4
Executing the Closure Plan

The PMCD intends to close JACADS (and, subsequently, chemical agent disposal facilities at sites in the continental United States) as quickly as possible after agent disposal operations have been completed through cost-effective means and in full compliance with all applicable permits and regulations. To accomplish this, the workforce that conducted the operations phase will be carried over through the closure phase, with the addition of a few specialized subcontractor personnel. Nevertheless, workforce morale may decline, as it almost invariably does, when a construction or demolition project nears completion. In anticipation of the problem, WDC, the Army’s contractor for JACADS operations and facility closure, proposed a personnel-retention plan to the Army that provides incentives for personnel to remain at JACADS for specific closure operations. The plan has been approved for implementation; coupled with a worker-recognition program, it should provide workers with more than just satisfaction at the successful completion of a difficult, dangerous, and vitally important task. To this end, the retention plan provides employees with a percentage of gross annual pay that is accumulated monthly and payable at the end of the employee’s assignment.

DECONTAMINATION OF SYSTEMS, STRUCTURES, AND COMPONENTS

A decontamination plan must be based on accurate knowledge of the kinds and extent of contamination present. Prior to the removal of systems, structures, and components (SSC) other than those needed for MPF operation, the external surfaces of equipment and components, as well as walls, floors, and ceilings of rooms and areas that have been contaminated with agent, will have to be decontaminated. Three methods will be used:

  • chemical decontamination—using sodium hydroxide (1 or 18 percent), sodium hypochlorite (5 or 5.25 percent), soap (Visco 15 and Whistle), and water and steam, alone or in combination

  • mechanical decontamination—using mechanical techniques such as scabbling, scarifying, water-jet cutting, and grit blasting

  • thermal decontamination—as necessary, particularly after structures are taken down, using existing furnaces or other means

One or more of these methods may be necessary to achieve the desired decontamination levels, four of which are described in Table 2-1 of the Decontamination Report (Appendix 2) in the Decommissioning Plan (U.S. Army, 2000d).

During agent processing and during closure of all CSDP disposal facilities, secondary wastes will be generated. Minimizing the quantity of these wastes and developing a plan for their destruction/disposal will reduce both operating and closure costs. The Army has addressed this problem in its waste minimization program (see subsection “Waste Minimization” later in this chapter) (U.S. Army, 2000d). The sites employing alternative technologies will not have furnaces available for processing items such as demilitarization protective ensembles (DPE). How the Army is going to address secondary waste processing/disposal at these sites without using furnaces has not been resolved. The Army should pursue means for addressing site-specific secondary waste processing and disposal issues using technologies other than incineration and incorporate this information into design and/ or operating permits where appropriate.

REMOVAL OF SYSTEMS, STRUCTURES, AND COMPONENTS

Risks During Dismantlement

Although processes for razing facilities have been used for years in the chemical industry, detailed procedures vary



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Closure and Johnston Atoll Chemical Agent Disposal System 4 Executing the Closure Plan The PMCD intends to close JACADS (and, subsequently, chemical agent disposal facilities at sites in the continental United States) as quickly as possible after agent disposal operations have been completed through cost-effective means and in full compliance with all applicable permits and regulations. To accomplish this, the workforce that conducted the operations phase will be carried over through the closure phase, with the addition of a few specialized subcontractor personnel. Nevertheless, workforce morale may decline, as it almost invariably does, when a construction or demolition project nears completion. In anticipation of the problem, WDC, the Army’s contractor for JACADS operations and facility closure, proposed a personnel-retention plan to the Army that provides incentives for personnel to remain at JACADS for specific closure operations. The plan has been approved for implementation; coupled with a worker-recognition program, it should provide workers with more than just satisfaction at the successful completion of a difficult, dangerous, and vitally important task. To this end, the retention plan provides employees with a percentage of gross annual pay that is accumulated monthly and payable at the end of the employee’s assignment. DECONTAMINATION OF SYSTEMS, STRUCTURES, AND COMPONENTS A decontamination plan must be based on accurate knowledge of the kinds and extent of contamination present. Prior to the removal of systems, structures, and components (SSC) other than those needed for MPF operation, the external surfaces of equipment and components, as well as walls, floors, and ceilings of rooms and areas that have been contaminated with agent, will have to be decontaminated. Three methods will be used: chemical decontamination—using sodium hydroxide (1 or 18 percent), sodium hypochlorite (5 or 5.25 percent), soap (Visco 15 and Whistle), and water and steam, alone or in combination mechanical decontamination—using mechanical techniques such as scabbling, scarifying, water-jet cutting, and grit blasting thermal decontamination—as necessary, particularly after structures are taken down, using existing furnaces or other means One or more of these methods may be necessary to achieve the desired decontamination levels, four of which are described in Table 2-1 of the Decontamination Report (Appendix 2) in the Decommissioning Plan (U.S. Army, 2000d). During agent processing and during closure of all CSDP disposal facilities, secondary wastes will be generated. Minimizing the quantity of these wastes and developing a plan for their destruction/disposal will reduce both operating and closure costs. The Army has addressed this problem in its waste minimization program (see subsection “Waste Minimization” later in this chapter) (U.S. Army, 2000d). The sites employing alternative technologies will not have furnaces available for processing items such as demilitarization protective ensembles (DPE). How the Army is going to address secondary waste processing/disposal at these sites without using furnaces has not been resolved. The Army should pursue means for addressing site-specific secondary waste processing and disposal issues using technologies other than incineration and incorporate this information into design and/ or operating permits where appropriate. REMOVAL OF SYSTEMS, STRUCTURES, AND COMPONENTS Risks During Dismantlement Although processes for razing facilities have been used for years in the chemical industry, detailed procedures vary

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Closure and Johnston Atoll Chemical Agent Disposal System widely among companies, geographical areas, and types of products that were produced. In this regard, the closure of JACADS will be the first razing of a chemical agent disposal facility anywhere in the United States. Some aspects of the baseline incineration disposal system used at JACADS may present unique hazards, risks, and challenges that will have to be addressed. The JACADS experience can provide a prototype for future closure activities at other sites and a wealth of lessons learned. The extent of contamination at JACADS can only be estimated at this time. For example, closure experience from other, non-Army sites suggests the possible intrusion of agent contamination into concrete floor slabs in the explosion containment rooms and adjacent processing areas (U.S. Army, 2000a, 2000c, 2000d). The level of protection afforded to the concrete by the epoxy layer is unknown, as is the extent of agent contamination in the epoxy itself. The extent of contamination intrusion into other niches and recesses is also unknown. Processing equipment has been repeatedly saturated with agent and subsequently washed down with decontamination solution during the course of disposal operations, but the extent of residual contamination is unknown. Monitoring for several agents will be necessary during JACADS closure (as it will be for most other baseline incineration facilities) to ensure that the decontamination has been effective. While agent-specific monitors for multiple agents can be used, employing a simple, reliable, single-unit multiagent monitor might prove as effective and more convenient. Closure demolition operations will generate significant quantities of particulates, which may contain hazardous chemicals, including agent. It is important to evaluate both the need for monitoring (at the location of closure activity and/or at the site boundary) and the potential health and/or ecological risks associated with particulate transport. During closure, workers in some locations must be initially protected with DPEs. A lesser level of protective dress may be acceptable as work progresses and proof of safe conditions is obtained. Concurrent closure activities and operations for the disposal of agent-contaminated waste are planned for JACADS and could take place at other facilities as well. Under such circumstances, the normal flow of activities and material could be disrupted and risks increased. Frequent changes in material flow, in HVAC routing, and in utility provisions might be encountered. To minimize the danger, planning must be meticulous and workers must comply with procedures and remain vigilant. In addition, as closure progresses and the dismantlement of the facility advances, workers will increasingly be required to handle heavy materials and equipment, including machinery, metal ducts, piping, and bulk material such as concrete removed from the facility. Closure activities will necessarily span several typhoon seasons. A direct strike could leave a tangled mass of material that would be difficult and dangerous to handle. Careful planning can reduce the risks associated with scheduled closure operations, but nothing can eliminate the threat of severe weather. Because closure is a new and unprecedented activity at JACADS and unexpected problems may arise during field activities, it may not be possible to identify all sources of risk during the planning phase. However, good project planning, risk assessment, and experienced proactive management can reduce the uncertainty. If new sources become evident as work progresses, they must be carefully addressed and the experience recorded to assist in closures of other disposal facilities. In the case of JACADS, there will be no risk to the public or environment other than those already identified in the operational quantitative risk assessment and health risk assessment. This may not be the case for the other eight sites. The JACADS experience will provide information on which assessments for the remaining sites can be based. Closure Safety and Health Risks Sources of risk will change during closure. During operations, the main risk is from the handling and destruction of chemical agents and associated energetics. During closure, especially once the agents and energetics have been destroyed, the main hazards will shift to the more conventional risks of dismantling and demolition. Hazards that may be encountered include the following: 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 These conditions may create a hazardous work environment that could be unfamiliar to many disposal operations employees. Safety statistics for the construction industry published by the Occupational Safety and Health Administration for 1997 and 1998 show an annual average of 2.5 times more fatal occupational injuries to workers during wrecking and demolition activities than during heavy construction (SIC Code 162, SIC Code 179, Department of Labor, 1999). The number of nonfatal occupational injuries for wrecking and demolition workers was 4.8 times higher than for heavy construction workers. Obviously, industrial safety will be a continuing challenge that will require a heightened sense of safety awareness and strict compliance

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Closure and Johnston Atoll Chemical Agent Disposal System with procedures and good work practices. To minimize risk, the Army should consider using the technology used by industry, such as three-dimensional computer graphics that track facility configuration during demolition and remote teleoperated equipment. Contaminated Material and Equipment Because the nature and extent of all agent and other chemical contamination will not be established until closure work is already in progress, planning is necessarily uncertain, and decommissioning, dismantlement, and demolition operations are certain to be complicated and potentially hazardous. The uncertainty is complicated by the nature and extent of contamination by agent and agent breakdown products, and the evolving methodologies for detection and analysis (e.g., surface detection techniques). Based on information presented to the committee in March 2001, no analytical method has been developed and approved to detect agent and agent breakdown products in concrete and soil. The use of protective dress for much of the dismantlement operation introduces additional risk, because such dress compromises a workers’ vision and hearing and slows their movements. Moreover, the probability of heat-related injuries increases in proportion to the time worked in protective dress. Decontamination of machinery will require handling of parts and components that are not normally or easily accessible. Machines may have to be broken or cut into smaller units for handling by workers and processing in the MPF. HVAC System Utility Services The committee’s review of the closure documentation indicates that the Army has carefully considered HVAC system phasing during closure to ensure that pressure differentials in subsystems are maintained and exhaust gases are routed through appropriate filters before release to the atmosphere. However, a breakdown in coordination and communication during transition and reconfiguration phases could raise safety concerns in addition to those of handling heavy ductwork. Planning is necessarily based on the information and assumptions available at the time the plan is developed. An unexpected discovery of agent contamination may require modification of the plan. The availability of utility services to areas of the plant that are continuing waste disposal operations will have to be ensured. This includes the operation of secondary systems such as the HVAC cascade ventilation system through which incoming plant air proceeds from areas of low toxic concentration to areas of higher toxic concentration before being passed through carbon filters and then released to the atmosphere. At the same time, the safety of workers will require deenergizing and disconnecting selected electrical power circuits and other utilities to the areas being dismantled. Equipment Following decontamination and removal, machinery and equipment can be prepared for final disposition. Disposing of them on Johnston Island would yield significant cost savings but will depend on the criteria and permit requirements for the end state for Johnston Atoll. If off-island shipment is necessary, the risk of accidents from handling and packaging machine components and fragments for shipment by barge and subsequently by rail or truck in the continental United States will have to be addressed. Buildings and Structures The removal of significant structural components and systems from buildings must be planned and evaluated to ascertain the effects on structural stability. The removal of floor systems, an increase in the effective length of columns, an increase in the span of beams, and changes in the distribution of loads or load patterns from those assumed in the original design could be dangerous. Temporary loads, such as heavy equipment or stacked material, must be anticipated and controlled. Planning should include access and egress routes, both routine and emergency, to prevent the inadvertent isolation of workers. Because an accumulation of debris invites injury, the cleanliness of the worksite will be especially important during demolition activities. Dismantling operations will create materials that are heavy and unwieldy. Handling heavy objects will create a risk of damaging structures and equipment still in operation or intended for abandonment in place. Workers could also incur risks. The placement and use of lifting equipment must be carefully planned to minimize the possibility of boom overload, collision of a boom or load with fixed objects, and contact with energized electrical distribution lines. The end use of Johnston Island will dictate which structures can be abandoned and which will require modifications. Good advanced planning can minimize wasted effort in meeting end-state requirements. Safety Program Given the unique nature of JACADS closure activities and the possible lack of worker experience with demolition-related safety procedures, planning and preparation for each task involved in closure will be essential. Timely discussions with appropriate craftsmen, supervisors, and safety professionals in planning the work and determining hazards will help in identifying risks and developing appropriate procedures. The Construction Industry Institute has noted that conferences before execution of a task help to prevent mishaps (CII, 1993). Fail-safe communication and coordination procedures typically used by the construction industry will be essential during decommissioning, dismantlement, and

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Closure and Johnston Atoll Chemical Agent Disposal System demolition. Lock-out, tag-out, and hazardous activity permit procedures should be mandatory. In the unique environment of decommissioning, ensuring that agent contamination, agent-breakdown products, and other chemical contamination are within acceptable limits for all media (including solids and liquids) will be essential for worker safety and worker morale. The Army currently uses multiple automatic continuous air monitoring system (ACAMS) and depot area air monitoring system (DAAMS) monitors to detect the presence of multiple agents in air. These systems should be carefully evaluated to ensure that they will provide MACT compliance.1 Furthermore, as previously noted by the committee in an earlier report on work-place monitoring, testing for surface contamination as currently planned is not state of the art (NRC, 2001).2 PMCD has no experience with the removal of machinery on a facility-wide basis or the detection of agent intrusion into structural elements such as concrete. To ensure worker safety and compliance with permit requirements, and to minimize the time and cost of closure, the Army will have to use state-of-the-art detection systems and sampling and analysis techniques (NRC, 2001). Safety Reporting Reporting accidents and near misses will be critical to the safety program. Procedures must be implemented to ensure that reporting is prompt, reports are professionally analyzed, and lessons learned are quickly disseminated. In the event of a fatality or other serious accident, independent safety experts should investigate causes and formulate corrective actions. Personal accountability throughout the chain of supervision is a proven technique for encouraging commitment to safety. Safety awareness and actions must have the strong personal commitment of all managers, supervisors, and employees in PMCD and its contractor organizations. MONITORING OF AREAS, WORKERS, AND MATERIALS Closure activities will require monitoring of solids, liquids, and air to maintain safe working conditions and to prevent the release of agent, agent-contaminated materials, and degradation products to the environment. Monitoring should include the following goals: detecting agent detecting any contamination that might expose workers, the public, and the environment verifying compliance with established standards alerting workers to out-of-specification conditions demonstrating that no off-site particulate contamination occurs providing data to decisionmakers for developing corrective actions providing historical data Agents could be exposed and vaporized as the configuration of the facility changes during disassembly activities. Therefore, air monitoring of areas, materials, and people will require close, continuous management and worker attention. If agent exposure is suspected, the monitoring of blood cholinesterase in potentially exposed employees will be carried out in accordance with the medical surveillance program followed during disposal operations. As closure operations progress, walls and floors will be removed, HVAC systems will be modified, and monitoring instruments will be removed and/or relocated. Monitoring during closure will be quite different from monitoring during normal operations. The monitoring plan should include postclosure monitoring (discussed in Chapter 5) where appropriate. During scabbling or similar operations, there is a potential to generate significant amounts of particulates. Particulate sampling at the site boundary during these operations is important. It could provide records that demonstrate hazardous chemicals are not leaving the site via this pathway during closure activities. Multiagent Monitoring of Areas and Workers Because JACADS has been used to destroy weapons and bulk stores of GB, VX, and HD, closure activities will involve potential worker exposure to all three chemical agents and their degradation products. Residual reservoirs of any of these agents may become exposed during disassembly of the facility, and the agents may vaporize, leading to harmful airborne concentrations. Therefore, it will be necessary to verify that decontamination procedures for equipment, waste streams, and building materials have destroyed any significant agent residue. The sampling and analysis plan in Annex 2E of the JACADS Closure Campaign Decommissioning Plan stated that monitoring of airborne agent other than particulates will be performed by ACAMS monitors backed up by DAAMS monitors (U.S. Army, 2000c). These were the systems used to monitor airborne agent during disposal operations at JACADS, and they continue to be used for this purpose at TOCDF (NRC, 2001). The ACAMS monitors are automated gas chromatographs with flame photometric detectors that automatically set off an alarm when any airborne agent exceeds preset levels (typically 20 percent of a specified 1   MACT refers to “maximum achievable control technology” regulations recently instituted by EPA defining more stringent limits for emissions into the air. 2   Charles E. Kolb, vice chair of the committee, memorandum to the committee on new technology to detect chemical agent and agent breakdown products on surfaces (with five enclosures on use of SIMS technique) dated March 22, 2000.

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Closure and Johnston Atoll Chemical Agent Disposal System agent hazard level). ACAMS monitors provide a measurement every 2 to 10 minutes, depending on the target agent and the preset hazard level. The DAAMS monitors, which consist of active air sampling sorbent canisters, are periodically collected and transported to the laboratory, where any agent collected is desorbed and analyzed by gas chromatography. The DAAMS monitors are used to confirm ACAMS agent detection and to quantify low-level concentrations of agent collected over several hours. The primary change to the monitoring program as a consequence of EPA permit modification C-2-052 having been approved, will be a reduction in perimeter monitoring and utilization of DAAMS monitoring in place of many ACAMS detectors for demonstrating compliance with agent emission limits at regulated process vents (EPA, 2000). This approach could be ill-advised as long as agent-contaminated materials are being fed to the furnaces. The Decommissioning Plan, produced by WDC for the Army, states as follows in Annex 2, page 18: “Since the air monitoring devices are equipped to monitor one specific agent at a time, provisions must be in place to monitor all three agents (GB, VX and HD) during sampling activities” (U.S. Army, 2000c). Monitoring for all three agents was done only in the unpack area and on the common stack during disposal operations at JACADS. For closure activities, the Facility Closure Plan calls (on page 61) for elimination of ACAMS monitoring on the common stack, because agent is not expected to be present at detectable levels during normal furnace operations, based on trial burns and routine performance data (U.S. Army, 2000a). However, agent-contaminated DPE suits and carbon, for example, could contain substantial amounts of any of the three agents that were stored at Johnston Island. Without near-real-time ACAMS alarms for all three, one or more could conceivably escape from the common stack during abnormal or upset conditions, as occurred in an incident at TOCDF in May 2000. The sampling and analysis plan from the Facility Closure Plan indicates that samples from liquid-phase waste streams and solid materials will be analyzed for agent contamination by chloroform extraction followed by gas chromatographic analysis (U.S. Army, 2000a). However, Table 2-E.4, Analytical Methods Summary (Appendix 2 of the Decommissioning Plan), indicates that the analytical method for chemical warfare agents (CWAs) is to be determined (U.S. Army, 2000c). This inconsistency notwithstanding, the analytical procedures will presumably be performed on samples transported to the laboratory and extracted. A sufficient number of gas chromatography instruments equipped with both sulfur and phosphorus detectors will be necessary to analyze these samples and any samples resulting from the increased number of DAAMS tubes. The increase in analyses cannot be handled by the small number of gas chromatographs currently deployed in the laboratory. The number of gas chromatography instruments and operators and the sufficiency of existing laboratory space will have to be determined. Finally, the possibility of using advanced technologies, such as secondary ion mass spectrometry (SIMS), to directly measure contamination by agent and/or agent breakdown product on solid surfaces is not discussed in the closure planning documentation (U.S. Army, 2000a, 2000c, 2000d). Recent studies indicate that such measurements might eliminate the need for time-consuming extraction procedures that use hazardous solvents such as chloroform (Groenewold et al., 1995, 1998, 1999, 2000). They also indicate that SIMS may be used to detect VX and its breakdown products in soil and concrete and HD on various surfaces. Relative to the safety program discussed earlier in this chapter, and considering the potential benefits to be derived from the employment of advanced monitoring technologies, the committee believes that there is probably a need for developing specialized technology in this area. WASTE MANAGEMENT The Problem The amount of agent-contaminated wastes to be disposed of during closure is estimated to be approximately 5.8 million pounds, according to the Facility Closure Plan (Table 1 in the Plan) (U.S. Army, 2000a). This quantity includes (1) waste stored on-site as of April 2000, (2) predicted increases in waste until the end of the munitions campaign (completed November 2000), (3) coprocessing of heavy machinery, (4) USACAP waste inventory, and (5) closure wastes from dismantlement and decontamination primarily in the MDB. Approximately 2.1 million pounds is expected from the dismantlement of the first and second floors of the MDB and the HVAC systems. In addition, approximately 250,000 gallons, or 2.3 million pounds, of spent decontamination solution will be generated during decontamination activities in the MDB. As of April 30, 2000, approximately 900,000 pounds of secondary wastes (including USACAP stored waste) had been generated and kept in long-term storage in the Red Hat Storage Area. In the waste inventory table of the Facility Closure Plan, Section 3.2, an estimated additional 120,500 pounds of agent-contaminated materials would be generated from the VX mine campaign and an additional 370,000 pounds during closure (not including spent decontamination solution) (U.S. Army, 2000a). The closure plan groups the permitted hazardous waste management units (HWMUs) for JACADS and the Red Hat storage area into five categories: (1) tank systems, (2) incinerators, (3) miscellaneous treatment units, (4) the munitions demilitarization building (MDB), and (5) permitted container storage areas. How buried and above-ground piping would be categorized is not apparent. Each category presents a different set of waste management issues that depend on the chemicals to be analyzed and the cleanup levels to be achieved. The closure plan, as submitted, is somewhat unusual in that the RCRA facility investigation (RFI), the

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Closure and Johnston Atoll Chemical Agent Disposal System analytical protocols, and the risk assessments are not finalized. Because the extent of contamination is uncertain, particularly in concrete, it is difficult to devise a well-documented and -formulated plan for managing closure. Also, the lack of analytical protocols accepted by EPA makes it difficult to specify some elements of the waste management plan, such as appropriate sampling frequencies, furnace feed specifications for materials like concrete, waste storage locations after treatment, and the ultimate destination for wastes if off-island disposal is required. The Process Much of the hazardous waste will be stored on the island until treated or transported to a treatment, storage, and disposal facility (TSDF) in the United States. Wastes accumulated as of October 2000 were listed in the Decommissioning Plan (U.S. Army, 2000d). These included 132,285 lb of DPE suits, 45,512 lb of inert bulk solid wastes, and 2,010 lb of spent hydraulic fluid. However, final amounts will not be known until closure activities are completed in 2003 and the areas certified as clean. The wastes stored in three buildings in the Red Hat Storage Area (Buildings 850, 851, and 852) and in 16 bunkers have been categorized in the RCRA permit. All of the agent-contaminated hazardous wastes generated during closure will be treated, according to the RCRA permit for the facility, predominantly by incineration. Nonagent-contaminated hazardous waste generated during closure will be managed according to regulations applicable to the generators of such waste (40 CFR 261) and shipped off-site before the end of closure. The RCRA permit has been modified to include this newly identified secondary waste. A description of plans and schedules for temporarily staging and transporting wastes is necessary, in that doing so provides an opportunity to predetermine and accommodate operational contingencies and related risks. Since hazardous wastes, including PCBs, would require appropriate notifications and manifesting, such planning and scheduling could be readily incorporated into the closure plan. This would include shipping requirements of 40 CFR 262 and 263 and DOT transportation requirements codified in Title 49. Some recognition is given to issues like these in the October 2000 Facility Closure Plan (U.S. Army, 2000a). Moreover, leachate collection, runoff control, spill and discharge controls, erosion control, and asbestos abatement could also be integrated into the overall waste management procedures. Countermeasures for problems such as these are highlighted in JACADS Procedure PL-15, which contains a contingency plan and a spill prevention, control, and countermeasures plan, both of which are required by 40 CFR 112 (U.S. Army, 2001b). Waste Minimization Waste minimization was considered in initial closure planning documents (June 1999) in terms of the JACADS Waste Minimization Program, PP-42, implemented to govern operational waste reduction efforts in accordance with the 1984 RCRA Hazardous and Solid Waste Amendments (U.S. Army, 1999d). From the more recent Facility Closure Plan, it appears that the earlier waste minimization program does not address the activities that will be conducted during closure (U.S. Army, 2000c). Integration of an effective waste minimization program into the closure effort may help focus the development of cost-effective decontamination strategies and overall waste management protocols. PUBLIC COMMUNICATIONS AND INVOLVEMENT Background The Army’s Chemical Stockpile Disposal Program (CSDP) for destroying chemical agents and munitions has long been of intense interest to elements of the public, including communities near planned and operational chemical agent disposal facilities. Public involvement is an inherent activity when National Environmental Policy Act3 and EPA regulations regarding RCRA permit processing apply. Johnston Atoll has had a long history of military activity dating back to the 1930s, including its use before and during World War II as a Pacific base, during the 1950s and 1960s as a launch facility for testing nuclear weapons, during the 1960s as a staging area for the shipment of Agent Orange to Vietnam, and from the 1980s to the present as a storage and disposal site for chemical agents and ammunition. All of these activities resulted in numerous incidents of hazardous material contamination of the islands comprising the atoll by the several agencies involved. Current regulations require cleanup to standards much more stringent than those that often applied when these incidents occurred. Public interest in most chemical agent storage sites was moderately high throughout the 1990s. Interest in JACADS peaked in mid-1990 as a result of the decision to transport the U.S. stockpile in Germany to Johnston Island. At that time, stakeholder meetings were well attended, with participants expressing some degree of agitation.4 In the last 2 years, however, there has been less public interest in the closure of JACADS. Recent public meetings have been relatively amiable, sparsely attended, and supportive of both the 3   The National Environmental Policy Act requires certain procedures for public input on and documentation concerning the preparation of a thorough environmental impact statement regarding activities undertaken by the federal government that have environmental impacts. 4   Marilyn Daughdrill, Public Affairs Director, PMCD, personal communication to Stockpile Committee member Charles I. McGinnis on October 26, 2000.

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Closure and Johnston Atoll Chemical Agent Disposal System public affairs effort and the operational plan for closure. Factors contributing to the public’s apparent disinterest include growing public confidence in the manner in which disposal operations were carried out and completed, the island’s remote location, and the absence of an indigenous native population. Interest in Johnston Island and JACADS activities among members of the public has intensified as a result of the formation of a regulatory working group consisting of state, regional, and national (EPA) regulators with jurisdiction over stockpile sites. This group has met regularly during the closure planning process and apparently perceives decisions involving JACADS as precedents for similar decisions at continental U.S. disposal sites. Some active members of the community (including nongovernmental organizations and Pacific Islanders) have attended these meetings and have filed written opinions with the EPA. Army and contractor representatives believe these opinions have significantly influenced regulatory working group positions. While JACADS in many ways serves as a prototype for closure expectations and activities elsewhere, the stakeholder challenge is not as great. In the continental United States, closure activities will probably be followed closely by political leaders at every level from local to federal, by concerned local citizen groups, and by activist citizen groups. Stakeholder activity will inject a higher level of uncertainty into planning, regulatory decisions, costs, and scheduling. Intensified public involvement will become increasingly important in planning and executing future closures smoothly. Public Information and Outreach for JACADS Public information and outreach activities at continental U.S. storage and disposal sites have been vigorously implemented by PMCD, and the reactions of elected officials and the public at large to these efforts have varied from site to site (NRC, 2000b). No such activities were ever set up specifically for Johnston Island, although support for public information activities concerning JACADS has been provided by the PMCD headquarters in Aberdeen, Maryland. Moreover, the PMCD project manager for JACADS has been directly involved in and personally committed to pursuing a vigorous public information and outreach activity in the Pacific region of the facility, particularly Hawaii. In view of the remoteness of Johnston Island, the experience of public outreach efforts there may not be particularly predictive of the experience of such efforts in the continental United States. A recent survey on community perspectives at the eight continental U.S. stockpile sites by a PMCD contractor at the University of Arizona excluded JACADS because of its atypical situation (Williams et al., 1999). Because there is no indigenous population adjacent to JACADS with whom to communicate, emphasis has been on other stakeholders, and no citizens advisory commission was established to represent local community interests. Outreach has been promoted by inviting reporters and stakeholder representatives to visit Johnston Island, where they receive briefings and view JACADS operations. The need to coordinate this activity with the Air Force, the current owner of Johnston Island, has added complexity to the outreach activities.5 Because of the unique jurisdictional issues surrounding the closure of JACADS within the overall context of the ultimate fate of the entire Johnston Atoll (see Chapter 2), it has been difficult to coordinate information given to the public by the multiple governmental agencies involved with Johnston Island. The Stockpile Committee has maintained a high interest in the public involvement activities associated with the Chemical Stockpile Disposal Program, such that it has published two relatively extensive letter reports on the subject: Public Involvement and the Army Chemical Stockpile Disposal Program (NRC, 1996) and A Review of the Army’s Public Affairs Efforts in Support of the Chemical Stockpile Disposal Program (NRC, 2000b). The Program Manager for Chemical Demilitarization and staff have these reports, which include findings and recommendations, available for their reference. Stakeholder Issues It is important to identify site-specific stakeholders early in the closure planning phase. The stakeholders in disposal operations and closure of JACADS include the following: U.S. Army, particularly PMCD and the U.S. Army Chemical Activity Pacific (USACAP), which is responsible for managing the Johnston Island stockpile storage area contractors and consultants U.S. Air Force Defense Threat Reduction Agency (U.S. Department of Defense) Fish and Wildlife Service (U.S. Department of the Interior) National Marine Fisheries Service (National Oceanic and Atmospheric Administration) U.S. Coast Guard (U.S. Department of Transportation) Environmental Protection Agency Federal Aviation Administration (U.S. Department of Transportation) environmental activist groups from the United States and Pacific island chains potential commercial investors in Johnston Island commercial transportation companies doing business on Johnston Island 5   Gary N. McCloskey, JACADS Site Project Manager, conversation with Stockpile Committee member Charles I. McGinnis on February 24, 2000.

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Closure and Johnston Atoll Chemical Agent Disposal System Pacific Islanders media representatives Chemical Weapons Convention technical and diplomatic observers legislators Some issues of concern to stakeholders may be addressed by reassuring them of the following: JACADS will not be converted to a permanent waste disposal site. No residual contamination will remain that could affect the land, water, or air surrounding the site. Disposal operations and closure activities are proceeding safely, within regulatory guidelines, according to a published, transparent plan, and without the prospect of bad surprises. Upon closure, all regulatory and end-state requirements will have been met. After closure, long-term monitoring and stewardship will be provided. The committee believes that government stakeholders will confront the following responsibilities: reaching agreement on end-use and end-state criteria, and communicating the decisions clearly to the public living within budgetary constraints and assigning responsibility for multiple tasks and for overall coordination in such a way that the outcomes are acceptable to participants and to their external constituencies achieving compliance with U.S. regulations and the Chemical Weapons Convention and minimizing cost, while at the same time earning public support safely transporting materials from JACADS to the continental United States providing safe and permanent storage or disposal of waste materials Planning for Transition to Closure Public outreach established during operations should continue seamlessly as emphasis shifts from operations to closure. Outreach activities for closure provide an opportunity to showcase operational accomplishments. Since public hearings may (depending on the RCRA modification classification) be required before new permits, or significant modifications to existing permits, can be issued, closure planning offers an opportunity to continue dialogue with interested stakeholders. Careful planning can ensure that timely notice of hearings and meetings is provided to all interested parties and that they are encouraged to participate. For issues of special sensitivity, proper responses can be prepared in advance of formal meetings to ensure against surprises to or from internal or external stakeholders (U.S. Army, 1999c).