include packaged in a multiple round container (MRC) that has been identification of assessment and disposal costs, disburse- certified by the Department of Transportation and can then ment of funds for assessment and disposal, and preparation be carried over public roads by CARA. of project schedules. The NSCMP prepares the relevant After the contents have been assessed by the MARB, d ocumentation and obtains the approvals needed. The t hey are destroyed or treated by one of the following documents include the site plan, the site safety submission, technologies: the destruction plan, and the environmental permits. If a • recovered munition is identified as a possible chemical fill, Explosive destruction system (EDS), • all information germane to that munition must be forwarded Transportable detonation chamber (TDC), • to the Materiel Assessment Review Board (MARB), which Detonation of ammunition in a vacuum integrated conducts an assessment of the munition to determine its chamber (DAVINCH), or • chemical fill and explosive configuration. The NSCMP has Static detonation chamber (SDC). responsibility for satisfying the obligations of the CWC. NSCMP provides the equipment used for assessment, If the RCWM is a chemical agent identification set storage, and destruction of recovered munitions, and it has (CAIS), the single CAIS access and neutralization system an active, ongoing program to improve this equipment and (SCANS) is used to destroy the CAIS. Secondary waste is to develop new technologies. transported to a commercial facility for final disposal. In addition to the NSCMP, the MARB, and the USACE, The committee had no recommendations to make on any other organizations are involved in hands-on aspects of reme- research and development for the following aspects of the diation of buried CWM: the 20th Support Command Chemi- aforementioned technologies: cal, Biological, Radiological, Nuclear and Explosives Ana- • lytical and Remediation Activity (CARA); the Edgewood Geophysical detection . Other organizations have Chemical and Biological Center (ECBC); the U.S. Army large R&D programs under way in this area. The best Technical Center for Explosives Safety (USATCES); and the policy for NSCMP is to track developments in these Department of Defense Explosives Safety Board (DDESB). programs. • Personal protective equipment. No needs identified. • Conventional excavation equipment . No needs TECHNOLOGIES FOR REMEDIATION OF BURIED CWM identified. • The committee’s other main responsibilities involved CWM packaging and transportation. As described (1) the review of the technologies now in use for cleanup in Chapter 4, the NSCMP is developing a universal of CWM sites and identification of any deficiencies and (2) munitions storage container. It is fabricated from the development of recommendations for targeted research high-density polyethylene, and its use will allow and development to correct these deficiencies. Many tech- the destruction of overpacked munitions in the EDS nologies are employed, as exemplified by a typical project without removing them from the overpack. No addi- in which suspected subsurface CWM are located through tional R&D needs identified. • the application of geophysical technologies, typically mag- CWM storage. No needs identified. • netometry or active electromagnetic sensors. An object is SCANS. No needs identified. • uncovered by mechanized or manual excavation and the air DRCT. No needs identified.

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3 SUMMARY • qualified. Future large remediation projects, e.g., Redstone DAVINCH or TDC detonation technologies . No Arsenal, might entail assessing tens or hundreds of thou - needs identified, although improvements to or refine- sands of munitions or opened munitions. When dealing ment of the technology might be justified, depending with such large quantities, the current PINS/DRCT/MARB on the application. approach may not be able to carry out its assessments in a sufficiently timely fashion, and the results may not be TARGETED RESEARCH AND DEVELOPMENT ON sufficiently accurate to guarantee the safety of treatment REMEDIATION TECHNOLOGIES equipment operators. Targeted research and development options were recom- Recommendation 6-4. The Non-Stockpile Chemical Mate- mended in a number of areas. riel Project should recommend modifications to the current P INS/DRCT/MARB assessment approach or adopt an Robotic Excavation Equipment alternative approach that will function more quickly and with more definitive and more accurate results when tens of Robotic technology has continued to grow in versatility thousands or hundreds of thousands of munitions are to be and reliability. The committee judges that further investiga- assessed at a single site. tion in and development of this technology for use in the remediation of buried chemical materiel would be fruitful. Destruction of Contaminated RCWM Recommendation 6-1. The Army should demonstrate that As noted above, the committee did not identify any areas robotic systems can be reliably utilized to access and remove of research for two of the four explosive destruction tech- buried chemical warfare materiel, and, where applicable, it nologies—the DAVINCH and the TDC—available for treat- should use them. ment of RCWM. It did, however, identify areas of research for the EDS and the SDC. Air Monitoring As a detected subsurface object is excavated, the air in the Explosive Destruction System area is monitored for agent. The Miniature Chemical Agent The NSCMP has a substantial product improvement Monitoring System (MINICAMS) is used for this purpose, program under way to increase the capabilities of the EDS, but it is a fragile system, not sufficiently robust to be moved including the use of steam injection to decrease cycle time from anomaly to anomaly. This results in long downtimes. and the identification of a universal reagent that will be effec- A more rugged and portable system for near-real-time air tive for neutralization of all chemical warfare agents. monitoring is needed to reduce downtime. The multiagent meter now being developed by NSCMP might fit this need. Dynasafe Static Detonation Chamber Assessment of Recovered Munitions The committee judges that the Dynasafe technology is a viable approach to processing large numbers—tens or hun- Before RCWM can be destroyed, each item is assessed dreds of thousands—of burned and open chemical munition to determine the nature of the contained agent and energet- bodies that might contain residual agent or energetics. ics. The noninvasive analytical method used for this purpose As described in Chapter 4, many problems were encoun- is PINS. While PINS is an essential tool in the assessment tered as the SDC 1200 was operating on chemical munitions of recovered munitions, it is not totally reliable. Munitions at the Anniston Chemical Agent Disposal Facility (ANCDF), have been misidentified, and improvements are needed in and work was begun on correcting these problems. One the PINS analytical method to provide more definitive infor- such problem was the sometimes incomplete combustion mation for the identification of chemical fills in recovered of carbon monoxide. Since then, Dynasafe has enlarged the munitions. thermal oxidizer for its SDC 1200s. This will allow better Recommendation 6-3. Research and development should control of excess oxygen and hence more reliable combus- tion of carbon monoxide. continue on the processing of data from portable isotopic neutron spectroscopy to provide more definitive information Recommendation 6-5. The Non-Stockpile Chemical Mate- for the identification of chemical fills in recovered munitions. riel Project should investigate the benefits of the larger thermal oxidizer now used in Dynasafe’s standard SDC After conducting the PINS analysis for fill and explosive 1200. If, as expected, the larger oxidizer aids in controlling content, the MARB reviews all available information for excess oxygen, leading to the more complete and consistent each RCWM and presents its assessment. The procedure is combustion of carbon monoxide, the project should con- involved and lengthy and the results are sometimes heavily

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4 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL sider replacing the current thermal oxidizer with the larger materiel, including burned and previously opened munition oxidizer. bodies that still contain detectable traces of agent and agent- contaminated scrap metal. This evaluation should include Since the SDC system was started up, it has become possible modifications to the SDC feed system, changes in clear that the spray dryer is not effective at preventing the the residence time in the SDC chamber, and changes to its formation of dioxins and furans, and the activated carbon off-gas treatment system. adsorbers in the off-gas treatment system must be depended on to capture the dioxins and furans formed there. Also, the CURRENT FUNDING AND ORGANIZATION FOR solids formed in the spray dryer sometimes accumulate on its EXECUTION OF THE RCWM PROGRAM interior walls. Eliminating the spray dryer and using a heat exchanger to cool the hot gases from the detonation chamber, As noted, the existing structure utilized by the Army, in its as is done in the CH2M HILL TDC process, might improve capacity as executive agent for destruction of non-stockpile the reliability of the process. chemical materiel, must now be reconfigured to prepare for the remediation of CWM at over 250 sites in the United States. Recommendation 6-6. The Non-Stockpile Chemical Mate- The current organizational structure was set on March 1, riel Project should evaluate the costs and benefits of improv- 2010, when the Under Secretary of Defense for Acquisition, ing the reliability of the Dynasafe static detonation chamber Technology and Logistics [USD(AT&L)] formally desig- system by replacing the spray dryer with a water-cooled heat nated the Secretary of the Army as executive agent for the exchanger and continuing to rely on activated carbon adsorb- RCWM program (see Appendix C). In 2011 the Army estab- ers to capture the dioxins and furans formed as off-gas from lished a provisional RCWM integrating office to integrate, the thermal oxidizer is cooled. If disposal of liquid waste coordinate, and synchronize the DOD’s RCWM response (i.e., spent scrubber solution) becomes a problem, the Non- program and related activities. The USD(AT&L) memo Stockpile Chemical Materiel Project should consider replac- required the Army to prepare and submit to the DOD a final ing the caustic scrubbers with a dry lime injection system. implementation plan for the RCWM program. As of April 30, 2012, neither the responsible officials within the Office A major process improvement program for the Dynasafe of the Secretary of Defense—the Deputy Under Secretary of SDC 1200 system was under way at the ANCDF as this Defense for Installations and Environment [DUSD(I&E)], report was being written. This program was well planned the Office of the OSD comptroller, and the Assistant Secre- and was expected to increase the reliability of the process. tary of Defense (Nuclear, Chemical, and Biological Defense) [ASD(NCB)]—nor the responsible officials within the Army Recommendation 6-7. The Non-Stockpile Chemical Mate- had completed the task assigned to them by the USD(AT&L) riel Project should continue its efforts to improve throughput memorandum of March 1, 2010. and reliability of the Dynasafe static detonation chamber Recommendation 7-1. The Army should formally approve, system. then submit, a final implementation plan for the recovery and Some of the RCWM at large burial sites will not contain destruction of buried chemical warfare materiel as required energetics such as bursters and fuzes but may still con - by the Under Secretary of Defense for Acquisition, Technol- tain detectable quantities of agent. Many options exist for ogy and Logistics in its memorandum of March 1, 2010. decontaminating these items to either the ≤1 vapor screening level (VSL) or to the suitable for unrestricted release level, Funding Issues including the following: Three major funding programs may come into play at an • Processing through high-temperature furnaces, RCWM remediation site: Chemical Agent and Munitions including furnaces similar to those used in stockpile Disposal, Defense (CAMD,D); Defense Environmental chemical weapon plants. Restoration Program (DERP); and Operations and Mainte- • Processing through a commercial transportable haz- nance (O&M). The committee was informed of the following ardous waste incinerator. funding practices: • Processing through a car bottom furnace. • • Treating with decontamination solution until a head- CAMD,D funding is used for the Chemical Stockpile space agent concentration of <1 VSL is achieved. Elimination (CSE), the NSCMP, and other projects. • Using the Dynasafe SDC 1200, as noted above. As is the case for other budget elements, the Presi- dent’s budget request for the project is authorized and Recommendation 6-8. The Non-Stockpile Chemical Mate- appropriated annually by Congress. The President’s riel Project should evaluate the Dynasafe static detonation budget request includes annual budget estimates for chamber for its ability to destroy recovered chemical warfare the following 4 years and, when available, the esti-

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5 SUMMARY mated cost to complete the project. All are subject to Secretary of the Army for Installations, Energy and Environ- change. Annual funding for the program beyond 2017 ment [ASA(IE&E)] for DERP and O&M, as shown in Figure has not been determined; however, the cost and time S-1. Thus, there is no single advocate for the program. In to complete the program were recently estimated to addition, at present the NSCMP must compete annually for exceed the previous estimate by about $2 billion and funding from the CAMD,D budget account, which is also 2 years.2 the source of funding for the much larger chemical stockpile • DERP is a very broad program encompassing fund- destruction program. Not only have estimates for complet- ing for early site investigation and characterization ing the stockpile program been extended to 2021-2023, they have also increased significantly.3 As the stockpile program t hrough funding for remediation, including, by definition, chemical warfare agents and chemical nears completion, the CAMD,D account can be expected to munitions. DERP funds are commonly used for come under increasing pressure for significant reductions, if conventional munitions cleanup at RCWM sites for not total elimination. The long-term funding and oversight site characterization and remediation up to the point issues inherent in a growing and enduring RCWM remedia- of the identification of RCWM munitions. Once tion mission need to be addressed and an enduring funding RCWM is discovered, DERP funding can no longer stream established that is integrated with other enduring be used and funding from CAMD,D is then used for environmental remediation programs. the assessment and remediation of the RCWM. • Recommendation 7-3. The Office of the Secretary of O&M funding, in the context of RCWM, is used for the O&M of active training ranges for each of the Defense and the Army should each select a single office to military services, including environmental restora- champion and fund remediation of all RCWM. tion of the ranges. Like funding for DERP, O&M funding is not used to assess and remediate RCWM Of the known large burial sites, only at Redstone Arsenal on active training ranges. Rather, CAMD,D funding (RSA) has an effort been made to assemble a comprehen- is employed. sive inventory of suspected buried munitions and sites (see Chapter 5). The remediation of buried munitions (including DOD (and the Army as the RCWM executive agent) CWM) is not clearly defined, in part because the inventory adhere carefully to congressional direction on the use of of suspected buried munitions and sites is incomplete. The these appropriations. However, the committee notes that the lack of an accurate inventory of the buried munitions and of current practice of not allowing the use of DERP and O&M a reliable cost estimate for the RCWM program limits the funding for RCWM assessment and remediation might not ability of the DUSD(I&E) and the comptroller in consulta- be a statutory requirement. tion with the ASD(NCB) and the Army to establish budget requirements and draw up an appropriate funding plan for a Recommendation 7-2. The Secretary of Defense should new and separate RCWM account. seek a legal interpretation of the perceived prohibition on Recommendation 7-4a. The Secretary of Defense should, s pending Defense Environmental Restoration Program (DERP) and Operations and Maintenance (O&M) funds to as a matter of urgency, increase funding for the remediation assess and remediate recovered chemical warfare materiel. of chemical warfare materiel to enable the Army to complete If it is determined that only Chemical Agents and Munitions the inventories of known and suspected buried chemical Destruction, Defense (CAMD,D) funds may be used for munitions no later than 2013 and develop a quantitative basis RCWM assessment and remediation, the Secretary should for overall funding of the program, with updates as needed seek legislative authority to change this stricture in order to facilitate accurate budget forecasts. Pending establishment to permit the commingling of DERP, O&M, and CAMD,D of a final RCWM management structure, this task should be funding for these RCWM activities. assigned to the director of the CMA as chair of the provi- sional RCWM integrating office. Authority and funding for RCWM activities, depending Recommendation 7-4b. As the RCWM executive agent, on how and where CWM is discovered, emanate from two OSD and two Army Secretariat offices. The two OSD offices the Secretary of the Army should establish a policy that are the ASD(NCB) for CAMD,D and the DUSD(I&E) for addresses all aspects of the remediation of chemical warfare DERP and O&M. The two Army Secretariat offices are the materiel and that prioritizes remediation requirements, and Assistant Secretary of the Army for Acquisition, Logistics, the Secretary of Defense should identify a new long-term and Technology [ASA(ALT)] for CAMD,D and the Assistant funding source to support the program. 2U.S. Army 3U.S. Army Element, Assembled Chemical Weapons Alternatives, press Element, Assembled Chemical Weapons Alternatives, press release “Department of Defense approves new cost and schedule estimates release “Department of Defense approves new cost and schedule estimates for chemical weapons destruction plants.” Aberdeen Proving Ground, Md., for chemical weapons destruction plants.” Aberdeen Proving Ground, Md., April 17, 2012. April 17, 2012.

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6 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL = Command = Funding SECRETARY OF DEFENSE ASD(NCB) USD(AT&L) DUSD(I&E) SECRETARY OF ASA(ALT) ASA(IE&E) THE ARMY CHIEF OF STAFF, DASA(ESOH) DASA(ECW) ARMY FORSCOM ACSIM/IMCOM AMC 20th Support CMA Command NSCMP CARA USACE USAEC FIGURE S-1 Current organization for policy, oversight, and funding for RCWM. DASA(ECW), Deputy Assistant Secretary of the Army for Elimination of Chemical Weapons; DASA(ESOH), Deputy Assistant Secretary of the Army (Environment, Safety and Occupational Health); AMC, U.S. ArmyIGURE S-1 Current organization for (U.S. Army); ACSIM/IMCOM,funding.eps Staff, Installation F Materiel Command; FORSCOM, Forces Command policy, oversight, and Assistant Chief of Management/Installation Management Command (U.S. Army); USAEC, U.S. Army Environmental Command. Recommendation 7-5. The Deputy Under Secretary of main player is the ACSIM office, and its field operating agency, IMCOM. The committee judges that the ACSIM Defense for Installations and Environment and the Under and IMCOM are performing a creditable job of integrat- Secretary of Defense, Comptroller, in coordination with the ing the Army’s cleanup requirements, including DERP and Assistant Secretary of Defense for Nuclear, Chemical, and CAMD,D, and presenting them in a defendable POM and Biological Programs and the Army, should proceed imme- budget. Some remaining duplication of effort on the part of diately to establish a separate budget account for recovered IMCOM’s Army Environmental Command (AEC) and the chemical warfare materiel, as directed by the memorandum USACE merits the Army’s attention. of the Under Secretary of Defense for Acquisition, Technol- ogy and Logistics dated March 1, 2010, and to ensure that Recommendation 7-6. T he Army should examine the funding requirements for the recovered chemical warfare RCWM roles and responsibilities to determine where money materiel program are included in the FY 2014-2018 Program can be saved by eliminating duplication of functions, such Objectives Memorandum (POM). as those of the Army Environmental Command and the U.S. Army Corps of Engineers. Organization for Execution At the OSD level, two major offices, ASD(NCB) and Provisional RCWM Integrating Office DUSD(I&E), work on RCWM policy and funding matters The provisional RCWM integrating office (IO) coordi- (Figure S-2). Within the Department of the Army, two sec- nates emergency response and planned RCWM projects for retariat (i.e., policy) offices—ASA(IE&E) and ASA(ALT)— DOD in keeping with the Army’s roles as RCWM executive have been very involved with the RCWM program. The agent. The member organizations are shown as the integrated Army would assign responsibility to ASA(IE&E), which product team in Figure S-2. The provisional RCWM IO has has enabled the Army to begin setting up a long-term orga- conducted some meetings while it awaits formal approval by nization to lead the program. At the Army staff level, the

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7 SUMMARY SECRETARY OF Executive Agent THE ARMY ASA (IE&E) DASA (ESOH) Executive ACSIM/ FORSCOM AMC USACE Management IMCOM Structure 20th Support RDECOM CMA Command Provisional RCWM IO Air NAVY Force Integrated Huntsville CARA ECBC NSCMP AEC BRAC Engineering and Product Team Support Center FIGURE S-2 RCWM Army execution structure. RDECOM, Research, Development, and Engineering Command; BRAC, base realignment and closure. SOURCE: Adapted from the presentation of J.C. Army the committee on September 26, 2011. FIGURE S-2 RCWM King to execution structure.eps the Army and DOD. The committee considers the establish- Center and the Chemical Biological Radiological Nuclear ment of the provisional IO to be a step in the right direction (Enhanced) Analysis and Remediation Activity with the in the overall management of the program but has some objective of eliminating any overlapping functions, particu- significant concerns. In brief, the provisional RCWM IO larly on emergency response activities. leader lacks directive authority, is placed too low in the Army Recommendation 7-8. The Army should review the long- organization, and is too junior in rank to be held accountable for the execution of the RCWM program. term requirements for executing the RCWM program with The CMA’s NSCMP and the USACE’s Huntsville Engi- the objective of making organizational changes that will neering and Support Center are key players for the execution eliminate duplication of effort and ensure sustainable orga- of both emergency responses and planned RCWM projects. nizational integrity. NSCMP has depth in project planning and technology utilization, while USACE has hands-on technical skills in ORGANIZATIONAL ALTERNATIVES RCWM project management, construction management, and contract management. The committee is also concerned Based on the findings and recommendations above, the that CMA may not have a sustaining role in the Army once committee evaluated two significant organizational changes the stockpile program winds down in the next several years, to the baseline organization (Figure S-2) to improve the leaving NSCMP without an enduring higher authority to efficiency, effectiveness, and accountability of the RCWM report to. These factors bring significant risk and uncertainty program and its leadership. to the RCWM program, raising the possibility that emer- In light of the committee’s conclusion that the IO and gency responses or large planned remediation projects will its leadership lack directive authority and are placed too not have adequate or sustainable management and funding low in the Army organization, the first change addresses the support. provisional IO and the accountability and effectiveness of its leadership. As discussed in Chapter 7, the grade of the Recommendation 7-7. The Army should reexamine the RCWM IO leader, GS-15, is too low to allow recruitment of roles and responsibilities of Edgewood Chemical Biological an individual who can effectively lead the program. The com-

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8 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL 1. SINGLE ACCOUNT FOR SITE REMEDIATION (Would comingle DERP, RCWM, & O&M) 2. INTEGRATED PROGRAM PLAN AND BUDGET (RCWM) a. Required RCWM emergency response infrastructure b. Research and Development, technology, procurement c. Planned remediation support d. Response to emergency response contingencies 3. INTEGRATED DOD PRIORITY LIST FOR POTENTIAL RCWM REMEDIATION 4. COORDINATED FIVE YEAR PROGRAM PLAN AND BUDGET ESTIMATE FOR REMEDIATION OF IDENTIFIED PRIORITY RCWM SITES CONGRESS Program, Planning, Budget & Execution Oversight, OMB Guidance, Management, and Direction DOD (DUSD, I&E) ARMY RCWM Program (ASA, IE&E) Executive RCWM OIPT ACSIM (POM Consolidation) IRP / MMRP BRAC FUDS RANGE RCWM O&M DERP DERP BRAC RCWM FIGURE S-3 RCWM program future funding. FIGURE S-3 RCWM programhefuture sought a reporting level within the Army T committee funding.eps mittee further concluded that the position should be upgraded to a civilian SES or a military general officer. at which this program executive would be most effective and concluded that the best reporting relationship would be for the Recommendation 7-9. The Secretary of the Army should program executive to report directly to the ASA(IE&E), giv- establish a new position at the level of the Senior Executive ing him or her the organizational reach and authority needed Service (civilian) or a general officer (military) to lead the to lead the program effectively. The new RCWM OIPT, com- RCWM program. The person who fills this position would posed of higher-level representatives of the organizations in report directly to the Assistant Secretary of the Army (Instal- the current provisional RCWM IO and appropriate members lations, Energy and Environment). The Secretary should dele- from OSD, would replace the provisional RCWM IO. OIPT gate full responsibility and accountability for RCWM program members should be fairly senior in grade, knowledge, and experience, and their parent organizations should give them performance to this person, including for programming, plan- ning, budgeting, and execution and for day-to-day oversight, authority to make decisions (see Figure S-3). guidance, management, and direction of the program. The second organizational change evaluated by the com- mittee involved the organizations executing the RCWM As previously recommended, the RCWM program program. The committee evaluated several alternatives for requires a leader at the civilian SES or military general offi- the long-term reporting relationship for the NSCMP and cer level who is assigned overall responsibility and account- selected one that would provide continuity of program ability for program performance. This person would have execution, cost-effective synergy, and an enduring reporting directive authority over other program participants within organizational relationship for NSCMP. the Army and, through agreements with the other Services, Recommendation 7-10. The Army should realign the non- within appropriate RCWM activities of the Air Force and Navy and would establish, chair, and direct a new overarch- stockpile chemical materiel program from the Army Materiel ing integrated product team (OIPT) for RCWM. Command/Chemical Materials Agency to the U.S. Army

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9 SUMMARY Command Tasking Authority Coordination SECRETARY OF ASA (ALT) ASA (IE&E) THE ARMY RCWM PROGRAM CHIEF OF STAFF, DASA (ECW) EXECUTIVE ARMY RCWM OIPT ACSIM/ USACE AMC FORSCOM IMCOM Huntsville 20th Engineering CMA RDECOM Support and Support Command Center ECBC CARA AEC BRAC NSCMP FIGURE S-4 Army RCWM organization and authority recommended by committee. NOTE: Tasking authority is the authority of the RCWM FIGURE S-4 Realignment of the NSCMP.eps Program Executive with respect to day-to-day oversight, guidance, management, and direction of Army elements on all RCWM matters, including program and budget planning and allocation, and program and budget execution and performance by the RCWM commands, agencies, and organizations. Corps of Engineers Huntsville Engineering and Support to exercise oversight, management, and provide fiscal and Center. operational guidance and direction to the operating elements of the RCWM and control the funds for RCWM, both during Recommendation 7-11. To provide for an effective transi- development and defense of the program plan and budget, tion, the new program executive should enter into a memo- and during the execution of the annual program. randum of understanding with the Commander of the U.S. The committee’s recommendations for RCWM program Army Corps of Engineers and the Army Materiel Command/ and budget planning are illustrated in Figure S-3. Chemical Materials Agency outlining the reporting ladder Once the new RCWM program executive position and and transition plan for the realignment of the non-stockpile the recommended OIPT are set up, the Army can begin chemical materiel program. transitioning the alignment of NSCMP from AMC/CMA to the USACE Huntsville Center. The committee believes that the assignment of an SES Recommendation 7-12. As a necessary first step the Deputy civilian or general officer RCWM program executive with full authority and responsibility for planning, programming, Under Secretary of Defense for Installations and Environ- budgeting, and execution for the RCWM program, who has ment, the Under Secretary of Defense Comptroller, the direct access to and visibility at the highest levels of the Assistant Secretary of Defense for Nuclear, Chemical, and Department of the Army and the OSD secretariat is abso- Biological Programs, and the Secretary of the Army should lutely critical to the future success of the program. It will be proceed immediately to implement the guidelines contained vital to the effectiveness of the program executive and the in the March 1, 2010, memorandum from the Under Secre- program that the executive possess the authority and ability tary of Defense for Acquisition, Technology and Logistics.

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10 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL The committee’s recommended structure for Army at active operational ranges, (3) management of remediation RCWM organization and authority is shown in Figure S-4, wastes using corrective action management units (CAMUs), which incorporates the recommended program executive (4) the need to store hazardous wastes for longer than 90 organization with the civilian SES or military general officer- days under a RCRA corrective action, and (5) identifying level RCWM program executive reporting to the ASA(IE&E); regulatory approval mechanisms for the use of explosive the RCWM OIPT under the direction of the RCWM program destruction technologies to destroy RCWM. executive; the tasking authority of the RCWM program exec- The committee also noted the importance of public utive; and the realignment of NSCMP under the USACE. participation in Army policy decisions regarding RCWM The figure also delineates the lines of command, tasking remediation. Public involvement is embedded in both RCRA authority, and coordination among the various elements of and CERCLA, in the Emergency Planning and Community the program. Right-to-Know Act (EPCRA), and in DOD and Army regu- lations and policies. For the remediation project at Spring Valley in Washington, D.C., for example, partnering and REGULATORY ISSUES planning were shown to be key to minimizing unnecessary The history of the stockpile and non-stockpile programs delay and costs. Findings and recommendations related to demonstrates that regulatory concerns and a failure to regulatory issues and public involvement can be found in involve the public can significantly delay implementation Chapter 3. and increase costs. Much of the regulatory experience gained in the implementation of the stockpile and non-stockpile CASE STUDY: REDSTONE ARSENAL programs can be utilized in the remediation of buried CWM to increase the effectiveness and efficiency of the regula- During the course of this study, the committee was made tory process. As discussed in Chapter 3, remediations must aware of the existence of what is arguably the largest and be done under appropriate federal and state environmen- most complex RCWM site in the United States (in terms of tal regulations and in compliance with the CWC. These the quantity and variety of materiel, regulatory issues, and regulations, principally the Comprehensive Environmental existing use)—namely, Redstone Arsenal (RSA) in Hunts- Response, Compensation and Liability Act (CERCLA) and ville, Alabama. RSA provides an excellent example of a site the Resource Conservation and Recovery Act (RCRA), along where, to paraphrase the committee’s Statement of Task, with existing Army Military Munitions Response Remedial supporting technologies and operational procedures may Investigation/Feasibility Study (MMRP RI/FS) Guidance, not be sufficient, targeted research and development may govern the recovery of buried CWM. This guidance recom- be needed, and coordination among existing organizations mends following the Army’s Technical Project Planning involved in RCWM remediation may need to be improved. process prior to the commencement of field activities. The committee used RSA as a case study to illustrate the The committee identified several regulatory issues, technological and operational challenges and community including (1) a need for regulatory flexibility, expedited relations issues that the Army will face in remediating large approaches, and risk reduction activities where minimal but CWM sites. Findings and recommendations concerning the sufficient data are available to enable selection of a cleanup application of regulatory issues to the special case of RSA technology, (2) consideration of unique circumstances pre- may be found in Chapter 5. sented by the recovery of buried chemical warfare materiel