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OCR for page 5
2
Assessment
NRC ASSESSMENT CONTEXT AND CRITERIA
The committee recognizes that the building protec-
tion and decontamination tasks the Environmental
Protection Agency (EPA) has been given are both
exceedingly important and extremely challenging.
Analyses of the decision processes required to effec-
tively handle a chemical or biological attack on a
civilian or public sector facility demonstrate that a wide
range of time-critical information and technical capa-
bilities are required to identify, respond to, character-
ize, and decontaminate or remediate the resulting
damage (Raber et al. 2002~. Evaluations of the
responses to recent anthrax contamination of congres-
sional and Post Office facilities clearly demonstrate the
severe management and technical difficulties posed by
even a modest biological attack (EPA, 2002; GAO,
2003b). While some straightforward measures have
been identified to protect buildings from chemical or
biological attacks (CDCINIOSH, 2002), more compre-
hensive attack warning, evaluation, and containment
strategies will require extensive advances in building
systems and their components.
The EPA Safe Buildings Program was conceived
as a comprehensive response to these challenges. The
lEPA, 2003, Research Implementation Plan Safe Buildings
Program (Draft), presented to the committee on May 13, 2003, by
N. Adams, Environmental Protection Agency, Research Triangle
Park, NC.
program is motivated by a threat analysis performed by
the agency with input from a range of relevant federal
sources.2 However, the current program is constrained
by the time frame (three years total, approximately
30 months remaining at the start of this review pro-
cess). Given the time currently available to the
program, the committee has attempted to identify criti-
cal safe building research and development challenges
that might be substantially completed within the time
and cost constraints as well as to note those that will
clearly require longer time frames or more substantial
budgets or both to ensure significant progress.
It is also apparent to the committee that execution
of any safe buildings program will require an extremely
wide range of chemical, biological, engineering, and
social science expertise. EPA' s traditional role of pro-
tecting human health and ecosystem viability from
insult by industrial and commercial products and by-
products has resulted in many staff and contractor
capabilities that are very pertinent to the safe buildings
challenge. However, the agency and its contractors
may not have all the skills required to specify, develop,
evaluate, and demonstrate desirable safe buildings
2EPA, 2003, Analysis of Potential Scenarios for Terrorist Attacks
on Buildings with Biological or Chemical Agents (Draft), Lemieux,
P., Adams, N., and Sparks, L., presented to the committee on July
10, 2003, by N. Adams, Environmental Protection Agency,
Research Triangle Park, NC.
s
OCR for page 6
6
technology components and systems. The committee
has attempted to identify Safe Buildings Program tasks
that require technical expertise in areas where the
agency has strong and in some cases even unique capa-
bilities; as well as to flag those tasks for which the
agency will need to develop new skills or acquire new
collaborators to succeed.
Given the time scale for the current Safe Buildings
Program, the committee recommends that priority be
given to those tasks that can reasonably be completed
within the program time frame and that draw most
heavily on the technical expertise of EPA's laborato-
ries and current contractors. The committee also
recommends that longer-range tasks and those that
require the development of expanded capabilities be
deferred in the short term or undertaken only in close
collaboration with agencies and organizations with the
required capabilities.
The committee notes that the threat scenario used
to define the Safe Buildings Programs should be used
to identify priority needs and to set program goals. The
Safe Buildings Program will likely be most successful
when specific, realistic program goals are set early in
the program and when success or failure is consistently
and systematically measured against those goals as the
program evolves. In the assessments of each Safe
Buildings Program element presented below the com-
mittee identifies goals and measures of success.
EPA also has a list for measures of success within
the three-year time framed:
· identify the most important threats (key drivers
.
of the program);
develop and define appropriate and effective
methods for detecting, containing, and decon-
taminating events relating to these top threats;
· produce methods and guidance for understanding
and predicting human health risks;
· lead the development of clean-up standards; and
3EPA, 2003, Analysis of Potential Scenarios for Terrorist Attacks
on Buildings with Biological or Chemical Agents (Draft), Lemieux,
P., Adams, N., and Sparks, L., presented to the committee on July
10, 2003, by N. Adams, Environmental Protection Agency,
Research Triangle Park, NC.
4EPA, 2003, Research Planning in the Safe Buildings Program
Report to the National Academies, presented to the committee on
June 30, 2003, by N. Adams, Environmental Protection Agency,
Research Triangle Park, NC, p. 29.
REVIEW OF EPA HOMELAND SECURITY EFFORTS
· distribute methods/guidance to building owners,
responders, and appropriate public officials (An
additional measure of success will be successful
use of these technologies and the guidance by our
customers.)
The committee' s assessment evaluates the program
in the context of these success factors as well as others
identified by the committee in its discussions.
DETECTION
Different Approaches to Chemical and Biological
Detection and Characterization Systems
In 1999 the National Research Council (1999a) dis-
cussed numerous biological and chemical detection
systems, many of which have since been improved. The
advantages and disadvantages of these systems should
be incorportated into EPA's strategy for characteriza-
tion, decontamination, and recovery. The technologies
most applicable to monitoring and notification for any
agent must be sensitive enough to detect agent concen-
trations at or below health risk levels, specific enough
to provide acceptable false-alarm rates, and prompt
enough for notification consistent with effective medi-
cal response. This generally equates to a critical
response time of minutes for chemical agents and toxic
industrial chemicals and days for most biological
agents. For attacks using chemical warfare agents,
symptoms are typically prompt, with coughing, chok-
ing, distress, and sometimes death occurring as soon as
seconds after exposure. Detectors must respond in
nearly real time to minimize exposures and guide medi-
cal intervention. Following a chemical attack it is likely
that well-established hazardous material operations
would be conducted during the notification phase.
Chemical sensors that respond quickly are already
available commercially from several sources, and
analytic instruments incorporating preconcentration
methods are already available to detect and identify
chemical warfare agents at or below known health risk
limits. Many of these methods have been developed to
support either the military or the current international
chemical weapons treaty verification program. After
the Aum Shinrikyo attack in Tokyo, strategies have
been investigated for detecting and responding to
chemical warfare agents in semi-enclosed structures,
such as subways and airports. In the United States,
OCR for page 7
ASSESSMENT
much of this work has been conducted through agencies
that are now part of the Department of Homeland
Security. The NRC Committee on Safe Buildings Pro-
gram recommends that EPA continue to utilize these
ongoing studies to aid implementation of the Safe
Buildings Program.
For biological attacks detection can be based on
environmental monitoring, epidemiological monitor-
ing, or an unusual diagnosis, as was the case with the
inhalation anthrax incidents. Actual detection of an
event is much more difficult and the time delay is
significant when compared with chemical incidents.
Several projects both within EPA and other agencies
are underway to enhance early detection and notifica-
tion, and some environmental monitoring systems have
already been deployed in major U.S. metropolitan areas
(Cole, 2003~. Because many biological threat agents
are zoonotic (outbreaks naturally occurring in animals),
biodetection systems must discriminate between
unnatural events and naturally occurring backgrounds.
For all detection systems it is important to recog-
nize that detectors alone do not directly measure threats
to people. For instance, chemical detectors often can-
not detect the lowest dose known to be a health risk
without a Reconcentration step, and biological detec-
tors usually cannot determine viability of an agent or
other important health-associated attributes, such as
antibiotic resistance. Historically the military has set
standards for chemical and biological detection for
battlefield scenarios. The civilian community needs
standards and uniform test protocols to ensure that sys-
tems perform predictably and that decision makers will
be confident they will understand the information pro-
vided. Civilian applications demand high standards for
performance, including low false alarm rates. An
important role for the EPA Safe Buildings Program
would be the establishing of these standards and uni-
form test protocols.
Detection to Assess Containment and for Post-
Decontamination Evaluation
The stated focus of the Safe Buildings Program is
building decontamination,5 and it is in decontamina-
sEPA, 2003, Research Planning in the Safe Buildings Program
Report to the National Academies, presented to the committee on
June 30, 2003, by N. Adams, Environmental Protection Agency,
Research Triangle Park, NC, p. 5.
7
tion rather than detection that the EPA has leading
expertise. Thus, the detection program should focus
exclusively on decontamination, as indicated by the
information provided to the panel from EPA. All tech-
nical parts of the program should be subordinate to de-
contamination and each part should technically sup-
port decontamination to achieve results within the
prescribed time period of the program (approximately
30 additional months).
The specific components of detections that the
committee feels should be highlighted are
· the creation and publication of decontamination
standards;
· specific specifications for detectors to support de-
contamination; and
field-testing of detectors and decontamination
strategies against the specifications provided
above.
.
The committee concludes that EPA should lead the
development of cleanup standards and sponsor and su-
pervise realistic field tests to validate the decontamina-
tion protocols, including detection equipment for de-
termining that necessary re-entry levels have been
met. Beyond that, for the area of detection the mea-
sures of success given by EPA all fall into less impor-
tant categories and should be removed from the EPA's
funding portfolio since they do not support the
program's primary objective.
Test-Beds and Protocols for Technological Systems
EPA's expertise in building safety has been on
facility rehabilitation. As such, the concept of restora-
tion of service is a key tenet of the EPA's core strength.
To continue to effectively accomplish the mission of
building safety and restoration EPA needs to focus its
research in the Safe Buildings Program on decontami-
nation and disposal. The components of the Safe Build-
ings program that are related to detection need to be
fully directed toward support of the primary mission of
decontamination and disposal. The components of the
program that deal with detect-to-warn, in the
6EPA, 2003, Research Planning in the Safe Buildings Program
Report to the National Academies, presented to the committee on
June 30, 2003, by N. Adams, Environmental Protection Agency,
Research Triangle Park, NC, p. 23.
OCR for page 8
8
committee's view, have little possibility for benefit to
either EPA or Homeland Security under the scope and
duration of the program, as the program duration is too
short to successfully complete this effort. Due to the
limited time available, EPA should focus on decon-
tamination. Any research on detect-to-warn, other than
by collaborating with other agencies, is outside the cur-
rent scope of EPA, and it would be unrealistic for EPA
to expect any results in the remaining time.
A second overarching issue is the need to accom-
plish results within the program time frame. The com-
mittee detected a lack of focus during the first six
months of research that has resulted in a dilution of the
overall program. The committee feels that significant
restructuring of detector research is needed, because
detection has a number of components that are impor-
tant to decontamination efforts. The committee feels
that in the remaining 30 months in the program, the
detection area should be focused to support the more
tractable area of decontamination.
Specifically, EPA needs to focus a significant
amount of its detection capabilities on answering the
question "How clean is clean?" The establishment of
standards for decontamination is within the purview of
EPA, and it should take the lead in these efforts and be
assisted by NIST and the Science and Technology
Directorate of the Department of Homeland Security.
In summary, detector development should play a
subordinate role to other components of EPA's Sci-
ence and Technology program for homeland security.
The area of detector development is not one in which
EPA should play a leading role, nor is it one in which
EPA should play a development role. EPA should be
involved in setting standards for decontamination, as
well as in testing commercial equipment to achieve the
level of decontamination standards that detection will
certify. This means that EPA must collaborate with
other agencies to establish relevant standards and test-
ing protocols.
As noted above, the committee recommends that
EPA not pursue detect-to-warn systems further (due to
the complexity of the issues and because this is outside
EPA's primary expertise). If EPA chooses to pursue
further research in this area, it is essential that the speci-
fications of the warning system be tied to meaningful
endpoints. For example, acute toxicology (or infectiv-
ity) thresholds for agents of concern should be consid-
ered, and the detection limit should be low enough
(considering sampling time) that the agent can be
detected before causing significant toxicity. If an agent
REVIEW OF EPA HOMELAND SECURITY EFFORTS
can be detected before causing toxicity, then indi-
viduals that would have been infected otherwise have a
chance to get out of the building and the decontamina-
tion procedure can begin at an earlier time.
Specifications for detection for re-entry should take
into account the toxicology of the agents of interest.
The detector should be able to detect levels exceeding
chronic health guidelines (e.g., exceeding the reference
concentration) following measurement for a specified
period of time. Sampling time for reliable measure-
ments should also be considered, although such con-
siderations are less limiting, because measurement for
re-entry can include sampling times on the order of
days.
Role of the EPA Environmental Technology
Verification Program
Establishment of required chemical and biological
agent detectors and detection systems for a range of
potential applications is an important challenge for
EPA's Safe Buildings Program. More robust, sensi-
tive, specific, and faster responding sensors will be
necessary for successful containment, decontamina-
tion, and potentially even disposal activities. However,
specification of sensor capabilities will not be suffi-
cient; detection instruments and integrated sensor
systems must be proven under realistically simulated
conditions using both surrogate and, in many cases,
actual chemical and biological substances.
Substantial technical effort and resources will be
required to test threat agent detectors and detection sys-
tems. Technical skills will be needed in
designing realistic tests;
- creating valid sampling and detection protocols;
- arranging accurate instrument calibration samples
and variable-strength, statistically robust, con-
taminant challenges in appropriate matrixes; and
· accurately scoring the performance of a range of
instruments based on disparate physical, chemi-
cal, or biological principles.
The difficulty increases when the use of military
grade chemical or biological agents requires a level of
isolation and containment available only in certified
surety facilities. To be credible, verification testing
must be done in independent trials designed, operated,
and scored by third parties with no direct stake in their
outcome.
OCR for page 9
ASSESSMENT
Through its Environmental Technology Verifica-
tion (ETV) program EPA has experience in certifica-
tion testing of pollutant detectors and detection systems
and would be appropriate to extend this program to
cover threat agent detectors and detection systems. For
current ETV projects an EPA contractor designs the
test program and invites instrument developers and
vendors to bring prototypes or early production instru-
ments to the test for certification. Scientists and engi-
neers from EPA and other agencies may contribute to
test specifications and design and also attend the verifi-
cation tests.
CONTAINMENT
Importance of Understanding Buildings
Buildings represent an important threat and exPo-
sure category for the deliberate or accidental release of
chemical or biological agents. Most of us spend
between 75 and 90 percent of our time in buildings at
work, at home, in schools, or in commercial establish-
ments. Buildings themselves and their occupants may
be direct targets of a chemical or biological attack or an
indirect target (downwind of a release targeted at
another facility); in either event buildings can offer
potential safe havens. Buildings and building opera-
tions can also help confine and spread harmful con-
taminants.
The focus of EPA's containment research is on the
development and testing of methods to prevent the
spread of contaminants thereby protecting building
occupants, first responders, and decontamination
crews. The overall objective is to reduce or eliminate
the impact of a chemical or biological attack on build-
ing occupants as well as to provide techniques and
guidance to determine the efficacy of chemical and bio-
logical protection measures for new and existing build-
ings. The research seeks to understand the building so
as to aid in safe, efficient, and cost-effective restoration.
The spread of contaminants in a building is gener-
ally by air circulation in large open spaces, airflow
between connecting spaces, and airflow in heating,
ventilating, and air-conditioning ducts. To devise a
containment strategy it is important to understand the
physics of air exchange caused by mechanical means,
such as HVAC fans, buoyancy, and external wind con-
ditions.
There are many building types, and containment
must take into account their characteristics. They range
9
from large open-plan buildings, such as stadiums, shop-
ping centers, and transportation hubs, to buildings
subdivided into modular spaces, such as apartment
buildings and offices with separate workspaces. Some
buildings are designed as sealed boxes ventilated
mechanically, while others are open to the outside air
through operable windows and other large apertures.
Research is needed to understand the rate at which
a contaminant introduced into a specific interior space
spreads throughout the building. For contaminants
introduced into the intake or ducts of an HVAC sys-
tem, the spread and concentration levels throughout the
building must be predicted. Exposure within the build-
ing from exterior sources must be tied to the perfor-
mance of the building envelope and the HVAC system.
Understanding of contaminant distribution must
then be coupled with an understanding of HVAC sys-
tem operations and control systems in order to develop
short-term protection strategies. The strategies range
from isolation of an individual space to modified opera-
tion or shut down of HVAC circulation systems to
building evacuation through spaces protected from
contaminant intrusion. Protective measures using
HVAC shutdown must be evaluated against adverse
health effects caused by loss of ventilation over vary-
ing time periods.
A better understanding of building classes is
needed to guide longer-term decontamination efforts
as well. This will help define locations for monitoring
and sampling based on predicted contaminant dispersal
patterns. Ventilation techniques to clear the building of
decontamination agents are linked to an understanding
of airflow patterns under different HVAC operations.
The building materials and furnishings may exhibit
long-term emissions of contaminant agents and decon-
tamination substances.
Relevance of EPA Program
EPA has a long history of research both on indoor
air quality and on buildings. Some of this work has
been intramural, while a significant amount has been
extramural support for research at a variety of institu-
tions, such as academia to the national laboratories and
private industry and organizations. Containment of
toxins, released either indoors or outdoors, so that
human exposures are avoided or minimized, will
clearly benefit from research on indoor air and on build-
ings. However, the containment research proposed by
the EPA's National Homeland Security Research
OCR for page 10
10
Center (NHSRC) is more an assembly of existing
research ideas than what is needed to answer critical
questions in the field. An additional difficulty is the
program's three-year limit (to the beginning of fiscal
year 2006), which means that a longer-term research
agenda cannot be formulated and work on key elements
begun until the deadline is renegotiated or work is
re-integrated into other EPA research centers and
activities without loss of direction or commitment.
EPA appears ill-suited for a short-term research
program in the area of "active" containment. In the
time remaining EPA containment research should have
three main objectives: (1) ensure that decontamination
strategies account for all potential transport and fate
pathways and surfaces in a building to ensure that
building decontamination, cleanup, and disposal prac-
tices effectively and economically meet the desired
criteria; (2) identify and prioritize key long-term
building science and containment research needs and
determine the role EPA should have in conducting or
funding the research; and (3) in collaboration with
industrial organizations and other agencies, develop
design and performance criteria and standards for con-
taminant containment systems and methods.
Containment Focus
One area of containment covered by EPA's man-
date that is of crucial importance to future EPA recom-
mendations is the role of containment during decon-
tamination and disposal. Containment and disposal
will be handled by professionals who will be actively
controlling the environment of the building. The ki-
netics of containment can be better understood in these
controlled circumstances. However, people involved
in decontamination and disposal operations will inevi-
tably face problems of continued transport of chemical
and biological agents, in part through resuspension of
previously deposited particles. Understanding these
problems and having supporting data and models to
address these requirements should be an important,
immediate EPA task, and could lead to guidelines in a
shorter time frame than work on active containment.
Areas of possible EPA focus are HVAC use, aerosol
and gas penetration through doors, and inadvertent dis-
persal of contaminants (i.e., many of the themes to be
studied by EPA in the broader containment framework)
specifically in the framework of decontamination and
disposal.
REVIEW OF EPA HOMELAND SECURITY EFFORTS
Another potential research topic is to use airflow
and contaminant transport and fate modeling to help
examine some of the contamination issues. It is an
important task to protect the public by ensuring that
decontamination materials are not lost to the environ-
ment and to maintain control over the building airflow
to ensure that a building is decontaminated as effi-
ciently as possible. Airflow circulation within a build-
ing can scatter contaminants and decontamination
agents in ways that may limit the efficiency of the
decontamination effort. Therefore, control is necessary
to prevent contaminants from re-entering decontami-
nated areas and allow decontamination agents to prop-
erly disperse so that toxic materials can be neutralized.
Identify Long-Term Research Needs and Determine
EPA's Role
Many of the containment issues cannot be
addressed adequately in a three-year program, in part
because of the dearth of past and current research in
this field by EPA, other government agencies, and
academia. The committee recommends that EPA use
the next few years to define a comprehensive long-term
research program in this area, and it should be carried
out with other organizations knowledgeable in this
field, including NIST, DOE, the Department of Home-
land Security and academic researchers in the United
States, Europe, and Japan. This research should incor-
porate the following:
· Evaluation of existing multizone airflow and
transport models, such as CONTAM (NIST) and
COMIS (LBNL), for predicting air and contami-
nant movement for application to the problem of
understanding the transport and fate of biological
and chemical contaminants and decontaminating
agents;
· Development or evaluation of modeling methods
for detailed simulation of contamination dispersal
in a single space that can be coupled to a multi-
zone model for overall building behavior to
specifically include ductwork and vents;
Development of containment strategies for im-
portant generic building types to include securing
safe spaces, evacuation, and decontamination;
Coupling of design of HVAC systems and con-
trols with potential fast detection technologies for
releases in and outside buildings;
OCR for page 11
ASSESSMENT
.
Prediction of contaminant dispersal patterns to aid
in decontamination;
Development of effective means for removing
gaseous decontamination products;
Characterization of the long-term reemission of
contaminates from building materials and fur-
nishings; and
Development of a building taxonomy for catego-
rizing new and existing building stock according
to building operations, contaminant transport, and
other characteristics.
EPA has begun to identify the long-term research
needs in this area and whether existing or planned pro-
grams in other agencies effectively explore them. The
agency has recognized that much of this research will
be collaborative, either in funding specific projects with
other governmental agencies or funding separate
projects that have collaborative or synergistic out-
comes. A key activity for which EPA is well posi-
tioned is to identify some common research goals and
priorities across the various agencies, both as a way of
directing EPA research to fill in critical research gaps
and as a means establishing interagency cooperation in
sharing knowledge, if not research goals.
Building Performance Criteria and Standards
Projects in the proposed containment Research
Implementation Plan (RIP) cover a variety of funda-
mental and applied topics on the mitigation of chemi-
cal and biological warfare (CBW) attacks. The RIP
does not consider one of the most important needs for
containment system design: the development of design
criteria and performance standards.
For example, a comfort air-conditioning system is
designed to maintain a particular indoor temperature
and humidity given specified occupancy and weather
conditions. The indoor conditions are selected to
ensure that at least 80 percent of the occupants of the
conditioned space will be satisfied with the thermal
environment. The parallel analysis for a CBW contain-
ment system could be to limit the maximum exposure
over a defined period in a given space to a design-basis
release of an agent. Considering the spectrum of CBW
agents that could be used in a terrorist attack, a design-
basis set of agents, both gas-phase and aerosol, may be
needed.
The performance standards that must be met by a
system or component and the design conditions that
define the reasonable worst-case scenario under which
the system must operate drive the design process.
Without them the level of protection afforded by a sys-
tem is not well defined. Consequently, the engineers
and other professionals responsible for designing and
implementing containment systems will not have all of
the information they need to cost-effectively ensure the
desired performance.
Successful pursuit of this objective will require
collaboration with agencies outside EPA with high
expertise in HVAC systems, air flow analysis, and
health effects of chemical and biological exposures. To
fully achieve consensus design standards, interaction
with organizations such as American Society of Heat-
ing, Refrigerating, and Air-Conditioning Engineers and
the American Society for Testing and Materials may
be required. This is a longer-term project but should be
initiated as soon as possible because of its importance.
Even interim standards and criteria would be of great
value.
The vast number of chemical and biological agents,
each with its own toxicity signature, and the essentially
unbound number of building types, creates a challenge
to providing meaningful advice regarding containment
during an attack. 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 preparing the advice. The understand-
ing of how contaminants spread in a building (even
how they spread from the opening of an envelope in a
very specific room scenario) will need to be gained
through extensive experimentation, evaluation of data
currently in existence, and generation of data in likely
threat scenarios. This understanding will inevitably
parallel to some degree the improvement of detection
equipment; in any case, such knowledge will need to
be acquired over a period of time far greater than the
current EPA mandate.
DECONTAMINATION
A complete national-level program for protection
against CBW agents and toxic industrial chemicals
(TIC) must also include elements to respond to an
attack. It is essential to develop and test technologies
to mitigate and decontaminate the effects of a CBW
OCR for page 12
12
agent or 11(: attack on facilities and people as well as
to restore critical facilities after they are attacked. This
committee sees EPA's primary role as one of giving
the nation an ability to completely restore domestic
facilities rapidly and safely after an attack.
The committee agrees that the need to develop and
implement effective decontamination technologies and
health-protective cleanup standards for civilian sce-
narios is urgent. The anthrax incidents illustrate impor-
tant problems associated with decontamination of
civilian-sector facilities. For example, more than three
months were required to clean up the Hart Senate
Office Building at an EPA cost recently reported to be
about $27 million, while the American Media, Inc.,
headquarters building in Florida, which was first to
receive a letter containing a powdered form of anthrax,
remains sealed and abandoned to this day. When con-
sidering how to address decontamination and cleanup
in the public sector it is important to recognize that an
effective response must be not only agent specific but
site specific as well. The Safe Buildings Program is
primarily aimed at indoor facilities such as an office
building or hotel, where decontamination of ventila-
tion systems is imperative, and public perception issues
are extremely important. It also includes a semi-
enclosed setting, such as a subway or transportation
node. EPA has identified a list of high priority threat
agents and the committee has considered those in its
assessment below.
In general, the committee feels that the Safe Build-
ings Program is on target with respect to ongoing and
proposed decontamination efforts. It is recognized that
a great deal of effort went into making sure that the
program was coordinated and not duplicative with
ongoing efforts of other agencies and the Department
of Energy national laboratories. It is also recognized
that this is not an easy task and that some agencies
continue to be less than forthcoming with regard to the
sharing of information. In the limited time available
the Safe Buildings Program has identified some key
areas that are not currently being pursued by other
agencies but fall in the EPA's jurisdiction and exper-
tise. EPA has focused its efforts on four areas, and the
committee provides more specific comments for each
area below. These efforts should be coordinated with
the disposal task to ensure that the resulting waste and
by-products are optimized for disposal. Additionally,
the committee suggests that more effort and resources
be expended on developing an extramural research pro-
gram that goes beyond current contractors. Academic
REVIEW OF EPA HOMELAND SECURITY EFFORTS
laboratories must be encouraged to participate in
longer-term research.
Development of Standardized Test Protocols for
Decontamination Technology Performance
The development of standardized test protocols for
decontamination technology performance is an impor-
tant area for EPA to pursue. In the United States new
formulations sold as a biocide must meet EPA approval
under the Federal Insecticide, Fungicide, and Rodenti-
cide Act (FIFRA). The committee agrees that current
testing requirements need to be changed because they
are obstacles to the commercialization of new bio-
decontamination formulations, many of which are
based on oxidizer systems for which the tests were not
designed. EPA is aware of this and has formed an inter-
agency committee to design more rapid and accurate
testing protocols. This activity needs to be accelerated
and needs to investigate all types of potential biocides,
whether they exist as solutions, foams, gels, gases, or
aerosols.
One major additional need that should be addressed
is the sampling and analysis protocols to be used for
cleanup of facilities following a CW or BW incident.
Issues involving spore recovery from porous surfaces
have not been adequately addressed and could have a
major impact on the interpretation of results. Quench-
ing should be better explored and standardized since
the use of surfactants in a formulation can also impact
the consistency of biocide results. EPA has procedures
for CW and TIC that are adequate but should be further
evaluated for the threat agents that EPA has identified.
Some of the sampling and analysis procedures devel-
oped in support of the Organization for the Prohibition
of Chemical Weapons may be easily implemented for
this application.
Overall EPA focus should be to develop written
standards and protocols that distinguish clearly
between requirements for chemical and toxic industrial
chemicals and biological threats. Additional guidance
and statistical sampling protocols should be developed
similar to those developed and used by DOE and EPA
for radiological sampling (EPA et al., 1997 ).
Systematic Study and Verification of
Decontamination System Performance
The committee supports the ETV proposed in prin-
ciple and feels that this is an important focus area for
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ASSESSMENT
the EPA's Safe Buildings Program. To be effective,
EPA must build off the lessons learned from the anthrax
incidents as well as other studies that have been done at
Dugway Proving Ground (Larsen, et al., 2002) and
elsewhere (Raber and McGuire, 2002) within the last
three years. The focus for this evaluation should be on
civilian sector issues, where decontamination require-
ments are extremely demanding and different from re-
quirements for the military. Military testing protocols
are aimed at formulations that decontaminate in 30
minutes or less and have not focused on many of the
environmental issues facing public sector use. Few
controlled protocols exist for testing various building
materials, and there is a limited experience base for
testing gases, especially in ventilation system decon-
tamination. In addition, the potential for resuspension
of previously deposited particles must be better under-
stood to allow for optimizing decontamination. The
indoor air-modeling discussion in the "Containment"
section addresses this in more detail.
Key test attributes must be determined and weighted
by stakeholder group; here again they differ from typi-
cal military requirements. What is desired is a method
that is noncorrosive, nonhazardous, and degrades to
environmentally acceptable residues (i.e., passes EPA
methods 8260 and 8270 for volatiles and semivolatiles)
and one that works over relatively short decontamina-
tion times (hours). Public sector applications also
require a formulation that makes maximum contact
with surfaces by adhering to walls and ceilings but does
not form toxic products by reacting with walls and ceil-
ings; is relatively inexpensive and available; has a long
shelf life (at least a year); and is easy to deploy and
implement. In short, the public sector would be well
served with a formulation that takes two days to decon-
taminate if the material were nontoxic or degraded to
environmentally acceptable by-products. This would
not meet military needs.
The committee is concerned about the number of
products appearing on the market with decontamina-
tion claims. EPA is in a good position to evaluate these
claims through an effectively structured ETV program.
The committee feels that this is an important national
role for EPA. Additionally, EPA needs to continue its
collaborative working relationship with the Department
of Homeland Security with regard to ongoing and
planned demonstration programs for decontamination
and restoration.
13
Evaluation of the Toxicology of Decontaminating
Agents
EPA has correctly concluded that there is a need
for information on the fate and safe exposure levels of
the decontaminating agents themselves, since residues
may linger after the building has been decontaminated,
and it is important to determine whether it is safe to
enter the building and occupy it. More information is
needed about the rationale for the choice of compound
being studied and for the experimental protocol; based
on the available information, the proposed study
appears unlikely to meet its desired objectives.
Of the possible gas-phase decontaminating agents
(e.g., chlorine dioxide, vapor-phase hydrogen peroxide,
pare-formaldehyde, and ethylene oxide), EPA has
chosen to conduct additional studies only on chlorine
dioxide. No rationale for this choice was expressed in
the RIP, but it appears to be because chlorine dioxide
was used at the Hart Senate Office Building and
because it is one of the agents of choice for anthrax. If
chlorine dioxide is indeed the agent of choice for
anthrax, and if anthrax contamination is among the
most likely of the threat scenarios, then additional
research on chlorine dioxide is reasonable. On the
other hand, if there are other decontaminating agents
with similar or higher efficacy than chlorine dioxide, it
may be preferable to conduct additional research on
these agents (see below).
It is not clear which data gaps the proposed studies
will consider or how the data would be used in the
development of building re-entry guidelines. Before
addressing the available data on chlorine dioxide, the
relevant exposure standard for re-entry should be con-
sidered. The investigators cite the existing NIOSH/
OSHA recommended exposure limit. This is useful as
an initial comparison, since the exposure of interest
occurs in the workplace, and OSHA is the regulatory
agency for workplace exposure. However, the expo-
sure of interest would most likely occur primarily
among office workers returning to the building.
Although this is not a well-defined area of occupational
risk analysis, office workers tend to have a lower
acceptance of risk than workers in factories that are
exposed to industrial chemicals. Office workers are
likely to resemble the general population more than
factory workers; the lower level of physical activity
and the absence of selection for healthy people may
remove much of the "healthy worker" effect. Although
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14
EPA does not have jurisdiction over the office environ-
ment, evaluation of the risk of long-term exposure for
office workers should take into account health stan-
dards developed for the general public (e.g., the
reference concentration PRfC]~. The RfC is defined as
"an estimate (with uncertainty spanning perhaps an
order of magnitude) of a continuous inhalation expo-
sure to the human population (including sensitive sub-
groups) that is likely to be without an appreciable risk
of deleterious effects during a lifetime" (EPA, 2000~.
A second exposure of interest is workers re-
entering a building to complete cleanup and replace
furnishings. In this case, exposure would be for a lim-
ited duration, and short-term guidance values (e.g., for
an eight-hour or one-week exposure) would be appro-
priate. If there are data gaps in this area, the proposed
studies may help in evaluating the toxicity of chlorine
dioxide. However, because the proposed high concen-
tration of 0.1 ppm is near the "no observed adverse
effect" level (NOAEL) for sub-chronic exposure, it is
not clear whether the proposed exposure concentrations
would provide the necessary information. Higher
exposure levels may be needed to identify a NOAEL
and a "lowest observed adverse effect" level (LOAEL)
for acute exposures. EPA assessed the inhalation toxic-
ity of chlorine dioxide in 2000, and has derived an RfC
for this chemical (EPA, 2000~. While the RfC is sig-
nificantly lower than the REL, due to differences in the
methods used, the documentation for the RfC identi-
fies key data gaps and uncertainties that should be con-
sidered in conducting further testing. In particular,
there is uncertainty regarding the NOAEL in the sub-
chronic study used as the basis for the RfC. Additional
short-term mechanistic studies will not resolve that
issue. Another key data gap is the absence of studies of
reproductive toxicity through the inhalation route.
While gene expression studies are useful for hypothesis
generation, they will not provide definitive answers
regarding the carcinogenic potential of chlorine dioxide,
particularly in the absence of a chronic cancer bioassay.
Based on these considerations, the proposed stud-
ies may provide useful general information in chlorine
dioxide toxicity, but they are unlikely to provide infor-
mation within the time frame of interest that is useful
to evaluating the health risks of chlorine dioxide
following re-entry. More relevant information would
be obtained by targeting the testing conditions to deter-
mine the NOAEL and LOAEL for the exposure dura-
tion of interest (acute or sub-chronic). These standard
toxicity studies could be supplemented by mechanistic
REVIEW OF EPA HOMELAND SECURITY EFFORTS
studies, such as studies designed to improve dosimetry
or to establish the mode of action. However, the
mechanistic studies should not be the focus of the test-
ing, in light of the objectives of the overall Safe Build-
ings Program.
In summary, the committee recommends that the
EPA Safe Buildings Program concentrate on the
potential for generation of toxic residues from the
interactions of decontamination agents with building
materials, furniture, carpets, and other furnishings and
cover more than just chlorine dioxide. Understanding
the fate of the decontaminants with regard to specific
building materials may be useful, but more important
is the actual resulting residues and whether they repre-
sent a significant health risk.
Engineering and Scientific Support and Analysis
EPA has identified an initial set of projects to go
forward with in this area. The key issue for the EPA
Safe Buildings Program will be to come up with the
necessary information and supporting processes to be
able to make risk-informed decisions when mounting a
response. Any kind of decontamination in the public
sector requires an understanding of the type of emer-
gency restoration needed, including characterization
and performance of site-specific risk assessments for
potential impact on human and animal health and the
environment. These considerations then determine the
decontamination or remediation treatment to be imple-
mented (Raber et al, 2001).
The committee supports the current efforts of EPA
to learn from ongoing anthrax fumigations and recom-
mends that efforts should include a thorough case study
of the Hart Senate Office Building and Brentwood Post
Office experiences, focusing on decontamination and
disposal. Understanding the real-world conditions and
results should provide a baseline for engineering and
economic analysis of building decontamination alter-
natives. Some of the more recent reports from EPA
(2002) and the GAO (2003a,b) also provide a useful
perspective and should be incorporated into this effort.
"How clean is clean enough?" or put another way,
"How clean is safe?" The challenge is to establish target
levels of cleanup for the various biological and chemi-
cal agents that will meet both regulatory and stake-
holder needs and address site-specific parameters as
well.
The committee feels that two concepts are essen-
tial to any discussion of cleanup levels. First, public
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ASSESSMENT
perceptions and stakeholder issues will drive cleanup
requirements. Second, economic drivers and inconve-
nience influence stakeholders to accept higher risks.
Input from public and regulatory stakeholder bodies is
essential when cleanup goals relating to health and risks
are set, and when cleanup and decontamination deci-
sions are made. The committee believes that successful
cleanup requires that risk information be communi-
cated to the public throughout the entire process. More-
over, the decontamination method that is selected needs
to consider the costs of cleanup versus the goal of meet-
ing cleanup criteria.
Following the anthrax letter incidents in the United
States, the importance of economic drivers became
clear when cleanup efforts commenced. Although regu-
latory guidelines and recommendations for specific air-
borne and soil cleanup levels for the G agents (tabun,
soman, satin, and cyclohexyl methylphosphonofluridate)
and VX exist (U.S. Army, 1999; NRC, l999b, EPA
2000), cleanup levels for biological agents remain
problematic (Raber et al, 2001~. To address standards
and policies for decontaminating public facilities
affected by exposure to harmful biological agents, in
particular, anthrax and smallpox, the Department of
Homeland Security has commissioned a new study by
the National Research Council. The EPA's Safe Build-
ings Program is providing useful direction regarding
the scope and direction of that study. The NRC com-
mittee encourages EPA to continue to work on this as
an important interagency effort.
The committee also recommends that the EPA Safe
Buildings Program consider adding the scope sug-
gested below to its proposed research and implementa-
tion program.
High on the list of important issues is the need for
methods to rapidly determine agent-specific viability
for effective biological agent decontamination. Current
methods, such as PCR technology, tell us what an agent
is but not whether it is alive or dead. Current sampling
and culturing methods take from one to three days,
depending on the agent. Rapid determination of spe-
cific agents is the key to restoring critical infrastructure.
Some initial research is underway at DOE laboratories,
primarily funded by the Defense Advanced Research
Projects Agency, to explore the technology gaps related
to viability determinations, but this area is not likely to
meet all of EPA's needs. The critical advantage of such
a method needs to be integrated into EPA's current
approach for biological decontamination.
It is important to understand the potential for natural
15
attenuation for both chemical and biological warfare
agents. It is well known that such factors as ultraviolet
light from the sun can kill vegetative cells and certain
other biologicals. Some literature is available for spore
and cell survival in outdoor environments, but infor-
mation is limited for indoor environments, and con-
trolled environmental studies are lacking (Setlow,
2000~. Research on Bacillus anthracis shows that the
spores suffer heavy mortality over time up to 90 per-
cent per year but remaining spores can germinate and
grow. Nonsporulating vegetative cells that require high
water activity survive longer in a dormant state. Thus,
it becomes important to study the conditions required
for germination, growth, and sporulation in enclosed
and semi-enclosed environments, especially as a func-
tionoftemperature,humidity,andtime. Again, under-
standing the limits of natural degradation potential can
aid in determining effective decontamination strategies.
With regard to CW agents, early work done by
Lawrence Livermore National Laboratory researchers
in cooperation with British scientists at Porton Down,
U.K., studied natural degradation of the G agents and
VX at a concentration of 5 g/m2. Tests were conducted
in sandy soil, silty soil, and on silicon rubber gasket
material. Within three days in a humid environment the
chemical agents degraded to nondetectable levels,
except for the tests on rubber gasket material (Raber et
al., 2001~. Thus, the expectation is that outdoors and at
least in soil, natural degradation of chemical warfare
agents can be effective. Understanding this for semi-
enclosed environments may also aid in determining
effective decontamination strategies.
Long-Term Research Needs and EPA's Role
The EPA Safe Buildings Program needs to help set
the stage for a longer-term research agenda for de-
contamination and restoration. EPA has identified
three areas that are required for longer-term success.
These are (1) development and optimization of novel
(and improved) decontamination methods; (2) addi-
tional evaluations of existing decontamination meth-
ods and systems; and (3) development of methods for
high-value materials (e.g., museum holdings, national
treasures).
The committee agrees with EPA's longer-term
recommendations. The committee evaluated current
technologies to identify significant decontamination
technology gaps for applications in the public sector.
The committee recommends that a longer-term decon-
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16
lamination and restoration research program, coordi-
nated with other agencies, include the following:
1. Technologies, systems, and studies to better char-
acterize the extent of chemical and biological con-
tamination resulting from a terrorist attack using
CBW agents or TICs.
· Standards Development studies to deter-
mine standards for cleanup levels for CBW and
TIC materials for various types of contami-
. ~ ·. - · . . . -
.
.
nated tacllltles and demographic groups.
Sampling Methodology Development tech-
nologies to increase sampling efficiency for
CBW agents in facilities and surrounding
areas.
Agent and Decontaminate Studies studies
to develop a better understanding of transport,
robustness, and viability of CBW agents and
the potential for toxic residues resulting from
the decontamination process.
2. Development of methods for better, cheaper,
safer, and faster decontamination of facilities and
other contaminated areas.
· Decontamination of Sensitive Equipment
and Other Items technologies and methods
to decontaminate other sensitive equipment
and sensitive items (e.g., computing equlp-
.
.
meet, paintings).
Decontamination of Hard-to-Reach Places-
technologies and methods to decontaminate
hard-to-reach places such as the interior of
ductwork and the area above ceiling tiles.
These technologies should include less toxic
vapor and gas decontaminants and methods
that can be employed and utilized with less
infrastructure requirements than chlorine
dioxide.
Decontamination of Exposed Surfaces and
Wide Areas technologies and methods to
effectively decontaminate exposed surfaces in
facilities and surrounding areas (i.e., special-
ized reactive and sealant materials in paints or
coatings that could adhere to high places and
require no cleanup and methods to decontami-
nate; foam, gels and liquids that adhere to ver-
tical surfaces and ceilings.
· Biological Mechanistic Decontamination
Studies studies to determine mechanisms of
spore kill and other related effects.
REVIEW OF EPA HOMELAND SECURITY EFFORTS
3. Restoration Systems Development and Evalua-
tion the study and development of systems and
tools to better understand, to plan, and to imple-
ment the restoration process (e.g., identification
of preventative measures for sealing and cover-
ing porous surfaces with materials, such as epoxy
paint or stainless steel sheeting, to create smooth
surfaces that are easier to decontaminate). This
includes the verification of decontamination prod-
ucts and the optimization of the process to be used.
It is clear from the efforts under way to use chlo-
rine dioxide and vaporous hydrogen peroxide that there
is much scientific data lacking (e.g., effectiveness as a
function of temperature, humidity, time, materials) that
is vital to an efficient and effective decontamination.
Currently, huge infrastructure needs (e.g., source gen-
eration, air-tight tenting of building, negative pressure
apparatus, circulation pumps, scrubbers, detection
apparatus) are required and this causes a significant
delay in the restoration of contaminated facilities. A
proper metric for this program would be to decontami-
nate and restore a building similar to the Hart Senate
Office Building in less than one month and preferably
two weeks.
DISPOSAL
The proposed strategy and research projects reflect
EPA's expertise in handling hazardous materials dis-
posal issues, its experience in responding to the recent
anthrax decontamination effort, and its overall experi-
ence in hazardous waste cleanup through implementa-
tion of Superfund cleanup and removal actions.
Specific research and implementation projects
focus on disposal options that include thermal or
incineration and landfill. The grass-roots approach
EPA is taking to involve impacted regulatory agencies,
manufacturers, emergency responders, and facility
operators is a sound approach. Both thermal treatment
and incineration have the advantage of addressing both
hazard and waste reduction issues. The need to under-
stand the matrix effects of incinerating bulk items to
destroy CBW agents is a necessary step toward using
this technology. Developing methods to test incinera-
tor emissions for the agents being treated is essential
for effectively using thermal treatments for CBW
agents and meeting public perception issues and stake-
holder demands. Looking at the viability and surviv-
ability of organisms of concern in landfills is also
OCR for page 17
ASSESSMENT
necessary to allow for disposal of BW materials directly
into landfills. Research focused on the longevity of
Bacillus anthracis spores shows that 90 percent of
spores in soil die within 50 years (Sneath, 1962~. How-
ever, surviving spores can remain viable for 300 years.
Understanding this issue and the associated impact is
key to an effective disposal strategy.
This committee supports EPA's approach to the
proposed projects on disposal. However, it also rec-
ommends that EPA consider the following in its CBW
disposal options:
1. Thermal treatment and incineration may not be
viable approaches in many states where air qual-
ity issues are a concern. For example, California
does not have a permitted hazardous or medical
waste incinerator and only has three municipal
facilities that use incineration as a permitted waste
transformation process.
There are only a handful of operating incinera-
tors around the country. Investigations as to
whether these few incinerators can handle the
bulky items identified in the project proposals
need to be included in EPA's consideration.
The project proposals also include streamlining
the permitting process for thermal treatments.
However, they do not include issues related to
whether there are technologies that can economi-
cally meet air quality standards and whether pub-
lic perception will allow such facilities to be sited
even if the permitting process were streamlined.
Thermal treatment temperatures that effec-
tively kill any remaining anthrax spores are typi-
cally higher than those for standard medical waste
incineration.7 To render biological warfare
agents completely harmless, dry heat requires two
hours of treatment at 160 degrees C. If steam is
used at 121°C and 1 atm of overpressure (15 psi),
the time may be reduced to 20 minutes, depend-
ing on volume (Office of the Surgeon General,
1997~. Therefore, these incineration and thermal
treatment proposals should include a focus on the
7Title 17, California Code of Regulations, Division 1, Air Re-
sources Board, Chapter 1 Air Resources Board, Subchapter 7.5.
Airborne Toxic Control Measures, Section 93 104, Dioxins Air-
borne Toxic Control Measure Medical Waste Incinerators
17
efficiency of different temperature treatments for
the specific CBW agents.
2. A criterion needs to be developed for disposing
of decontaminated materials in municipal land-
fills, which would allow more options with
respect to facilities able to take decontaminated
CBW waste. For example, in California, if crite-
ria were available to determine that wastes are no
different than any other municipal waste, includ-
ing waste contaminated with sewage, CBW
wastes could be disposed in an appropriate Class
III landfill.8 9 The key technical question for EPA
to answer is whether the decontaminated material
meets the criteria of any other municipal wastes.
Answering this question positively could set
baseline criteria for a decontamination standard
and should be a key factor in setting goals and
objectives for EPA's decontamination research
program discussed in EPA' s Research Implemen-
tation Plan.
3. EPA also identifies thermal treatments as a dis-
posal option; however thermal treatments are also
decontamination methods. In fact, the projects
seem to be proposing thermal treatment as a way
of treating residual contamination before dispos-
ing the waste products to air and landfill. The de-
contamination and disposal strategies and
proposals should be better coordinated. If the
material is to be decontaminated, then decontami-
nation methods that will meet municipal landfill
criteria as discussed above should be identified.
4. The committee recommends that EPA have a
strategy related to methods development for sta-
bilizing remaining hazardous waste materials so
that the materials may be sent to a landfill rather
than impose an incineration or thermal treatment
approach. Such items as air handling filters and
other more porous materials may be more difficult
to decontaminate. It will be important to evaluate
Title 27, California Code of Regulations, Environmental Pro-
tection Division 2, Solid Waste
9Title 14, California Code of Regulations, Natural Resources
Division 7, California Integrated Waste Management Board per-
taining to nonhazardous waste in management in California.
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18
REVIEW OF EPA HOMELAND SECURITY EFFORTS
some of the more recently developed resin stabili-
zation methods for nuclear-contaminated material
in the context of the Safe Buildings Program.
Some such methods may stabilize remaining
spores and be applicable to treatment for toxic
industrial chemicals, including CW materials.
The committee encourages EPA to discuss some
of the approaches used by the DOE national labo-
ratories where they have been successful in stabi-
lizing difficult wastes to meet land disposal
restrictions and dispose of the wastes directly in a
landfill (Tyson and Schwendiman, 1995; Bowers
et al., 1995; Gates-Andersen et al., 2003~.
5. The EPA's proposals discuss liquid wastes gen-
erated as part of decontamination efforts, but they
do not include research regarding disposal of this
waste or whether there is a need to address liquid
waste disposal options. For example, can these
types of waste be discharged to a publicly owned
treatment works (POTW) without interrupting
treatment processes or causing exposures to
workers at the POTW. In some cases the decon-
taminated wastewater might be characterized as
hazardous for toxicity. It is important to deter-
mine whether the current hazardous waste dis-
posal methods are indeed adequate for handling the
liquid waste stream created by decontaminating
CBW-contaminated materials. Approaches
should be evaluated for stabilizing any remaining
hazardous liquid wastes that are generated so that
they can meet landfill toxicity characteristic
leaching procedure (TCLP) disposal criteria.
Such approaches should be incorporated into
EPA's overall strategy.
In summary, EPA should develop guidance docu-
ments and matrixes for emergency managers on what
the best disposal options would be as a function of
potential impacts on environmental media (e.g., air,
water, land) receiving the different types of waste
material. EPA also needs to include an analysis of com-
peting and overlapping federal, state, and local regula-
tions and ordinances that might prevent the application
of certain disposal technologies. This would be the key
to streamlining disposal procedures.
Representative terms from entire chapter:
buildings program
