The successful closure of JACADS will be a major accomplishment for the CSDP and will provide guidance for the closure of other chemical agent disposal facilities in the continental United States. This chapter examines a number of the technical considerations involved in planning for the closure. Issues related to the execution of a closure plan and postclosure activities are covered in Chapters 4 and 5.
Key objectives for the closure of a chemical agent disposal facility can be found in Chapter 4 of the Guide to Closure Planning (U.S. Army, 1999c):
protect workers and the public
protect the environment
meet applicable regulatory requirements
meet cost and schedule goals
Table C-1 in Appendix C lists likely activities during planning and implementation phases for closure of an industrial facility. Not all of the activities listed will necessarily apply in every closure situation. The following activities are most important for the successful closure of a hazardous waste site:
defining the end state of the site to be achieved following closure activities
developing a conceptual site model (CSM) that identifies all potential receptors, contaminants, pathways, impacts of exposure to contaminants (if any), the risks to be mitigated, and the means of mitigation
submitting the CSM for review by the appropriate stakeholders very early in the closure planning process
obtaining regulatory approval of the CSM and the likely mitigation measures early in the planning process, so that ample time is available to react to comments and make the changes required
ensuring the safety of workers and the public
protecting the environment
If the final end state is not known at the time the closure plan is first prepared, the Army should develop preliminary plans and costs for various reasonable scenarios. This information could also serve as a very useful negotiating tool with EPA.
The JACADS closure activities will involve the dismantling and destruction of that portion of the facility that cannot be decontaminated to meet the 5R1 cleanliness standard. An area decommissioning matrix delineates the areas that will be decontaminated and dismantled, decontaminated and abandoned in place, or solely abandoned in place (U.S. Army, 2000c). The remaining systems, structures, and components (SSCs) that are left in place must meet the Resource Conservation and Recovery Act (RCRA) criteria for decontamination as well as the Army standard of 5R. Areas that were kept free of any agent or hazardous materials will be sampled to demonstrate their cleanliness in accordance with the final closure sampling and analysis plan.
For JACADS and the stockpile storage area (Red Hat Storage Area), the Army has defined the following closure objectives (U.S. Army, 2000a):
safe removal and destruction of agent- and/or explosive-contaminated systems, structures, and components
protection of workers, the public, and the environment
compliance with the EPA-issued RCRA permit, as modified
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Closure and Johnston Atoll Chemical Agent Disposal System 3 Planning the Closure Operation The successful closure of JACADS will be a major accomplishment for the CSDP and will provide guidance for the closure of other chemical agent disposal facilities in the continental United States. This chapter examines a number of the technical considerations involved in planning for the closure. Issues related to the execution of a closure plan and postclosure activities are covered in Chapters 4 and 5. CLOSURE OBJECTIVES Key objectives for the closure of a chemical agent disposal facility can be found in Chapter 4 of the Guide to Closure Planning (U.S. Army, 1999c): protect workers and the public protect the environment meet applicable regulatory requirements meet cost and schedule goals Table C-1 in Appendix C lists likely activities during planning and implementation phases for closure of an industrial facility. Not all of the activities listed will necessarily apply in every closure situation. The following activities are most important for the successful closure of a hazardous waste site: defining the end state of the site to be achieved following closure activities developing a conceptual site model (CSM) that identifies all potential receptors, contaminants, pathways, impacts of exposure to contaminants (if any), the risks to be mitigated, and the means of mitigation submitting the CSM for review by the appropriate stakeholders very early in the closure planning process obtaining regulatory approval of the CSM and the likely mitigation measures early in the planning process, so that ample time is available to react to comments and make the changes required ensuring the safety of workers and the public protecting the environment If the final end state is not known at the time the closure plan is first prepared, the Army should develop preliminary plans and costs for various reasonable scenarios. This information could also serve as a very useful negotiating tool with EPA. The JACADS closure activities will involve the dismantling and destruction of that portion of the facility that cannot be decontaminated to meet the 5R1 cleanliness standard. An area decommissioning matrix delineates the areas that will be decontaminated and dismantled, decontaminated and abandoned in place, or solely abandoned in place (U.S. Army, 2000c). The remaining systems, structures, and components (SSCs) that are left in place must meet the Resource Conservation and Recovery Act (RCRA) criteria for decontamination as well as the Army standard of 5R. Areas that were kept free of any agent or hazardous materials will be sampled to demonstrate their cleanliness in accordance with the final closure sampling and analysis plan. For JACADS and the stockpile storage area (Red Hat Storage Area), the Army has defined the following closure objectives (U.S. Army, 2000a): safe removal and destruction of agent- and/or explosive-contaminated systems, structures, and components protection of workers, the public, and the environment compliance with the EPA-issued RCRA permit, as modified 1 See definition of 5R in the acronyms list, page xviii.
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Closure and Johnston Atoll Chemical Agent Disposal System completion of the closure process within the approved schedule and budget CLOSURE ALTERNATIVES The JACADS processing area and Red Hat Storage Area are being decontaminated, dismantled, and closed following the completion of processing of all agent material and energetics (November 2000). These closure activities are being performed in accordance with the JACADS Closure Campaign Facility Closure Plan and the JACADS Closure Campaign Decommissioning Plan (collectively referred to as the JACADS closure campaign documents), which incorporate the requirements of applicable RCRA permits (U.S. Army, 2000a, 2000c, 2000d). Because the Army’s objective at JACADS is to reduce cost by pursuing prompt dismantlement, no other closure mode alternatives (e.g., entombment) were studied. Furthermore, the closure plan does not discuss other issues such as spill control, dust control, erosion control, or control of special materials such as asbestos. Countermeasures have been considered should these occur, but they are not detailed in the plan. Suppression, control, and sampling of dust during scabbling operations are not covered in the plan that the committee reviewed. RISK ASSESSMENT Modern risk assessment techniques can offer a powerful framework for assembling and presenting critical information for decision makers and thereby become the cornerstone of an effective risk management program. Such a risk management program would address programmatic as well as worker risk issues. Programmatic issues would include cost, schedule, and technology risks arising from, for example, uncertainties in end use, the choice of regulatory requirements, or the evolution of those requirements. Such a risk management framework should be in place prior to the initiation of closure activities and should be a dynamic process. The constituent risk models should be updated as new information becomes available and should be responsive to changing and emerging hazards. Delays were encountered in closure risk assessment for JACADS because the Army’s first CSM, prepared by USACHPPM and submitted to EPA Region IX in December 1999, provided only a human health risk assessment based on industrial end use for JACADS (EPA, 2000; U.S. Army, 2000e). Neither the Air Force (the present Johnston Island owner) nor the FWS (the anticipated owner) was asked to review the CSM before it was submitted to EPA. After subsequent meetings with all stakeholders, a CSM that included both ecological and human health risk assessment methodologies was submitted to EPA in July 2000 as part of RCRA permit modification C3-050 (U.S. Army, 2000e). The CSM for JACADS specifies the Army’s proposed facility end use, agent contamination levels expected after closure, associated solid waste management units (SWMUs), and areas of interest (AOIs).2 When it is approved by the EPA, it will provide a basis for determining cleanup requirements that must be met to close JACADS and satisfy the conditions of the RCRA permits. ACQUISITION STRATEGY Background The procurement process at JACADS is subject to the federal acquisition regulations with which the site contractor, WDC, must comply. The WDC contract with the Army is cost-reimbursable, with provisions for an award fee. Prior to the closure stage, the award fee was based on production (disposal of agent and munitions). WDC anticipates that the award fee for the closure stage may be based on meeting the schedule.3 However, some contracts today in general industry practice also require safety performance and off-site impacts as part of the fee structure. Heavily weighting superior contractor safety and environmental performance is an applicable consideration for award and incentive fees in contracts for closures of chemical agent disposal facilities. The present contract calls for reimbursement of all allowable expenses, excluding contractor costs disallowed by the federal acquisition regulations, such as business development costs. A small base fee was negotiated as profit. The disallowed expenses must be covered by the base fee. The contractor receives a base fee during execution of the contract, and only in the most unusual circumstances is any part of this fee denied. An additional 3 percent of the contract value is set aside as an incentive fee that can be earned by superior performance. The federal acquisition regulations that govern procurement and acquisition procedures undertaken with federal funds are applicable to both materiel and contract services for closure of JACADS.4 Closure Acquisition Because the scope of work for JACADS closure is too uncertain to permit fixed-price competition, contracts for services under a cost-reimbursable contract with an award fee will be used (Bushman, 2000). The entire process of chemical demilitarization has been a novel experience, both for the Army and its contractors. Consequently, a fixed-price contract for the first closure of a disposal facility was not practical. Fixed-price contracting for JACADS closure 2 The term “areas of interest” refers to areas that are believed to be of regulatory concern and of interest to regulators because of possible contamination. 3 Leo O’Shea, JACADS Closure Phase Project Manager, conversation with Stockpile Committee members Charles I. McGinnis and W. Leigh Short on May 24, 2000. 4 See preceding footnote.
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Closure and Johnston Atoll Chemical Agent Disposal System would have involved so many contingencies that the price would probably have been unnecessarily high, even had contractors been willing to bid. This situation prevailed for the pilot phase of each aspect of the CSDP to date; it will likely continue through JACADS closure. The contractors operating demilitarization facilities have proven themselves capable and responsive. However, if it becomes necessary to change contractors for closure operations, the change should begin as early as possible to facilitate a smooth transition. The new contractors should have comparable safety knowledge and injury-management expertise. One indicator of such expertise is the “experience modification rate” at facilities they operate—that is, the worker’s compensation insurance premium adjustment, which reflects the contractor’s safety experience. For the closure of JACADS, the Program Manager for Chemical Demilitarization (PMCD) decided to continue the existing cost-plus-award-fee contract with WDC for the following reasons:5 satisfaction with the operations contractors the unique nature of closure activities for agentcontaminated facilities the probability that there will be concurrent disposal of agent-contaminated materials and closure activities time and cost constraints inherent in closure planning the time and effort required to obtain authorization for cost-plus-fixed-fee contracting Considering the remote location of JACADS, the problems involved in coordinating multiple contractors on the island, and the time and cost penalties inherent in educating another contractor, continuation of the operating contract (with appropriate changes to accommodate closure) appears to be justified. With the benefit of the lessons learned at JACADS, the use of another operations contractor to perform site closure at continental U.S. sites should be considered. The best strategy to employ will depend on site-specific considerations. The acquisition strategy for JACADS closure will be implemented and controlled by issuing engineering change proposals (ECPs) and work orders (U.S. Army, 2000c). The ECP process has been used throughout disposal operations and is well established. However, some changes can be expected. Previously, individual ECPs were converted to contract changes, which the Operations Support Command (OSC) at Rock Island, Illinois negotiated with the contractor.6 For closure, several ECPs can be aggregated under a single master ECP, and a single contract modification negotiated.7 This consolidated process involves a sequence of steps—scope identification, coordination of potentially affected operating elements, safety and environmental reviews, and definition of mechanical and electrical boundaries. Material and cost estimates must also be prepared before contract modifications are negotiated (U.S. Army, 1999d). The processing of ECPs for closure should be carefully documented and lessons learned identified to assist other sites. The JACADS Closure Campaign Decommissioning Plan of October 2000 contains a closure interim cost estimate report that was developed to assist in planning the overall detailed cost estimate submitted for each of the remaining out-years of the closure campaign. The estimate covered the work from January 2001 to September 2003 and consisted of labor, materials, waste treatment and disposal, and travel costs, as well as overhead, general and administrative, and escalation costs. However, there was no information on the costs of ECPs and work orders, which are determined as those documents are prepared. Thus, total project cost cannot be estimated with confidence until the final ECPs have been processed and negotiated (U.S. Army, 2000d). A disadvantage of this system is that there is little incentive to contain costs. The ECP process does not include competitive pressures or pose a serious risk to the contractor’s base fee for failure to contain costs. Contract provisions pertaining to other sites will be different to varying degrees.8 Project cost control procedures and contract incentives should be included in every CDP contract as a proven means of reducing and controlling costs. Industry practices have shown that better project performance is achieved when incentives are positive and when they flow down, that is, when they are shared by the prime contractor with subcontractors, suppliers, and in appropriate cases, individual managers and craftsmen (CII, 1992). Closure Materiel Procurement Although the Army anticipates procuring equipment, systems, and tools that are unique to closure operations, closure planning documents made available to the committee addressed this issue in a cursory way (U.S. Army, 2000c). Section 3.3 of the decommissioning plan simply states a requirement for vendor contracts and engineering guidance. WDC said, however, that it has a very extensive and sophisticated company procurement manual (O’Shea, 2000). Because of the importance of materiel procurement, the Army should insist on full disclosure of the contractor process, and all interested parties must understand and 5 Jerry Linn, PMCD Closure Manager for TOCDF, conversation with Stockpile Committee members Charles I. McGinnis and W. Leigh Short on May 24, 2000. 6 OSC handles procurement for PMCD, but PMCD exercises limited delegated authority through a contracting officer representative. 7 Tim Baker, PMCD Operations Associate Project Manager JACADS, conversation with Stockpile Committee members Charles I. McGinnis and W. Leigh Short on May 24, 2000. 8 See preceding footnote.
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Closure and Johnston Atoll Chemical Agent Disposal System adhere to the process established in the procurement manual and required by the federal acquisition regulations. Chemical Demilitarization Procurement Process As a consequence of OSC’s responsibility for contract negotiations, PMCD’s authority in the procurement process is diluted. Moreover, having OSC as a participant in the procurement process adds to the time needed for processing routine matters. CATEGORIES OF CONTAMINATION JACADS area and equipment contamination lists are provided in “System and Area Closure Report,” which is Annex 1-A of the draft JACADS Closure Campaign Planning Documents, Volume 1 (U.S. Army, 2000c). Annex 1-A lists all equipment, components, and bulk material actually contaminated with agent and/or explosive or that could become exposed to chemical agent liquid or vapor. Hazard categories A, A/B, B, C, D, and E (see Table 3-1) are assigned to areas on the first and second floors of the munitions demilitarization building (MDB) and to the equipment installed there. These hazard categories are described in Annex 2-D of Appendix 2 in the JACADS Closure Campaign Decom missioning Plan (U.S. Army, 2000d). The potential for contamination is primarily based on the operational history of the area in which the equipment is located (U.S. Army, 2000a). For example, all equipment in hazard categories A and B is assumed to be contaminated. The Army has not reported any characterization results of measured agent contamination levels of equipment and surface areas. Permitting Considerations During the development of the closure plan, changes were identified that necessitated a change to the JACADS RCRA permit. Table 3-2 lists six permit modifications submitted by the Army to EPA to support closure. These permit modifications were submitted to EPA from April 2000 through July 2000. Currently, two permit modifications are partially approved and awaiting final EPA approval. The remaining four permit modifications have been approved. Permit modifications need to be identified with sufficient lead time to allow EPA regulatory review, public comment, and the resolution of any EPA and/or public comments. Delays in the approval of permit modifications can delay the completion of closure. If the Army elects to implement an ECP prior to EPA approval, it does so at its own financial and/or schedule risk. Potential delays and TABLE 3-1 Hazard Categories for JACADS Process Areas Hazard Category Comment A Has greatest probability of agent contamination, both liquid and vapor. A/B Are Category A when processing leaking munitions but Category B at all other times. B May be vapor contaminated, but liquid contamination is unlikely. C Not expected to be to be contaminated, but low levels of vapor are possible under unusual upset conditions by virtue of their location next to Category A and B areas. D Are never expected to be agent contaminated. E Are supplied with filtered, positive-pressure air. SOURCE: Adapted from U.S. Army, 2000d. TABLE 3-2 Permit Modifications Submitted for JACADS Closure Permit Modification Number Focus Date Submitted to EPA Status C3-051 Use of a carbon micronization system July 2000 Partially approved for installation only C2-052 Multiagent monitoring July 2000 Approved C2-022 Performance of halogenated-plastics trial burn April 2000 Approved C3-034 Increase of MPFa rates April 2000 Approved C2-035 Addition of allowable waste streams April 2000 Approved C3-050 JACADS closure (sampling protocols, etc.) July 2000 Partially approved aMPF, metal parts furnace. SOURCE: O’Shea, 2001.
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Closure and Johnston Atoll Chemical Agent Disposal System additional cost could have been minimized if the initial RCRA permit for JACADS submitted to EPA had included the requirements for closure operations. The closure of JACADS and the Red Hat Area will be conducted under the existing RCRA permit (I.D. No. TTO-570-090-001) for operating the facility, modified as necessary to reflect the closure activities. The JACADS Closure Campaign Facility Closure Plan, which is the closure plan as of July 2000, includes a permitting plan and a corrective measures study (U.S. Army, 2000a). The corrective measures study provides details for the closure of areas that are not permitted hazardous waste management units (HWMUs). These areas will be remediated according to the requirements for a corrective action program under the JACADS permit module VIII. The corrective measures study includes a RCRA facility assessment and the RCRA facility investigation sampling and analysis work plan required for approval of the permit modifications submitted to the EPA in July 2000. However, EPA has only partially approved two of these permit modifications, and the areas had not been sampled. The closure criteria list chemicals of concern (COCs) and the contaminant concentration levels that must be met by closure activities. Defining final concentration levels (end-state requirements) will require that the end use of the island be specified. The end use will determine what standards will be applied during (1) the removal of the JACADS operating equipment used to destroy chemical agents and their containers and (2) the cleanup of equipment areas and areas such as storage facilities and soil surrounding the operating equipment. Each new or additional set of standards can lead to additional permit changes as well as increased costs and schedule delays. The Army’s current draft documentation on JACADS closure planning includes the expected modifications to the RCRA permit, but not all of these have been approved by the EPA (U.S. Army, 2000a, 2000c, 2000d). Until appropriate cleanup levels, and the means of quantifying them, have been agreed on between the Army and EPA, the permit modifications cannot be issued, which could seriously delay the closure and increase the costs. Cleanup levels for all contaminants except PCBs are determined under RCRA. Cleanup levels for PCBs are determined under the Toxic Substances Control Act and the issued MegaRule,9 administered by an EPA office different from the one handling the RCRA permit. Therefore, some intra-agency coordination within EPA will be involved. A complicating factor is that the Army is responsible for the closure of its portion of the island, while the Air Force and DTRA are responsible for the remainder. Some areas are adjacent to each other. The October 2000 JACADS closure planning documentation fails to discuss fully items such as the following (U.S. Army, 2000a, 2000c, 2000d): sampling protocols for areas to be cleaned sampling procedures location of soil that must be removed sampling for leakage into the ocean a work plan that incorporates permit requirements (as modified), including provisions for an on-site analytical laboratory (specifically for closure), signature authority for manifests, and training requirements for contractor personnel The potential volume of soil to be removed and its eventual disposition will be determined from analytical findings during investigations conducted in accordance with the JACADS RCRA permit (U.S. Army, 2000a). These investigations will include soils in the vicinity of or underlying the tank systems, incinerators, miscellaneous treatment units, and container storage units, with testing for contamination. Removal and ultimate disposal of the soil will be based on applicable exposure limits in accordance with permit stipulations. The ultimate disposition of the contaminated soil will be resolved by a negotiated agreement with EPA and, in the case of off-site disposal, with the receiving treatment, storage, and disposal facility. The Stockpile Committee believes that JACADS has had adequate standard operating procedures to cover operations and maintenance and that management personnel have done a good job of reviewing the procedures to determine those that require change to incorporate closure activities. In addition, the “Procedures Update Manual” in Volume 3 of the June 1999 Decommissioning Plan calls out several existing procedures that need to be revised in order to fully reflect closure activities (U.S. Army, 1999d). These include the “Workforce Training Plan,” an “Operations Personnel Certification,” and related procedures. With regard to training, Volume 2 of the October 2000 Decommissioning Plan has a closure staffing plan for the Training Department that assigned 13 people in FY 2000 and drops to 3 people in calendar year 2002 (U.S. Army, 2000c). The key to a successful closure will be the degree to which everyone complies with the procedures. Six permit modifications required to support closure were submitted to EPA by the Army. The permitting plan, Appendix 1 of the JACADS Closure Campaign Facility Closure Plan, shows that three were submitted in April 2000 (C-2-022, C3-034, and C2-035) (U.S. Army, 2000a). These modifications address the processing of materials, mostly secondary waste (see Table 3-2). A second group of three permit modifications which address closure tasks and sequencing was submitted in July 2000 (C3-050, C3-051, C2-52) (U.S. Army, 2000a). These modifications include use of a CMS, multiagent monitoring 9 MegaRule per PCB Disposal Amendments to 40 CFR Part 761 (June 29, 1998; 63 FR 35384).
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Closure and Johnston Atoll Chemical Agent Disposal System requirement, sampling protocols, and conceptual site models and assessment methodology for human and ecological risk based closure. The goal of the cleanup for Army facilities on Johnston Island is to achieve for each contaminant of concern a concentration less than a value established for that contaminant in a standard. Two sets of standards are under consideration: the industrial standard and the residential standard, each established for the end use implied by the name. As might be expected, the industrial standard is less strict than the residential standard, and the concentration will generally be higher for the industrial standard. Because cleaning to the residential standard typically costs more than cleaning to the industrial standard, there is strong interest in the choice that will be made. At a meeting with representatives of the Stockpile Committee on May 24, 2000, PMCD officials reiterated that cleanup to the industrial standard was the only logical option for all future uses of Johnston Island because of the other hazardous materials (plutonium, Agent Orange, etc.) that would remain on the island.10 It was not known whether these contaminants would be cleaned up to the residential standard, as WDC noted a great many unknowns associated with a residential standard, among them the possibility that measuring contaminants to a lower concentration than called for by the industrial standard might require new technology. At that time, May 2000, the Army noted that all of the EPA regions with oversight of closure of stockpile disposal facilities appeared to be pushing for residential standards.11 The decision on which standard would be used at JACADS would probably be considered a precedent for subsequent closures of facilities in the continental United States. If a residential standard was to be set for JACADS, the Army believed that none of the other sites would be allowed to adopt a lesser standard. An environmental working group with participants from EPA, state regulatory agencies, and representatives of public interest groups was established in February 1999 to ensure that JACADS would not be treated as a separate entity for regulatory purposes because of its unique legal and geographical circumstances (Bushman, 1999). Considering uncertainty regarding end use, the Army finally decided in April 2000 in its closure process at JACADS to screen at a residential standard, even though it believes that it will ultimately not have to clean its entire portion of the atoll to these criteria.12 Screening in this context means comparing the analytical results with a standard for each contaminant, if available. The Army is not yet cleaning up to any standard except 3X or 5X.13 WDC believes that its closure schedule is achievable unless EPA’s review and approval of any new submitted permit modifications are delayed or denied. For example, if the modification requesting an increased feed rate for secondary waste to the metal parts furnace had been denied, the time required for incinerator processing of primary and secondary wastes would have increased. In summarizing the permit situation, the committee made the following observations: The schedule is intact for now, although the ability to maintain the schedule in the event of unforeseen delays will become constrained as the planned closure date approaches. Activities requiring multiagent monitoring could become a problem. Cost and schedule risks will typically increase if a residential standard is chosen. To the maximum extent practical at CSDP disposal sites, secondary wastes should be identified in the initial RCRA permit so disposal can be done continuously and concurrently with operations. The most significant unresolved issues may be the cleanup standards and the analytical methods for measuring agent and agent breakdown products in concrete and soil. PREPARATION OF DETAILED ENGINEERING REQUIREMENTS WDC has prepared documentation contained in three large three-ring binders. Collectively known as the JACADS closure campaign documents, this documentation has two main components, the JACADS Closure Campaign Decommissioning Plan (two volumes) and the JACADS Closure Campaign Facility Closure Plan (U.S. Army, 2000a, 2000c, 2000d). The Decommissioning Plan includes several appendixes with detailed information on the following: system and area closure and decontamination; waste disposal; and decontamination cost estimates. Appendixes to the Facility Closure Plan cover the following areas: permitting plan; sampling and analysis plan; corrective measures study; final release criteria; and closure schedule. SAMPLING AND ANALYSIS PLANS In conducting sampling for preclosure activities (such as the RCRA facility investigation (RFI)) and for closure activities, the Army must either follow accepted published 10 Bill Stayer, PMCD Environmental Engineer, conversation with Stockpile Committee members Charles I. McGinnis and W. Leigh Short on May 24, 2000. 11 Leo O’Shea, JACADS Closure Phase Project Manager, and Tim Baker, PMCD Operations Assistant Project Manager JACADS, conversation with Stockpile Committee members Charles I. McGinnis and W. Leigh Short on May 24, 2000. 12 Leo O’Shea, JACADS Closure Phase Project Manager, conversation with Stockpile Committee Study Director Donald L. Siebenaler, January 14, 2002. 13 See definitions of 3X and 5X in the acronyms list, page xviii.
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Closure and Johnston Atoll Chemical Agent Disposal System protocols or obtain regulatory approval for proposed protocols (e.g., for the analysis of agent in concrete). Examples of existing protocols for other materials include documents for Superfund guidance, RCRA guidance, and PCB sampling guidance. The Army should ensure that sample holding times, replicate requirements,14 and preservation methods provided in existing EPA-approved protocols or new protocols are met for all samples, and that careful photographic and/or written records are kept identifying the sample, its source, the date, and so on. The Facility Closure Plan includes two sampling and analysis plans. The first, “Sampling and Analysis Plan for HWMU Closure” (Appendix 2 in the Plan), includes requirements and procedures for conducting field sampling operations and investigations of soils and structures associated with the MDB and the HWMUs, as well as data quality objectives and field sampling protocols that could be used to verify decontamination (U.S. Army, 2000a). The second, “RCRA Facility Investigation Sampling and Analysis Work Plan” (Appendix 3, Annex 3-B), describes sampling plans to show whether closure conditions specified in the JACADS RCRA permit are met in the operational areas, SWMUs, and AOIs (U.S. Army, 2000a). Samples to be collected and analyzed include concrete, soils, sediment, and sludge. Samples will be obtained and analyzed concurrently with HWMU closure sampling. An integrated sampling and analysis plan prepared by a field sampling subcontractor will be used during the sampling operations. JACADS Operational and Storage Areas For purposes of sampling, analysis, and cleanup, the parts of Johnston Island that were involved in agent and munitions storage and disposal have been divided into six operational areas (U.S. Army 2000a): JACADS, the Red Hat Storage Area (RHSA), the Southwest Area, Scientific Row, the Wharf Area, and Hama Point (see Appendix D, Plate D-1). In addition, six other small sites outside these areas will require remediation or cleanup. Plates D-2 through D-6 in Appendix D show the location of hazardous waste management units within the Red Hat Storage Area; sampling strata G, H, I, J, K, L, and M—areas outside the munitions demilitarization building; and Red Hat buildings 850, 851, and 852. In all, 65 SWMUs and 52 AOIs are known to contain or be suspected of containing chemicals of concern, including volatile organic compounds, semivolatile organic compounds, PCBs, metals, chemical warfare agents (CWAs), agent degradation products (ADPs), and explosives. Five of the compounds listed in the RFI Sampling and Analysis Work Plan are ADPs (see Table 3-3). TABLE 3-3 Agent Degradation Products Listed in the RCRA Facility Investigation Sampling and Analysis Work Plan ADP Abbreviation Chemical Name Agent Source TDG Thiodiglycol HD IMPA Isopropyl methylphosphonic acid GB MPA Methylphosphonic acid GB or VX EMPA Ethyl methylphosphonic acid VX DESH 2-diisopropylaminoethanethiol VX EA-2192 S-(diisopropylaminoethyl)methyl-phosphonothioate VX NOTE: Contained in Appendix 3, Annex 3-B of the Facility Closure Plan. SOURCE: U.S. Army, 2000a. The situation is even more complex. Weapons-grade agents may contain stabilizers, starting materials, or byproducts of their manufacture, as well as products formed by reactions between these compounds and the agents during storage. In HD alone, 42 degradation products and impurities have been reported (Munro et al., 1999). The Sampling and Analysis Work Plan of the Facility Closure Plan that is the source of the information in Table 3-3 lists analytical methods to be used for five of the listed ADPs, but no method is listed for EA-2192, an HD degradation product. The work plan also indicates that methods are to be determined for HD, GB, and VX. Moreover, EPA, states with regulatory authority, and treatment, storage, and disposal facilities (TSDFs) that will treat wastes off-site do not recognize the 1X, 3X, 5X, and 5R measures of decontamination currently used by the Army. Under existing regulations, JACADS and other sites, as they commence closure, will have to meet not only the Army standards, but also the EPA and state-mandated RCRA standards. Through permit modifications, EPA has allowed 5X metal to be shipped off Johnston Island and sold as scrap metal. Most contaminated carbon will not be analyzed for agent but will be fed through a carbon micronization system15 and furnace for disposal. However, inevitably, some carbon will be left at the end (e.g., the carbon in the filtration system for the plant ventilation air while the contaminated carbon is being burned). The residual carbon will have to be shipped off the island for disposal, somewhere in the continental United States. Although concentrations of agent on the contaminated carbon are expected to be low, analysis will be required by the receiving disposal facility. 14 The term “replicate requirements” refers to the number of analytical samples required to provide statistically significant results with the required degree of precision. 15 The carbon micronization system (CMS) is used for the disposal of agent-contaminated, activated charcoal that was used as an agent filtration medium in the pollution abatement system of the plant cascade ventilation system. CMS is a system that grinds the solid carbon granules into micronized particles so that the carbon can be thermally treated in its furnace.
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Closure and Johnston Atoll Chemical Agent Disposal System DECONTAMINATION Decontamination Technologies Decontamination techniques and processes, involving chemical, mechanical, and thermal methods, have been developed for the removal of hazardous materials from systems, structures, and components (SSCs), to soil and water. The primary objectives of decontamination are to reduce exposure, reduce the potential release of hazardous materials to clean areas, and enable decontaminated equipment and materials to be salvaged and reused. For JACADS closure, a key objective will be to meet the end-state criteria for the land and the SSCs that are left in place. The Decommissioning Plan provides the engineering and operational details for closure activities (U.S. Army, 2000c, 2000d). The Plan’s Appendix 2, Annex 2-A, the Decontamination Report, describes potential decontamination methods for SSCs and concrete and the process used for the identification, evaluation, and selection of several decontamination and decommissioning technologies (U.S. Army, 2000d). A search was conducted relating to recent industrial experience with the closure of facilities containing hazardous materials, particularly chemical agents. A plethora of decontamination technologies was identified through this search that included both existing and emerging and innovative technologies. These were summarized in a lengthy table (Table 2-A.1) in the Decommissioning Plan (U.S. Army, 2000d). SSCs that will require decontamination include the tank systems for the collection and storage of agent; spent decontamination and brine solutions; trench and sump liners; heating, ventilation, and air conditioning (HVAC) systems; laboratory support buildings; incinerators, furnaces, and contaminated areas of the Munitions Demilitarization Building (MDB); and pollution abatement systems. The Decontamination Report identifies and evaluates current and innovative decontamination and treatment technologies. The technology evaluation criteria (consistent with RCRA guidance) include the following: effectiveness of the method for a specific application past reliability in terms of operation and maintenance requirements capital costs and operations and maintenance costs feasibility of implementation with respect to energy requirements, permit modifications, system modifications, secondary wastes produced, and risks to personnel and the environment quantity of secondary wastes produced and their disposal costs WDC (formerly Raytheon) evaluated many technologies obtained from the literature, the Internet, and equipment vendors. Based on these evaluations, the primary decontamination technologies proposed for JACADS closure were existing technologies that had been successfully used either at other government sites or in industrial applications. The Stockpile Committee agrees that existing technologies appear appropriate and that there does not appear to be any requirement for specialized technology for this application. However, one area in need of further development (discussed in Chapter 4) involves the employment of modern techniques for agent detection and analysis in various media. The Decontamination Report provides an overall strategy for removing hazardous materials from the MDB, SWMUs, and AOIs. A contamination investigation (RFI), yet to be completed, will provide the detailed characterization data to support closure activities. The characterizations will be based in part on analysis of concrete core borings taken from selected locations. Adjacent Sources of Contamination Although the Army is responsible for closure of only the JACADS area of Johnston Island, a closure plan that integrates Air Force and Army closure activities would provide opportunities for cost savings. It might, for example, allow eliminating cross-contamination and reducing disposal costs. Concrete The MDB is a two-story, steel-framed building with thick, reinforced-concrete floors and most interior walls made of concrete and foam-core sandwich panels. Explosion containment rooms have 2-foot-thick reinforced concrete floors, walls, and ceilings. Because concrete is a porous material capable of absorbing agent, all concrete surfaces in the JACADS process areas were sealed with an epoxy coating. A total of 134,153 square feet of concrete will require decontamination (U.S. Army, 1999d). The Decontamination Report assumed that application of a decontamination solution to concrete will not be sufficient for personnel to have unrestricted access to agent-contaminated areas, and that removal of the epoxy coating and some surface concrete will be necessary. Numerous surface cleaning/removal technologies were identified using literature and vendor information, including hydroblasting, carbon dioxide blasting, shot blasting, and scabbling.16 Scabbling was selected on the basis of its documented industrial performance and proven cost-effectiveness. It has also been used successfully by the Department of Energy and commercial nuclear facilities to decontaminate concrete areas exposed to radiation (DOE, 1994). The Decontamination Report states that it would take 160 days to thermally 16 Scabbling is a scarification process used to remove concrete surfaces. Scabblers utilize several piston heads, which contain tungsten carbide cutters to cut or chip away concrete surfaces.
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Closure and Johnston Atoll Chemical Agent Disposal System decontaminate the total volume of concrete with potential surface contamination to a depth of 0.25 inch by processing it through the MPF (U.S. Army, 2000d). The technical basis for selecting a nominal 0.25-inch scabbling depth is documented in the Environmental Closure Plan Outline and Regulatory Review for USACAP Operations Johnston Island, Johnson Atoll (CH2MHILL, 1998). A 0.25-inch depth is also consistent with the requirements of U.S. law (40 CFR 268.45(a)(1) Table 1, “Alternative Treatment Standards for Hazardous Debris”) and with previous experience in decontaminating radioactive concrete structures. Although 0.25-inch scabbling may be adequate to decontaminate most concrete surfaces in the MDB, agent may have penetrated much further in some places (e.g., along cracks and reinforcing bars and in joints between the floor and walls). A procedure for verifying the absence of agent in hard-to-reach locations has not been established. If agent has seeped into these places, additional concrete will have to be removed. The JACADS closure schedule is based on removing 0.25 inch of concrete from agent-contaminated surfaces and an MPF utilization rate of 60 percent, or 345 lb/hr. This is based on a permitted burn rate of 575 lb/hr (feed rate of one munitions tray containing 700 lb of material every 73 minutes) (U.S. Army, 2000d). The thick epoxy coating could limit the scabbling rate and affect the closure schedule unless at least 345 lb/hr can be removed. As the furnace can operate at a higher feed rate, there is some built-in contingency. Beyond that, the completion date will slip. The schedule could also be compromised by the need to decontaminate places in the concrete where agent has penetrated much more than 0.25 inch. Core borings of floors and walls in the MDB might be expected to show how far agent has penetrated into the concrete. However, borings of this type are usually done with diamond-tipped core bits, often with water cooling the cutting edge. The heat and moisture involved in this operation could substantially change the chemical composition of the sample and might vaporize or chemically alter any agent that was present before the sample was taken; as a result, the analytical results for agent values might underreport the amount of agent actually present in the concrete. SCHEDULE AND COST ESTIMATES Closure operations at JACADS began approximately in January 2001 and are estimated by the Army and WDC to be completed in October 2003, a total of 33 months17 (Bushman, 2001). The closure criteria given in the Facility Closure Plan states as follows (U.S. Army, 2000a): Closure of JACADS will be accomplished by demonstrating the absence of identified regulated substances or waste-related compounds: On surfaces within the facility and waste storage areas; On surfaces and the subsurfaces surrounding the facility and waste storage areas; On subsurfaces directly beneath the facility, and waste storage areas where necessary; On or within any other area or structure deemed to be included in the JACADS Closure Campaign (JCC) through the RCRA Facility Assessment (RFA) or other means. At the time the schedule was developed, there were significant uncertainties, the most important of which was EPA’s failure to agree on the end state for the site in the absence of a decision on end use. The Army and WDC assumed that industrial standards would apply rather than more stringent residential standards. However, this issue has not been settled. Moreover, EPA agreement will be required for RCRA permit modifications C3-050 and C3-051 and any new ones. Failure to obtain approval for any of these modifications will further prolong the closure schedule. The main impetus for completing closure as quickly as possible is the high cost of continued operations (it reportedly costs $331,500 per day for JACADS with a full complement of personnel) (Bushman, 2000). The initial cost estimate in early 1999 for the JACADS closure program was $70 million to $80 million.18 This estimate was labeled a rough, order-of-magnitude estimate that, because it did not include certain noncontractor charges, was rather optimistic. Another estimate given to the committee in September 1999 was $150 million (Bushman, 1999). The most current estimate is between $200 million and $400 million.19 Final cost estimates for each permit modification can be made only after EPA approval. The estimate of $200 million to $400 million is based on the assumption that EPA will require only the industrial cleanup standard. If, however, EPA chooses the residential standard, it is estimated that there will be a substantial increase in cost and considerable uncertainty owing to the unknown difficulty of the more rigorous cleaning and the timing of the switch in standards. The timing of a possible switch in standards, particularly if it occurs after completion of the present cleanup, would give rise to an avoidable cost and therefore merits consideration. 17 Gary N. McCloskey, JACADS Site Project Manager, conversation with Stockpile Committee member Charles I. McGinnis on February 24, 2000. 18 See footnote 3. 19 See footnote 3.
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Closure and Johnston Atoll Chemical Agent Disposal System DEVELOPMENT AND IMPLEMENTATION OF A SAFETY PROGRAM A key element of the mission of the CSDP is to eliminate safely the aging U.S. stockpile of chemical agents and munitions. The Army has in place safety and occupational and environmental health programs at chemical agent disposal facilities that have been visited by the Stockpile Committee (NRC, 2001). The committee found these programs to be comprehensive, professional, and adequate to meet the occupational health and safety needs of the CSDP workers as well as to protect the public and the environment (NRC, 2001). As part of its risk management program (RMP), PMCD has issued requirements that apply to both the operation and the closure of the disposal facilities. The risk management requirements published in Chemical Agent Disposal Facility Risk Management Program Requirements (U.S. Army, 1996) include a safety program (PMCD R 385-1), which specifies policies, responsibilities, and procedures to protect workers, the public, and the environment and to avoid the accidental loss of property; a system safety management plan (PMCD R 385-2), which describes a framework for the implementation of a formal safety program; and an incident and accident reporting, investigating, and records component (PMCD-385-3), which provides mechanisms for reporting and analyzing incidents and accidents. Combined with the facility’s policies and practices, the RMP requirements are intended to create an effective safety culture, which must be an integral part of closure planning. The RMP is carried out by the management and operations contractors and their subcontractors, but the Army is ultimately accountable. The safety and industrial hygiene requirements for JACADS are provided in two site-specific plans, Safety Assessment and Accident Prevention (PL-11) and Occupational Health and Hygiene Plan (PL-40), which incorporate the industrial safety requirements in Occupational Safety and Health Administration 29 CFR 1910.120 (U.S. Army, 1997, 2001a). As the transition from operations to closure proceeds, maintaining safety standards will become more difficult because of the changing configuration of the facility and the many one-of-a-kind demolition operations. For example, coprocessing of waste while parts of the facility are being demolished to allow the installation of the carbon micronization system will be a very risky undertaking due to simultaneous operation and alteration of the plant’s ventilation system. Safety will require the full commitment of each worker and all levels of management. The committee has observed that the site contractor at JACADS conducts process hazards reviews and frequent safety briefings with the workers that will help prevent accidents and injuries during the closure operations. SECURITY AND SURETY REQUIREMENTS General Security Although the remote location of Johnston Atoll provides a degree of natural security, the sensitive nature of the storage and demilitarization of chemical weapons has required additional security precautions. Johnston Island, where the sensitive operations are concentrated, is the responsibility of the installation commander, Detachment 1, 15th Air Base Wing, U.S. Air Force Pacific: “The mission of the islandwide security force is to provide normal police force function, law enforcement, enforcement of installation traffic control, and air terminal passenger security screening” (U.S. Army, 2000f). The Air Force security force currently comprises 13 civilian employees of the base operations support contractor. Physical Security of Storage Areas and the Processing Facility U.S. Army Chemical Activity–Pacific (USACAP) and JACADS, tenants on the island, have larger security contingents associated with their operations. USACAP provides approximately 250 people, military and civilian, for the surety program, and the JACADS security mission has about 720 people, including military, contract civilian, and civil service personnel involved (U.S. Army, 2000f). The Commander USACAP, the JACADS site project manager, and the WDC project manager are responsible for their own people and the organizational elements subordinate to them or under their contract control. “The mission of the JACADS security force and an important objective of the surety program is to properly safeguard chemical agents against sabotage, theft, loss, seizure, or unauthorized access, use or diversion through the application of stringent physical security measures” (U.S. Army, 2000f). Chemical Surety Program The chemical surety program is a Department of Defense-mandated program. It is a system of safety and security control measures designed to protect the local population, workers, and the environment by ensuring that chemical agent operations are conducted safely, that chemical agents are secure, and that personnel involved in those operations meet the highest standards of reliability (U.S. Army, 2000f). The commander at each level and contractor supervisors are responsible for implementation of an integrated management system based on the Army Chemical Surety Program and contract requirements. The program specifies accountability for the chemical agent inventory and controls access to storage and processing areas (U.S. Army, 2000f).
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Closure and Johnston Atoll Chemical Agent Disposal System Surety and Security After Completion of Agent Operations The Army does not anticipate the presence of Army personnel on Johnston Atoll after the completion of the cleanup and closure required by the RCRA permit. USACAP is expected to phase out its surety program first. According to Army Regulation 50-6, dated 1 February 1995, “Installation or site surety status will be terminated when all chemical agent in accessible form has been demilitarized, detoxified, transferred, or consumed in experimentation.” At that point, the USACAP commander will send a memorandum requesting termination of surety requirements to Headquarters, Department of the Army. The request must include supporting certifications and reports. Upon approval of the USACAP request, a memorandum will be issued terminating surety status. Regular safety and routine physical security activities will continue to protect personnel, facilities, and materiel from pilferage, unauthorized use, sabotage, and violation of community rules and regulations by any source, internal or external (U.S. Army, 1995, 2000f). Conceivably, the island could be the target of unauthorized entry and trespassing from the air or sea. Thus, a security presence appears to be warranted until final ownership of the island is established. JACADS will require a continuing security contingent following the departure of USACAP to protect workmen and other island residents until the JACADS facility has been declared closed and its property transferred to the installation commander. Then, the only security required following JACADS closure would be to protect remaining government property (U.S. Army, 2000f).