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Closure and Johnston Atoll Chemical Agent Disposal System 2 Initial Considerations for Facility Closure In this chapter, critical management issues that will have to be addressed early in the JACADS closure planning process are discussed: ownership and stewardship determination of end use (what the property will be used for) end-state cleanup criteria (here, end state means the final environmental condition of the property) retention of personnel exit strategy for post-closure activities Although these issues are discussed in the context of the JACADS closure process, they are applicable to any facility that is to be permanently closed, whether the property remains with the original owner or is transferred to another. These issues require timely resolution for closure to be completed safely and cost effectively. Early in its closure study, the committee prepared a letter report addressed to the Deputy Assistant Secretary of the Army for Chemical Demilitarization. Delivered on May 4, 2000, the letter expressed the committee’s concerns as they relate specifically to JACADS (NRC, 2000a): identification of a lead agency and a steward responsibility for the Johnston Atoll1 during and following closure of the JACADS facility identification of the government agency or entity that would assume ownership of Johnston Island following closure of JACADS definition of the end use of Johnston Island after closure (e.g., industrial site, residential site, or wildlife refuge) establishment of end-state cleanup level standards to be applied based on the end use of the Johnston Atoll Although not included in the letter report, two other issues of concern to the committee are the retention of key staff personnel throughout the JACADS closure program and the development of an exit strategy. These issues are reviewed in more detail in the following sections. OWNERSHIP Two agencies have asserted ownership of Johnston Atoll, which includes Johnston Island. The Air Force was described to the committee as the owner of the island (and the Army as the main tenant). However, the Fish and Wildlife Service (FWS), and perhaps other government agencies, have documents that appear to give them ownership. FWS cited an executive order as its authority to declare the island a wildlife refuge. The FWS contended that the executive order gave it authority to mandate stringent cleanup standards, but not the responsibility to seek appropriations to pay for the cost of meeting those standards (U.S. Army, 1999a). However, EPA must concur with the lead agency having ultimate responsibility for cleanup. The Army plans to leave Johnston Island following completion of the destruction of the chemical stockpile. To complete the closure of JACADS, the Army must demonstrate to EPA that its portion of the island is acceptable for future use (whatever that use is determined to be). Other parts of Johnston Island will require cleanup by appropriate government agencies to address contamination by non-JACADS wastes. These include plutonium,2 Agent Orange, 1 Johnston Atoll consists of Johnston Island and three much smaller nearby islands that function primarily as nesting sites for various seabird species. The entire atoll complex, including Johnston Island, is managed jointly by the U.S. Department of Defense and the Fish and Wildlife Service as a national wildlife refuge. 2 Plutonium contamination resulted from missile test failures in the 1960s.
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Closure and Johnston Atoll Chemical Agent Disposal System dioxins, polychlorinated biphenyls (PCBs), and other potentially hazardous substances. There are no indications that the area of Johnston Island where cleanup is required by the Army contains any of these contaminants. Accordingly, the Army’s closure plan is not required to address issues associated with the cleanup of these substances. In 1998, the Army’s Program Manager for Chemical Demilitarization (PMCD) began planning and making preparations to close JACADS by September 2003. In its letter report, the committee noted that because other federal agencies (as noted in the next section) have an interest in how the atoll will be used after the Army and Air Force complete their missions, the end use at Johnston Atoll has not yet been determined. This may prevent the completion of closure as scheduled by the Army for September 2003, which could result in the expenditure of additional fiscal resources on prolonged cleanup operations, surveillance, and maintenance (NRC, 2000a). DETERMINATION OF END USE Because the primary steward and ultimate ownership responsibility for Johnston Atoll have not been determined, the Army has not been able to negotiate final cleanup standards for the JACADS facility. The Stockpile Committee’s letter report noted that a decision on the end use of Johnston Atoll would require the participation of at least four federal departments (Commerce, Defense, Interior, and Transportation) as well as EPA (NRC, 2000a). In the Department of Defense, the Department of the Army (the major tenant) and the Department of the Air Force (the current steward) will play lead roles in various aspects of closure. Another defense agency, the Defense Threat Reduction Agency, has been responsible for cleaning up the plutonium on Johnston Island. Although the Air Force is the current steward for the island, it will probably not be the agency ultimately responsible for the overall atoll and therefore is not in a position to make final determinations about end use. The National Oceanic and Atmospheric Administration (Department of Commerce) is concerned about aquatic life in the lagoon. The U.S. Coast Guard (Department of Transportation), as well as other agencies, may also be interested in the ultimate use of the atoll. If it is designated surplus property, the General Services Administration (GSA) may become involved. The Federal Aviation Administration (Department of Transportation) operates the runway on Johnston Island. The FWS (Department of the Interior) operates the wildlife refuge and may be the final steward of the atoll. Pending a resolution of the ownership issue, a number of scenarios can be envisioned. For example, if the Air Force is the owner, the island might be turned over to GSA to sell to the highest bidder for industrial, residential, or recreational use. If FWS becomes the ultimate owner, all of Johnston Island would likely become a national wildlife refuge. The cleanup standards, which EPA would establish for each end use scenario, differ in terms of receptors and exposures to inhabitants, which should be defined in an appropriate risk assessment. Receptors are plants, biota, animals, and humans that are exposed to a contaminant of concern. The risk assessment should assess the risks to both human health and ecological receptors, because they may require different end states. PMCD assigned the U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) to prepare the Conceptual Site Model (CSM) for JACADS closure and to perform the risk assessment. The Army initially proposed an industrial end-use scenario as the most reasonable and cost-effective approach for the JACADS site, because other parts of Johnston Island contain hazardous substances such as plutonium and Agent Orange. A draft of the CSM for the JACADS closure risk assessment, submitted to EPA Region IX in December 1999, provided an outline for a risk assessment performed in support of the JACADS closure plan (U.S. Army, 1999b). The CSM was returned to the Army with comments and a request from EPA for the inclusion of an ecological risk scenario that contains a methodology for conducting an ecological risk assessment based on a wildlife-refuge end use (EPA, 2000). At this writing, the Army is developing a work plan for the ecological risk assessment. The assessment will be completed in late 2003. Also, agreement on an end use for the JACADS site following closure has not been finalized, but it appears that the FWS is considering several options to maintain a presence or conduct periodic visits.3 More specifically, current plans call for the Army to place the site under the jurisdiction of the Air Force upon completion of JACADS closure activities. Although it is likely that FWS will ultimately assume stewardship responsibility for Johnston Island, the Army presently plans to provide parttime monitoring staff for a period of 5 years after closure operations have been completed. END-STATE CLEANUP CRITERIA The end state, as defined in this report, is the final required condition of a building, facility, or site after cleanup is accomplished. It must be known so that receptors and exposure to inhabitants can be defined in the risk assessment. The end state also must be known and specified for a realistic, cost-effective, and timely closure program to be developed. EPA will define the cleanup standards for JACADS closure based on the end use proposed by the owner. It will also monitor and enforce the implementation of the approved 3 Steve Bushman, Group Leader, Post Operations, Technical Management Office (PMCD), conversation with Stockpile Committee Study Director Donald L. Siebenaler, February 19, 2002.
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Closure and Johnston Atoll Chemical Agent Disposal System end-state requirements. EPA regulations (40 CFR 264.115)4 require that the facility owner or operator submit a certification when the facility has been cleaned in accordance with specifications in the EPA-approved RCRA permit and closure plan for the site. RETENTION OF PERSONNEL Whenever closure of a facility is announced, a major problem is the loss of personnel to outside jobs and uneasiness among the remaining workforce about prospects for future employment. Industry has successfully mitigated this problem by recognizing it early in the planning process, providing appropriate personnel counseling and career planning, and establishing, communicating, and fully implementing incentives for knowledgeable personnel to remain throughout the closure of a facility. The Army’s contractor for JACADS, Washington Group International, Inc., has recognized the need to retain key supervisory personnel and staff for the duration of the closure campaign. These personnel can provide the corporate memory for the physical plant and help to maintain the safe, disciplined work practices that have evolved throughout the operation and maintenance of JACADS. Subsequently, the orderly transfer of experienced personnel from JACADS to other chemical disposal facilities that are already operational or are being built may be a good way to transfer valuable knowledge about JACADS operations, maintenance, and closure to these facilities. Currently, one chemical agent disposal facility in the continental United States is operational and five facilities are under construction or in the systemization phase. Employment at these facilities can provide career advancement opportunities, as well as an improved family and community lifestyle at sites in the continental United States. The JACADS operations contractor, WDC, submitted and received approval from the Army for a staff retention plan. The implementation of this plan for JACADS personnel retention, transfer, and release will be critical to successful closure. EXIT STRATEGY Defining the end point of any remediation treatment or process for the closure of a chemical agent disposal facility (including JACADS) is critical to limiting the extent and cost of closure activities and to keeping all stakeholders (tenants, owners, nearby communities, employees, and the general public) informed of intended activities. Before a new remediation process is started, the Army should negotiate with the regulators the type of tests, samples to be taken, and frequency, and should specify the end of treatment in sufficient detail that the closure activities and remediation processes can be concluded as soon as possible. For example, if air and groundwater sampling is required, the criteria for reducing the frequency of sampling should be defined, as well as the point at which the sampling can be terminated. 4 CFR citations refer to the U.S. Code of Federal Regulations with the volume number preceding CFR and the section number following. Copies of volumes of the U.S. Code of Federal Regulations are available through Government Printing Office outlets and commercial document and regulatory services.
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