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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations (1999)
Commission on Engineering and Technical Systems (CETS)

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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations

(EPA) mandated a delay in processing M55 rockets, which has significantly slowed the planned reduction of stockpile storage risk. In the interim, operations were continued on bulk items. Following the successful DFS trial burn in November 1998, the Army was processing M55 rockets at half rate under a RCRA permit limitation.1 When the TSCA permit was issued in mid-1999, the RCRA limitation was lifted. The TOCDF is now authorized to process M55 rockets at the full rate and is proceeding toward meeting its original risk reduction goals as soon as possible.

Some early operational problems were linked to important safety management issues. These problems, and the investigations necessitated by them, have taken time and management resources that might otherwise have been applied to improving operating performance.

Unresolved issues involving the disposal of dunnage and problems with the slag removal system heater are not critical to continuing safe performance, but their prompt resolution (in the interest of minimizing waste and reducing the number of plant shutdowns for heater replacement) remains a high priority. For example, because it is more economical to ship waste brine off site, the Army has not retested the compliance of the brine reduction area (BRA) with particulate emissions standards. If off-site brine disposal becomes infeasible, this could affect TOCDF operations.

Trial Burn Tests to Establish Compliance with RCRA and TSCA

The committee has reviewed and evaluated the results of trial burns conducted on the various incinerators comprising the baseline system. Trial burns were conducted in accordance with RCRA and TSCA protocols. The acceptance criteria for the RCRA trial burn of the liquid incinerators, the DFS, and the metal parts furnace have been met. A second test of the DFS polychlorinated biphenyl (PCB) destruction efficiency showed that emissions levels meet TSCA criteria. The TOCDF has been issued a TSCA permit for the DFS, and activities to obtain a national TSCA permit are still ongoing. Certification of the BRA is not required as long as waste brine is being processed off site. An application was submitted in late 1998 for the RCRA permit renewal, allowing six months for regulators to review the application before the present permit expired in June 1999. At the time of publication, the regulators had completed work with the Army on the permit renewal, but its issuance was pending until the conclusion of a public comment period.

Improvements in Monitoring Systems

False-positive alarms from the current automatic continuous air monitoring system continue to occur and interrupt agent destruction operations. Although the Army appears to be making reasonable progress in addressing the committee's previous recommendations-including upgrading both the automatic continuous air monitoring system and the depot area air monitoring system—the development, testing, and deployment of more reliable agent monitors should be expedited as much as possible. The development and testing of Fourier transform infrared technology for the real-time detection of an agent release is also proceeding, but real-time alarms are still in development.

Risk Management

The risk management program2 uses the health risk assessment (HRA) and quantitative risk assessment (QRA) as quantitative tools to evaluate and manage the

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 Because of artifact contamination, some of the initial DFS test runs after the destruction and removal of polychlorinated biphenyl (PCB) were inconclusive. The retest unambiguously demonstrated compliance with TSCA requirements.

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 Risk management is a decision-making process for balancing alternative strategies and consequences and a process for implementing those decisions. Risk management is based on: (1) a thorough assessment of performance and the full spectrum of risks to the public, workers, the environment, and property; (2) the prioritization of risks so they can be addressed in order of seriousness; (3) methods of assessing the impact of proposed changes in procedures, management, or equipment; (4) evaluations of abnormal incidents for effects on facility risk; and (5) a commitment to continual evaluation and improvement. Risk management usually involves the following steps:

  • understanding the risk (including identifying major contributors to risk)

  • suggesting alternative ways to reduce risk

  • evaluating alternatives for risk reduction

  • selecting preferred alternatives (including implementing decisions)

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