Executive Summary

This report addresses significant issues related to the ongoing closure of the Johnston Atoll Chemical Agent Disposal System (JACADS) and identifies matters that may influence the closure of other disposal facilities at storage sites in the continental United States. Most notable are issues dealing with (1) establishing final end-state (final environmental condition of the property) cleanliness standards for contaminants remaining after facility closure, (2) ensuring personnel safety, (3) minimizing delays and additional costs due to the processing of RCRA permit modifications not included in the original permit submitted to the U.S. Environmental Protection Agency (EPA), and (4) personnel retention.

JACADS, the first fully integrated baseline incineration system for the disposal of stockpiled chemical agent and munitions, is located on Johnston Island, part of the Johnston Atoll, approximately 800 miles southwest of Hawaii. The facility occupies 130 acres of the 625-acre island and includes one large process building, with three furnaces and auxiliary equipment.

Concurrent with the beginning of construction of the baseline incineration facility at JACADS in 1987, the Army requested that the National Research Council (NRC) review and evaluate the Chemical Stockpile Disposal Program (CSDP) and provide scientific and technical advice and counsel. The NRC established the standing Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee), one of whose early reports was a study of operational verification testing at JACADS prior to the start of agent disposal operations. In the intervening years, the Stockpile Committee produced 27 reports on various aspects of the CSDP.1

In 1998, the Army’s Program Manager for Chemical Demilitarization (PMCD) began planning for the closure of JACADS by September 2003. In January 1999, the Stockpile Committee was asked by the Army to begin a review of JACADS closure planning. To complete the closure, the Army must demonstrate to the EPA that the Army’s portion of the island meets applicable regulatory standards for future use. The several federal agencies having an interest in how the atoll will be used after the Army (the main tenant) and the Air Force (the current steward) complete their missions have as yet left undetermined the end use (what the property will be used for) of Johnston Atoll, following closure of JACADS. This may prevent completion of closure as scheduled by the Army for September 2003. The need for prompt action on this matter at a high level was pointed out in a letter report of the committee dated May 4, 2000 (NRC, 2000a).

End use is an important parameter because remediating JACADS to a residential standard typically would be more difficult than remediating the site to an industrial standard. The Army has favored an industrial standard, because the decision on which standard will be used and permitted by regulatory authorities may also set an important precedent for the closures (and costs) of other chemical agent disposal facilities.

Considering the uncertainty surrounding end use, the Army is currently screening in its closure process at JACADS to a residential standard, although it does not necessarily believe that it will ultimately have to clean its portion of the atoll to these criteria. Screening in this context means comparing the analytical results to a standard for each contaminant, if available.

A generic closure process for the remediation of any industrial or government facility, including chemical agent disposal facilities using incineration or other disposal technologies, would involve a planning phase and an implementation phase (see Appendix C). The committee used

1  

The 27 reports of the committee are listed in Appendix A; biographical sketches of the committee members are given in Appendix B.



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Closure and Johnston Atoll Chemical Agent Disposal System Executive Summary This report addresses significant issues related to the ongoing closure of the Johnston Atoll Chemical Agent Disposal System (JACADS) and identifies matters that may influence the closure of other disposal facilities at storage sites in the continental United States. Most notable are issues dealing with (1) establishing final end-state (final environmental condition of the property) cleanliness standards for contaminants remaining after facility closure, (2) ensuring personnel safety, (3) minimizing delays and additional costs due to the processing of RCRA permit modifications not included in the original permit submitted to the U.S. Environmental Protection Agency (EPA), and (4) personnel retention. JACADS, the first fully integrated baseline incineration system for the disposal of stockpiled chemical agent and munitions, is located on Johnston Island, part of the Johnston Atoll, approximately 800 miles southwest of Hawaii. The facility occupies 130 acres of the 625-acre island and includes one large process building, with three furnaces and auxiliary equipment. Concurrent with the beginning of construction of the baseline incineration facility at JACADS in 1987, the Army requested that the National Research Council (NRC) review and evaluate the Chemical Stockpile Disposal Program (CSDP) and provide scientific and technical advice and counsel. The NRC established the standing Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee), one of whose early reports was a study of operational verification testing at JACADS prior to the start of agent disposal operations. In the intervening years, the Stockpile Committee produced 27 reports on various aspects of the CSDP.1 In 1998, the Army’s Program Manager for Chemical Demilitarization (PMCD) began planning for the closure of JACADS by September 2003. In January 1999, the Stockpile Committee was asked by the Army to begin a review of JACADS closure planning. To complete the closure, the Army must demonstrate to the EPA that the Army’s portion of the island meets applicable regulatory standards for future use. The several federal agencies having an interest in how the atoll will be used after the Army (the main tenant) and the Air Force (the current steward) complete their missions have as yet left undetermined the end use (what the property will be used for) of Johnston Atoll, following closure of JACADS. This may prevent completion of closure as scheduled by the Army for September 2003. The need for prompt action on this matter at a high level was pointed out in a letter report of the committee dated May 4, 2000 (NRC, 2000a). End use is an important parameter because remediating JACADS to a residential standard typically would be more difficult than remediating the site to an industrial standard. The Army has favored an industrial standard, because the decision on which standard will be used and permitted by regulatory authorities may also set an important precedent for the closures (and costs) of other chemical agent disposal facilities. Considering the uncertainty surrounding end use, the Army is currently screening in its closure process at JACADS to a residential standard, although it does not necessarily believe that it will ultimately have to clean its portion of the atoll to these criteria. Screening in this context means comparing the analytical results to a standard for each contaminant, if available. A generic closure process for the remediation of any industrial or government facility, including chemical agent disposal facilities using incineration or other disposal technologies, would involve a planning phase and an implementation phase (see Appendix C). The committee used 1   The 27 reports of the committee are listed in Appendix A; biographical sketches of the committee members are given in Appendix B.

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Closure and Johnston Atoll Chemical Agent Disposal System these phases as a framework for discussing the closure of JACADS. Decontamination of JACADS will require chemical, mechanical, and thermal processing. The removal of critical structural components and systems from buildings will have to be planned to ensure structural stability. Residuals of any of the agents processed at JACADS (HD, GB, and VX) may be exposed during disassembly activities. These residuals will be harmful to anyone in the immediate area: If they are vaporized, airborne agent concentrations could be harmful, so decontamination procedures for equipment, waste streams, and building materials must ensure that agent residues are destroyed, and the destruction must be verified. The closure of the baseline incineration system used at JACADS will present unique hazards, risks, and problems that must be anticipated and resolved as the decommissioning work progresses. Because closure is a new activity in the chemical disposal program, all sources of risk might not have been identified in the planning phase. New sources of risk must be addressed carefully, and the experience meticulously recorded to assist in the subsequent closure of other disposal facilities. The JACADS experience may be the prototype for future closures and should provide a wealth of lessons learned for those closures and for the design of new facilities. For example, after closure activities have been completed, long-term monitoring may be needed. As closure progresses and dismantling of the facility advances, the workforce will be required to handle increasingly heavy materials and equipment. This equipment will include all possibly agent-contaminated machinery, metal ducts, and piping, as well as bulk materials such as concrete. Consequently, some risks to workers may be encountered more frequently during the dismantling and demolition associated with facility closure: equipment mistakenly believed to be free of agent, energetics, or other chemical hazard (e.g., lead-based paint, decontamination solutions) slips, trips, and falls hazards presented by heavy objects and heavy lifting equipment utility systems only temporarily connected heat stress, uncomfortable working conditions confined work spaces proximity to flame-producing equipment unstable structures and equipment noisy environments The Army has programs for risk management, safety, and occupational and environmental health in place at its chemical stockpile disposal sites. The recommendations set forth below are provided with the committee’s expectation that if they are carried out, workers employed in closure operations will be less likely to encounter the posited risks. Currently, there are closure Resource Conservation Recovery Act (RCRA) permit modifications awaiting EPA approval. To date, there have been no delays due to approval of permit modifications, but they could occur in the future. Permit modifications need to be identified sufficiently early to allow time for regulatory reviews, public comment, resolution of comments, and incorporation of changes into the applicable engineering change proposals (ECPs), work orders, or other management control documents. The method used at JACADS to process ECPs has become well defined and refined over the life of the project. The processing of proposals relevant to closure of the site should be carefully documented and lessons learned identified to facilitate the closure of other disposal facilities. The retention of experienced and knowledgeable personnel during facility operation and closure is an important management issue. Personnel staffing and retention plans need to be addressed early in the facility planning process. Implementation of a suitable personnel retention, transfer, and release program is essential to the successful closure of JACADS. The Army’s contractor for JACADS has recognized this issue and has developed a staff retention plan. Public outreach and engagement established during disposal operations must be continued as the emphasis shifts from operations to closure. Outreach activities during closure will also provide the Army with an opportunity to promote its operational accomplishments. FINDINGS AND RECOMMENDATIONS Decision Making and Project Planning Finding 1. The initial JACADS closure plan was developed late and was not comprehensive. Preproject planning and early decision making by management are necessary to support the closure of all chemical agent disposal facilities. A comprehensive, facility-wide, integrated closure plan could have had significant overall cost benefits at JACADS. The plans did not provide detailed information on new required standard operating procedures, nor did they provide training for personnel carrying out the closure tasks in this new environment. Recommendation 1. The Army should prepare a comprehensive closure strategy for each chemical agent disposal facility. The strategy would provide for responsible project and contractor management personnel to be trained in preproject planning. A comprehensive, integrated closure plan should be developed for each disposal site and surrounding area based on realistic assumptions at the time the facility is designed or as soon as possible if it is in construction or operation. This plan should provide for appropriate standard operating procedures and personnel training for the anticipated activities.

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Closure and Johnston Atoll Chemical Agent Disposal System Finding 2. Decisions on the end use and identification of the ultimate owner of Johnston Island or other chemical disposal facilities have not been reached in a timely way. For JACADS, the need for prompt action on this matter at a high level was pointed out in a letter report of this committee dated May 4, 2000 (NRC, 2000a). Regulatory requirements and analytical procedures/protocols to meet end-state requirements for JACADS were not completed as of the writing of this report. Recommendation 2. The end state, end use, and stewardship issues pertaining to closure of any chemical agent disposal facility should be resolved early so that planning can proceed on an assured rather than an assumed basis. If possible, facility end uses should be included in the RCRA operating permit. If end use and end state cannot be defined early in the planning process, risk assessments and cost and schedule estimates for alternative end states and uses should be prepared. Finding 3. Closure of any chemical agent disposal facility necessitates the identification of potential exposure pathways and environmental receptors in an initial conceptual site model. Closure of JACADS has been complicated because this was not done early and the end use will not be determined until much of the closure planning has been completed. Recommendation 3. Development of a conceptual site model should include identification of potential exposure pathways for receptors, their impacts, if any, the risks to be mitigated, and the means of mitigation. Such a conceptual site model should be reviewed and agreed to by the various stakeholders early in the planning phase and before submission of the overall closure plan to the regulatory agency for approval. The RCRA operating permit for the facility should be amended as early as possible to include closure criteria, closure sampling criteria, and mitigation methods. This information could be in the initial operating permit. At the latest, it should be developed while agent disposal operations are under way. Finding 4. The closure plan is incomplete in that it does not sufficiently address contingencies such as control of spills, dust, or special materials such as asbestos, nor does it specify countermeasures for mitigation of these potential situations. Moreover, the hazardous waste management units (HWMUs) at JACADS and the Red Hat Storage Area differ in the chemicals to be analyzed, their management and associated cleanup levels, and required permit modifications, because new unidentified secondary waste may be generated during decommissioning and closure. Recommendation 4a. The closure plan must include a consideration of storage, handling, and ultimate disposal of wastes generated from JACADS closure, including provisions for temporary staging and transportation on-site and off-site. Recommendation 4b. To promote the development and implementation of contingency responses during both closure and postclosure operations, control strategies for unexpected liquid runoff or particle dispersion, as well as for special hazardous substances—such as asbestos—should be integrated in the closure plan. Finding 5. Stockpile disposal facilities that do not use components of the baseline incineration system, or modified versions of it, lack a means to achieve thermal decontamination of secondary wastes during closure operations. Recommendation 5. The Army should proceed as soon as possible to develop means to address secondary waste processing/disposal issues at sites employing disposal technologies other than incineration, and should seek early regulatory and stakeholder approval for such means. Personnel Retention Finding 6. The loss of experienced personnel prior to completion of closure could jeopardize the cost-effective and safe implementation of closure plans. Fostering personnel retention during facility closure could present a challenge, particularly if the contractor responsible for closure is different from the one responsible for operations. Recommendation 6. The Army and its contractors for operating chemical agent disposal facilities should develop and adopt a strategy for personnel retention at project inception. The strategy should consider hiring procedures, training (including lessons learned), career development, reward and recognition, management of change, the work environment, retention incentives, and employee morale. Acquisition Strategy and Procurement Finding 7. The procurement strategy proposed for closure of the JACADS facility appears to be workable; however, the contracting mechanism is awkward and inherently inefficient. Recommendation 7. The Program Manager for Chemical Demilitarization should continue to work with the Operations Support Command to make procurement processing as efficient and responsive as possible. Finding 8. The contract for closure at JACADS is expected to have an award fee based on meeting the schedule for closure.

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Closure and Johnston Atoll Chemical Agent Disposal System Recommendation 8. Future contracts should consider all aspects of performance, including (but not limited to) safety, cost, and schedule, in setting criteria for the award fee. Cost Control Finding 9. Cost containment efforts in the closure of JACADS are fragmented and have been inhibited by the absence of a total project cost baseline estimate for the Army and all contractors supporting closure activities. A multiyear program cost estimate and schedule that encompasses all closure costs is essential for the cost-effective completion of the JACADS closure campaign. Costs will probably change as the closure project evolves. Recommendation 9. The Army should develop an earned value system to maintain a comprehensive multiyear cost and schedule for the construction, operation, and closure of each chemical agent disposal facility. The system should be used to control and report the effect on cost and schedule from changes such as permit modifications, proposals for engineering changes, and the phaseout of security for surety material. Finding 10. Prudent management requires early decisions, accurate assumptions, and full consideration of all cost components, regardless of the entity incurring them, and cost estimates that approach the actual final costs. Project cost control procedures and contract incentives were not established as part of the JACADS contract. Recommendation 10. The Program Manager for Chemical Demilitarization should assure that for future site closures, all means at his disposal, including JACADS lessons learned, are applied early and continuously to estimate costs more accurately, thus facilitating project management and executive and congressional oversight. This should include the establishment of cost control procedures and contract incentives during development of the relevant contracts. Monitoring Finding 11. Contamination at JACADS by multiple agents and agent degradation products is a certainty, but the extent is unknown. At JACADS, weapons and bulk stores containing GB, HD, and VX were destroyed. Any or all of these agents and their degradation products may be present in the munitions demilitarization building, in secondary stored wastes such as used DPE suits, and in spent carbon from air filters. Intrusion of agent into the epoxy coating and concrete floor slabs in processing rooms is likely, and contamination is likely in niches, recesses, joints, and cracks, as well as within process equipment, lines, and valves. There will also be contaminated carbon from the plant air ventilation filter system. Recommendation 11. Near-real-time monitors (ACAMS) for all three chemical agents (GB, HD, and VX) should be provided to protect workers in any areas where they might be exposed to agent during dismantlement activities or during the handling and treatment of secondary wastes. Multiagent monitoring should also be provided for the common stack. Finding 12. By rigid adherence to definitions and terminology prescribed by Army regulations on decontamination levels, the Army has failed to communicate clearly with external agencies holding regulatory responsibility or with members of the knowledgeable, interested public. Steps can and should be taken to improve communications in this important area. Recommendation 12. The Army should either seek relief from the internal regulation prescribing use of the 1X, 3X, 5X, and 5R terms or augment its use of these designators with scientifically derived terms that communicate clearly with external regulators and interested stakeholders. Ideally, EPA standards (or actual values) should be the primary reporting values, with “X” and “R” designations as secondary reporting values. Finding 13. The sampling and analysis plan for closure, and the need to increase the number of DAAMS tubes to monitor all three agents, will require a substantial increase in the numbers and kinds of chemical analyses. Recommendation 13. The Army should estimate the numbers of chemical analyses of each kind that will be required as closure proceeds and ensure that adequate instrumentation, laboratory space, and personnel will be available to handle them. Finding 14. Analytical procedures for the chemical agents and their most toxic degradation products have not been specified and may need to be developed, particularly when these agents and products occur in media such as concrete, soils, and spent carbon. Recommendation 14. The Army should demonstrate that it has the ability to analyze for agents and their toxic degradation products in concrete, soil, and spent carbon, and to provide assurance that any structures or media left in place will be decontaminated consistent with the island’s future use. Security Finding 15. Security requirements for Johnston Atoll following the departure of USACAP include (1) protection of personnel, facilities, and materiel, (2) prevention of pilferage, unauthorized use, sabotage, and violation of community rules and regulations, and (3) prevention of

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Closure and Johnston Atoll Chemical Agent Disposal System unauthorized entry and trespass from either air or sea until the island’s end state has been reached and final ownership has been established. Recommendation 15. Security measures on Johnston Atoll commensurate with personnel safety and the protection of government and personal property should be maintained throughout the closure process. Safety Finding 16. Experience gained at JACADS will establish precedents for closure planning at chemical agent disposal facilities in the continental United States. Unusual and unanticipated events during JACADS closure, including those from construction- and demolition-related activities and those due to the inexperience of some workers with these activities, will likely be used by regulatory authorities in setting requirements for closures at other facilities. Recommendation 16. The detailed plans for decommissioning, dismantlement, and demolition of chemical agent disposal facilities should examine all levels of activity, e.g., task procedures, utility requirements, personnel training, and safety considerations. The examination should include consideration of daily task planning and identification of risk factors inherent in each planned activity and worker adherence to procedures. It should also develop contingency scenarios and intended responses so as to achieve the highest degree of safety and lowest probability of disruptive, unplanned situations. Prompt investigation, reporting, and analysis of every accident and near miss should be ensured, with all safety data assembled in a lessons learned format easily accessible to future closure campaign supervisors and planners. Finding 17. The introduction of new structural risks during closure operations is a potential source of accidents. Dismantlement and removal of building structural components, such as the concrete floors of the explosion containment rooms, could pose added risks of structural instability during closure operations, as could temporary loadings from stacked materials or heavy equipment. Recommendation 17. Throughout closure operations, the sequence and extent of building demolition should be planned to ensure continuous separation of contaminated waste from uncontaminated waste. Professional engineers should review the proposed sequence and extent of demolition actions. The effects of demolition on structural integrity in the event of a contingency condition (such as a typhoon) should be considered. A system of work permits and controls should be established for operation of heavy equipment within structures and for sizing and locating material stockpiles. Finding 18. During closure, utility service becomes less dependable with the changing configuration of a facility. Also, adverse interactions of materials handling and lifting equipment with ongoing changes in building structures and utility distribution systems can create unique risks. Recommendation 18. The Army should carefully assess the need for redundancy in utility systems so that needed utilities are available for planned operations. Special training may be necessary to assure the safe use of lifting equipment and to preclude utility system failure. Public Affairs and Public Involvement Finding 19. The Army has made great strides in the public relations and outreach elements of its public affairs program in support of JACADS, identifying external stakeholders, communicating with them, establishing credibility, and satisfying their needs—often by going well beyond minimal requirements. Completing closure of JACADS as rapidly as possible, and with full regard for safety and the environment, appears in the best interest of the public and the Army. Also, the Army has gone to considerable expense to hold meetings in Hawaii, to sponsor travel to Johnston Island for inspections and discussions, to hold meetings in South Pacific island regions in the vicinity of Johnston Island, and to maintain stakeholder contact. As the Army moves forward with the third element of its comprehensive public affairs program, public involvement, there are measures it can take to continue to improve its results. Recommendation 19. The Program Manager for Chemical Demilitarization should continue to do the following: Maintain contact by multiple means with all stakeholders, taking appropriate public outreach initiatives as the transition from operations to closure occurs. Press for opportunities for effective public involvement in closure planning and implementation. Press for end-use and end-state criteria as vigorously as possible and communicate this information to stakeholders along with notices of important operational accomplishments. Ensure that, as progress in the closure of JACADS continues, the information is disseminated to all stakeholders, especially to communities near other sites. Seek coordinated, interagency support for outreach efforts to facilitate the clarity, candor, and consistency of disseminated information at all disposal sites.