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Findings and Recommendations The committee's overall findings and recommen- dations are listed below. The high-level findings and recommendations are listed first and represent what the committee deems most important. These are followed by more general findings and recommendations, and finally, comments are included specific to major research areas. Detailed recommendations are found in Chapter 2. As noted earlier, the committee chose to provide EPA review and recommendations for key areas rather than perform a detailed review of every proposal in the RIP. Given the short time frame, the committee felt this would best provide EPA guidance for the remaining time in the program. OVERARCHING FINDINGS AND RECOMMENDATIONS EPA has correctly identified the major research areas essential for the Safe Buildings Program. The primary areas of research associated with an effective building decontamination strategy are pre- sented in the Safe Buildings Program Research Imple- mentation Plan: detection, containment, decontamina- tion, and disposal. The duration of the current program is insufficient to deal with all the tasks and goals presented in the Research Implementation Plan. 19 As specifically noted in the various findings and recommendations, the program time frame (scheduled to end at the end of fiscal year 2005) is too short to effectively accomplish all the goals set forth in the Research Implementation Plan. The proposed plan covers an extensive area of new research, of which the scope and breadth is too large to accomplish in the allotted time frame. Given current resources and the extramural collaborations of EPA, it is unrealistic to expect results in all areas of proposed research in the . . . remaining time. The current effort should include a planning func- tion for a potential longer-term research program to address unmet needs in technical areas. The short time frame proposed in the Research Implementation Plan is an overarching concern; accordingly, the committee has made specific recom- mendations for tasks that can reasonably be completed in three years or less. One of these tasks should be the development of a coordinated program for a long-term research and development effort focusing on the agency's strengths. In some areas, the committee has provided guidance or recommendations for long-term research activities. In the short term, the program should focus almost exclusively on decontamination and disposal issues

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20 and other parts of the program should be subordi- nate to decontamination and disposal. EPA has expertise in the area of decontamination and disposal. The agency should focus the remaining time toward improving these aspects of its work. Activities in the remaining areas detection and con- tainment should technically support decontamination and disposal in a logical manner to achieve results within the prescribed time period of the program. The committee has made specific recommendations for these areas, as described below. GENERAL FINDINGS AND RECOMMENDATIONS EPA should develop a more interactive system to communicate and collaborate with other govern- ment agencies. Throughout the course of its review, committee members were able to identify related programs and projects in other agencies that were not accounted for in EPA's planning process. This is understandable given the short time EPA had to start up the Safe Build- ings Program. More effort and resources should be expended in communicating with other agencies having research programs in these areas. Academic laborato- ries should be encouraged to participate in longer-term research. Participants should include people from other government agencies, industry, and academia. EPA should develop an external scientific advisory board for this program that does not include current con- tractors. The key research areas require milestones toward meeting the goals of the program and measures of success that concretely reflect the degree to which EPA's recommendations improve building safety in accordance with program goals. The Safe Buildings Program will likely be most successful if specific, realistic program goals are set early in the program and success or failure is system- atically measured against those goals as the program evolves. This will ensure that each program area is adequately progressing as well as ensure that resources remain focused on successful ventures. REVIEW OF EPA HOMELAND SECURITY EFFORTS SPECIFIC FINDINGS AND RECOMMENDATIONS Detection In the short term, EPA does not have the capabilities to develop new preventative detection technologies. Very specific technical skills are required for the difficult tasks associated with developing preventative (i.e., "detect-to-warn") detection technologies. The tasks include designing realistic tests, creating valid sampling and detection protocols, arranging accurate instrument calibration samples and variable strength, statistically robust, contaminant challenges in appro- priate matrixes, and accurately scoring the performance of a range of instruments based on disparate physical, chemical, and/or biological principles. Because this is a relatively new activity for EPA, the design of detec- tion technologies for use in real-time warning or reaction modes is not realistic given the three-year time frame of the Research Implementation Plan. EPA's role in detection should be to set standards for required detector performance (e.g., limits of detection, accuracy, detection time, operational availability, etc.) either for agents or for decontaminants. There are three detection areas for which EPA should play a role. First, detection for determining that re-entry of a building is safe is a valid research area and within the scope of EPA's authority and expertise. Second, EPA should also be involved in setting stan- dards or requirements for detection limits, particularly through interagency coordination. Third, EPA has experience in certification testing of pollutant detec- tors and detection systems through its Environmental Technology Verification (ETV) program. The agency can thus play a role in setting the test protocol standards and sponsoring the test beds for testing commercial equipment to meet the detection standards provided by EPA. Containment In the short term, EPA does not have the expertise to develop active, real-time building protection systems.

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FINDINGS AND RECOMMENDATIONS The challenge of providing meaningful advice related to real-time containment of a biological or chemical attack lies in the vast number of chemical or biological agents, each with its own toxicity level, detection signatures, and dispersion characteristics. In addition, there is an essentially unbounded number of building types. Conceivably, advice pertaining to HVAC design and operation, while relevant to the con- tainment of chemical and biological agents in the event of contaminant entry into a building, might actually lead to the spread of the contaminant if acted on in either an untimely manner (i.e., after contaminant entry into the building) or in a building context not imagined by the agency. In addition, the proposed containment research appears to be an assembly of existing research ideas rather than a response designed to answer critical questions in the field. A longer term research plan is needed to effectively address these issues. The RIP should differentiate between long-term versus short-term goals in the area of containment. The committee recommends that EPA use the next few years to define a comprehensive long-term research program in this area. This should be carried out in con- junction with other organizations knowledgeable in this field, including National Institute of Standards and Technology, Department of Energy, Department of Homeland Security, and academic researchers. Detailed recommendations for long-term research goals can be found in Chapter 2. The RIP should seek to develop building perfor- mance criteria and standards. Projects in the proposed containment RIP cover a variety of fundamental and applied topics relevant to the mitigation of CBR attacks. However, the RIP does not address one of the most important practical needs for new containment system design: the development of design criteria and performance standards. The containment focus in the RIP should be on decontamination and disposal efforts. One area of containment that is in the purview of EPA and is of crucial importance to future EPA recom- mendations is the role of containment during decon- tamination and disposal. After contamination of a building by chemical or biological substances, those 21 involved in decontamination and disposal operations will inevitably face problems of continued transport of chemical and biological agents, in part through resuspension of previously deposited particles. Under- standing these problems could be an important task for EPA, and could lead to practical guidelines. For detailed recommendations on the decontamination effort refer to Chapter 2. Decontamination EPA has expertise and resources in decontamina- tion technology and assessment. In general, the committee feels that the EPA's Safe Buildings Program is on target with respect to decon- tamination efforts ongoing and proposed. The research program does need to be expanded to include gas phase decontaminants other than chlorine dioxide. The RIP should fund efforts to develop standards and protocols for decontamination that distinguish between requirements for chemical and biological threats as well as develop and evaluate sampling technologies and protocols for decontamination. The overall focus should be to develop standards and protocols that distinguish between requirements for chemical or toxic industrial chemicals and biological threats. Additional guidance and statistical sampling protocols should also be developed similar to those developed and used by DOE and EPA for radiological sampling (EPA et al., 1997). EPA's role in decontamination should include evaluation of decontamination technologies through an effectively structured ETV program. This is an important national role for EPA. The EPA should help set a longer-term research agenda for decontamination and restoration. Research needs include (1) development of methods to rapidly determine agent-specific viability for effec- tive verification of biological agent decontamination, (2) technologies, systems, and studies to better charac- terize the extent of chemical and biological contamina- tion resulting from a terrorist attack, and (3) develop- ment of methods for better, cheaper, safer and faster

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22 decontamination of facilities and other contaminated areas. Disposal EPA has a great deal of knowledge and background in the area of waste disposal. The proposed waste disposal strategy and research projects therein reflect the EPA's expertise in handling hazardous materials disposal issues, its experience in responding to the recent anthrax decontamination ef- fort, and its overall experience in hazardous waste cleanup through implementation of Superfund cleanup and removal actions. In the area of disposal the RIP should concentrate on the interactions, effects, and potential for genera- tion of toxic residues from the interactions of bio- logical decontamination agents with building mate- rials, furniture, and carpets. Understanding the fate of the decontaminants with regard to specific building materials may be useful, but more important are the resulting residues and whether they represent a significant health risk. EPA needs to conduct an analysis of competing and overlapping federal, state, and local regulations and ordinances that might prevent the application of certain disposal technologies. Thermal treatments and incineration may not be viable approaches in many states where air quality issues are a concern. For example, California does not have a permitted hazardous or medical waste incinera- tor and only has three municipal facilities that use incineration as a permitted waste transformation processes. There are only a handful of operating incinerators around the country. Investigations as to whether these few incinerators can handle the bulky items identified in the project proposals need to be considered by EPA. In addition, guidance documents need to be developed for emergency managers that specify the best disposal options available. A criterion needs to be developed by EPA to deter- mine the efficiency of decontamination efforts that REVIEW OF EPA HOMELAND SECURITY EFFORTS would allow decontaminated materials to be dis- posed in municipal landfills. Better understanding of the survivability of organ- isms of concern may allow for landfill disposal options. Additionally, the committee recommends that EPA have a strategy for developing methods for stabilizing waste materials so that they meet land disposal require- ments. Cross-Cutting The decontamination and disposal strategies and proposals presented in the RIP are not well coordi- nated. EPA identifies thermal treatments as a disposal option however thermal treatments are also decontami- nation methods. To be effective these overlapping areas need to be better coordinated. The EPA's effort should include a case study of the recent anthrax decontamination experience, focus- ing on decontamination and disposal. Evaluations of the responses to recent anthrax con- tamination of congressional and Post Office facilities demonstrate the severe management and technical dif- ficulties posed by even a modestly scaled biological attack. Understanding the real-world conditions and results should provide a baseline for the engineering and economic analyses of building decontamination alternatives. A successful EPA Safe Buildings Program should show a significant decrease in the amount of time required to restore a building. The goal should be on the order of weeks and not months. EPA should establish evaluation parameters, speci- fications, and needs for safe building systems and systems components and work with systems and components developers to establish their market potential. For systems and systems components with signifi- cant market potential, EPA should use the ETV pro- gram to establish which systems and components meet required safe building specifications. This applies to decontamination, containment, and detection systems.