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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities IMPACT OF REVISED AIRBORNE EXPOSURE LIMITS ON NON-STOCKPILE CHEMICAL MATERIEL PROGRAM ACTIVITIES Committee on Review and Assessment of the Army Non-Stockpile Chemical Materiel Demilitarization Program: Workplace Monitoring Board on Army Science and Technology Division on Engineering and Physical Sciences NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES THE NATIONAL ACADEMIES PRESS Washington, D.C. www.nap.edu
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities THE NATIONAL ACADEMIES PRESS 500 FIFTH STREET, N.W. Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This study was supported by Contract/Grant No. W911NF-04-C-0045, between the National Academy of Sciences and the Department of the Army. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the views of the organizations that provided support for the project. International Standard Book Number 0-309-09545-X Additional copies of this report are available from the National Academies Press, 500 Fifth Street, N.W., Lockbox 285, Washington, DC 20055; (800) 624-6242 or (202) 334-3313 (in the Washington metropolitan area); Internet, http://www.nap.edu. Copyright 2005 by the National Academy of Sciences. All rights reserved. Printed in the United States of America
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce M. Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm. A. Wulf is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce M. Alberts and Dr. Wm. A. Wulf are chair and vice chair, respectively, of the National Research Council. www.national-academies.org
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities COMMITTEE ON REVIEW AND ASSESSMENT OF THE ARMY NON-STOCKPILE CHEMICAL MATERIEL DEMILITARIZATION PROGRAM: WORKPLACE MONITORING RICHARD J. AYEN, Chair, Waste Management, Inc. (retired), Jamestown, Rhode Island MARTIN GOLLIN, St. Davids, Pennsylvania GARY S. GROENEWOLD, Idaho National Engineering and Environmental Laboratory, Idaho Falls FREDERICK T. HARPER, Sandia National Laboratories, Albuquerque, New Mexico PAUL F. KAVANAUGH, BG, U.S. Army (retired), Fairfax, Virginia TODD A. KIMMELL, Argonne National Laboratory, Washington, D.C. LOREN D. KOLLER, Oregon State University (retired), Corvallis BRIAN LAMB, Washington State University, Pullman BENJAMIN Y.H. LIU, University of Minnesota (retired), Shoreview DOUGLAS M. MEDVILLE, MITRE Corporation (retired), Reston, Virginia BARBARA PALDUS, Picarro, Inc., Sunnyvale, California GEORGE W. PARSHALL, DuPont Company (retired), Wilmington, Delaware JAMES P. PASTORICK, Geophex UXO, Ltd., Alexandria, Virginia CHARLES F. REINHARDT, DuPont Company (retired), Wilmington, Delaware GARY D. SIDES, Gas Technology Institute, Birmingham, Alabama LEONARD M. SIEGEL, Center for Public Environmental Oversight, Mountain View, California ROBERT SNYDER, Rutgers, the State University of New Jersey, Piscataway BILLY R. THOMAS, Integrated Environmental Management, Inc., Findlay, Ohio WILLIAM J. WALSH, Pepper Hamilton LLP, Washington, D.C. Liaison Board on Army Science and Technology HENRY J. HATCH, Army Chief of Engineers (retired), Oakton, Virginia Staff BRUCE A. BRAUN, Director, Board on Army Science and Technology NANCY T. SCHULTE, Study Director HARRISON PANNELLA, Program Officer JAMES MYSKA, Research Associate TOMEKA N. GILBERT, Senior Program Assistant
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities BOARD ON ARMY SCIENCE AND TECHNOLOGY JOHN E. MILLER, Chair, Oracle Corporation, Reston, Virginia GEORGE T. SINGLEY III, Vice Chair, Science Applications International Corporation, McLean, Virginia SETH BONDER, The Bonder Group, Ann Arbor, Michigan DAWN A. BONNELL, University of Pennsylvania, Philadelphia NORVAL L. BROOME, MITRE Corporation (retired), Suffolk, Virginia ROBERT L. CATTOI, Rockwell International (retired), Dallas, Texas DARRELL W. COLLIER, U.S. Army Space and Missile Defense Command (retired), Leander, Texas ALAN H. EPSTEIN, Massachusetts Institute of Technology, Cambridge ROBERT R. EVERETT, MITRE Corporation (retired), New Seabury, Massachusetts PATRICK F. FLYNN, Cummins Engine Company, Inc. (retired), Columbus, Indiana WILLIAM R. GRAHAM, National Security Research, Inc., Arlington, Virginia HENRY J. HATCH, U.S. Army Corps of Engineers (retired), Oakton, Virginia EDWARD J. HAUG, University of Iowa, Iowa City MIRIAM E. JOHN, Sandia National Laboratories, Livermore, California DONALD R. KEITH,* Cypress International (retired), Alexandria, Virginia CLARENCE W. KITCHENS, Science Applications International Corporation, Vienna, Virginia ROGER A. KRONE, Boeing Integrated Defense Systems, Philadelphia, Pennsylvania JOHN W. LYONS, U.S. Army Research Laboratory (retired), Ellicott City, Maryland JOHN H. MOXLEY, Korn/Ferry International, Los Angeles, California MALCOLM R. O’NEILL, Lockheed Martin Corporation, Bethesda, Maryland EDWARD K. REEDY, Georgia Tech Research Institute (retired), Atlanta, Georgia DENNIS J. REIMER, National Memorial Institute for the Prevention of Terrorism, Oklahoma City WALTER D. SINCOSKIE, Telcordia Technologies, Inc., Morristown, New Jersey WILLIAM R. SWARTOUT, Institute for Creative Technologies, Marina del Rey, California EDWIN L. THOMAS, Massachusetts Institute of Technology, Cambridge BARRY M. TROST, Stanford University, Stanford, California JOSEPH J. VERVIER, ENSCO, Inc., Melbourne, Florida Staff BRUCE A. BRAUN, Director WILLIAM E. CAMPBELL, Manager, Program Operations CHRIS JONES, Financial Associate DEANNA P. SPARGER, Administrative Coordinator * GEN Keith died on September 9, 2004.
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities Preface The Committee on Review and Assessment of the Army Non-Stockpile Chemical Materiel Demilitarization Program: Workplace Monitoring (see Appendix A for committee members’ biographies) was appointed by the National Research Council (NRC) to evaluate the impact of then newly promulgated or proposed airborne exposure limits (AELs) for nerve agents and mustard on the program of the U.S. Army Non-Stockpile Chemical Materiel Product (NSCMP). The chemical demilitarization workforce and neighboring populations must be protected from the risk of exposure to hazardous materials during munition disposal operations and during facility closure. To accomplish this, a program must be in place to monitor hazardous materials in and near the workplace and to monitor workers’ activities and health. A previous NRC report examined the programs in place at two stockpile facilities, the Johnston Atoll Chemical Agent Disposal System and the Tooele Chemical Agent Disposal Facility, to monitor concentrations of airborne and condensed-phase chemical agents, agent breakdown products, and other substances of concern. The report concluded that the programs then in place were adequate and recommended the pursuit of improvements in agent monitoring technologies (NRC, 2001c). Public Law 91-121 and Public Law 91-441 require the Department of Health and Human Services to review Department of Defense plans for disposing of lethal chemical munitions and to make recommendations to protect public health. In the process of meeting these requirements, the Centers for Disease Control and Prevention (CDC) recommended new AELs for nerve agents and published these recommendations in the Federal Register in October 2003 (Federal Register, 2003a). The AELs of the nerve agents were to be monitored starting January 1, 2005. New AELs for mustard were recommended and published in the Federal Register in May 2004 (Federal Register, 2004). Monitoring of mustard will start on July 1, 2005. The statement of task for the committee was, on its face, limited: The NRC will establish an ad hoc committee on workplace monitoring at non-stockpile chemical materiel disposal sites and former production facilities. The committee will: Review and understand the basis for the Centers for Disease Control and Prevention’s (CDC’s) newly promulgated airborne exposure limits (AELs) for GA (tabun), GB (sarin), and VX and proposed CDC AELs for mustard agent and assess the safety and process implications of these standards. Review and become familiar with facility designs and operational procedures: For destruction of the former production facility at Newport, Indiana, and For the use of the mobile explosive destruction system and the rapid response system. Assess monitoring technologies in use at the existing non-stockpile sites to determine if they are capable of measuring compliance with short- and long-term AELs and determine the degree to which these technologies can be incorporated into overall program monitoring strategies, particularly for the purposes of process verification and environmental permit compliance. If existing monitoring methods are not capable of determining compliance with short- and long-term AELs, evaluate the capability of other monitoring that may achieve the same goal. Make recommendations on Application of currently used monitoring methodologies to facilitate non-stockpile activities, Capability of currently used measurement technologies to meet future monitoring requirements, Assessing impacts of newly promulgated AELs on worker and public safety aspects, Alternative measures (e.g., increased personal protective equipment and worker safety training
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities requirements) that may be required to compensate for inabilities to meet standards with existing equipment, Impact of relevant monitoring technologies (for new AELs) and effect on ability to implement in time to meet the CWC treaty deadline, and The critical path regulatory approval and public involvement issues that may arise in developing such a monitoring program. In light of this specific charge, the committee accepted the new AELs from the CDC as a starting point for its review of the monitoring program. That is, the committee did not evaluate the process used or the end points selected by the CDC in revising the 1988 limits, nor did it take a position on the appropriateness of the 2003/2004 CDC-recommended AELs. Nevertheless, the committee expresses in Chapter 3 its belief that the new AELs will not achieve any risk benefit. This report contains a significant discussion of the 2003/2004 AELs and the differences between them and the 1988 limits, because understanding the degree of uncertainty in the new AELs was necessary to understand the role of monitoring in implementing them. This study was conducted under the auspices of the NRC’s Board on Army Science and Technology (BAST). The chair acknowledges the continued superb support of the BAST director, Bruce A. Braun, and the study director, Nancy T. Schulte. Valuable assistance was provided by Harrison Pannella, Tomeka Gilbert, and James Myska of the NRC staff and by the committee members, who all worked diligently on a demanding schedule to produce this report. Richard J. Ayen, Chair Committee on Review and Assessment of the Army Non-Stockpile Chemical Materiel Demilitarization Program: Workplace Monitoring
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities Acknowledgment of Reviewers This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Barbara Callahan, University Research Engineers and Associates, Richard A. Conway, Union Carbide Corporation (retired), Gene Dyer, Bechtel Corporation (retired), Eugene Kennedy, National Institute for Occupational Safety and Health, David Mummert, Shaw Environmental, Inc., Hyla Napadensky, Napadensky Energetics, Inc. (retired), Kenneth Shuster, U.S. Environmental Protection Agency, William Tumas, Los Alamos National Laboratory, and Calvin Willhite, State of California Department of Toxic Substances Control. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by Stephen Berry, University of Chicago. Appointed by the NRC, he was responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities Contents EXECUTIVE SUMMARY 1 1 INTRODUCTION 9 Announcement of New Airborne Exposure Limits, 9 The Chemical Weapons Convention, 10 The Non-Stockpile Chemical Materiel Disposal Program, 11 Nature and Extent of Sites for Non-Stockpile Items, 11 Former CWM Production Facilities, 11 Mobile Treatment Systems, 11 Mobile Systems Use and Monitoring Requirements, 12 Background, 13 Overview of New Airborne Exposure Limits, 13 Units for Airborne Concentration Levels, 14 Applicability to Non-Stockpile Monitoring Environments, 14 Non-Stockpile Sites Addressed, 14 Statement of Task, 14 Sources of Information, 15 Structure of This Report, 15 2 A NON-STOCKPILE FACILITY AND TWO MOBILE TREATMENT SYSTEMS 16 Former Production Facility at Newport, Indiana, 16 Condition of the NECD Facility Buildings, 16 VX Exposure Issues, 16 Personal Protective Equipment and Worker Operations, 18 Issues Surrounding Pipe Removal, 18 Initial Piping and Equipment Demolition Procedures, 22 Modifications to Demolition Procedures, 23 Air Monitoring and Personal Protective Equipment, 24 Explosive Destruction Systems, 26 General, 26 EDS Workforce Tasks and Workforce Protection, 27 Secondary Containment, 27 Monitoring for Protection of the EDS Workforce, 29 Monitoring for Protection of the General Population, 31 Rapid Response System, 32 General, 32 Equipment and Operations, 32 RRS Workforce Tasks and Workforce Protection, 33 Current RRS Monitoring Procedures and Experience, 33
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities 3 OLD AND NEW AIRBORNE EXPOSURE LIMITS 37 Basis for Establishment of Airborne Exposure Limits for Nerve Agents GA, GB, and VX, 37 Basis for Establishment of Airborne Exposure Limits for Mustard Agent, 40 Impact of the Revised AELs on Worker and Public Safety, 42 4 AIR MONITORING SYSTEMS 43 Systems Used to Monitor at the 1988/1997 AELs, 43 MINICAMS, 44 DAAMS, 48 Other Monitoring Systems (A/DAM), 50 Ability of Systems Used for Monitoring at the 1988/1997 AELs to Monitor at the 2003/2004 AELs, 51 MINICAMS, 51 DAAMS, 52 A/DAM, 54 Alternative Technologies for Monitoring at the 2003/2004 AELs, 54 Alarm Levels for Near-Real-Time Monitors, 56 5 PROCESS IMPLICATIONS OF THE NEW AELS 62 Newport Chemical Depot, 62 Impact on the Operations of Mobile Treatment Systems, 62 EDS Operations, 62 RRS Operations, 64 Decontamination of Agent-Contaminated Materials: The X Requirement, 64 6 REGULATORY APPROVAL AND PERMITTING, AND PUBLIC INVOLVEMENT 66 Introduction, 66 Regulatory Programs, 66 Worker Protection, 66 Protection of Human Health and the Environment, 67 Worker Protection Standards and RCRA Integration Issues, 67 Using Lower Alarm Levels and Reportable Limits, 68 Relationship of AELs to the RCRA Contingency Plan, 68 Public Involvement, 69 REFERENCES 71 APPENDIXES A Biographical Sketches of Committee Members 75 B Non-Stockpile Inventories 79 C Committee Meetings and Other Activities 82 D Approved Personal Protective Equipment 84
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities Figures, Tables, and Box FIGURES 2-1 Former VX production facility at NECD, 17 2-2 Level B PPE, 18 2-3 Level C PPE, 19 2-4 Level D PPE, 19 2-5 Structure of VX and EA-2192, 20 2-6 Diagram of the EDS-1 vessel on its trailer, 26 2-7 Typical EDS deployment layout, 29 2-8 Side view of RRS operations trailer, 32 2-9 RRS exhaust air filtration system, 34 4-1 MINICAMS and DAAMS operating ranges for the 1988/1997 GB AELs and required ranges for the CDC’s 2003 GB AELs, 47 4-2 MINICAMS and DAAMS operating ranges for the 1988/1997 VX AELs and required ranges for the CDC’s 2003 VX AELs, 48 4-3 MINICAMS and DAAMS operating ranges for the 1988 HD AELs and required ranges for the CDC’s 2004 HD AELs, 49 TABLES ES-1 Types of Airborne Exposure Limits, 2 ES-2 1988 and 2003/2004 CDC-Recommended Airborne Exposure Limits for the Nerve Agents GA, GB, and VX (2003) and Sulfur Mustard (HD) (2004), 3 1-1 Types of Airborne Exposure Limits, 10 1-2 1988 and 2003/2004 CDC-Recommended Airborne Exposure Limits for the Nerve Agents GA, GB, and VX (2003) and Sulfur Mustard (HD) (2004), 13 1-3 Equivalent Unit Nomenclatures for AEL Concentrations, 14 2-1 Types of PPE Currently Employed at the NECD Former VX Production Facility, 18 2-2 VX Airborne Exposure Limits (Effective January 1, 2005), 24 2-3 Available PPE Approved for Use at the NECD Former Production Facility, 25 2-4 General EDS Explosive Containment Vessel Specifications, 27 2-5 Usage Data for the EDS, 28 2-6 Personal Protective Equipment Levels, 29
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities 3-1 1988 and 2003 CDC-Recommended AELs and 2003 Acute Exposure Guidelines (AEGLs) for GA, GB, and VX, 37 3-2 1988 and 2004 CDC-Recommended AELs and 2003 AEGLs for Sulfur Mustard (HD), 40 4-1 TWA Concentrations Reported by Two Different MINICAMS for 1.00-TWA Challenges Made During 4 Weeks of Operation (August 2004), 58 5-1 EDS and RRS Containment Features, 63 B-1 Inventory of Non-Stockpile Items at the Pine Bluff Arsenal, 80 B-2 Inventory of Non-Stockpile Items at Dugway Proving Ground (DPG) and Deseret Chemical Depot (DCD), Utah, 81 B-3 Inventory of Non-Stockpile Items at Aberdeen Proving Ground, Maryland, 81 B-4 Inventory of Non-Stockpile Items at Anniston Chemical Activity, Alabama, 81 BOX 2-1 Formation of the G-Analog, 21
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities Abbreviations ACAMS automatic continuous agent monitoring system(s) A/DAM Agilent/Dynatherm agent monitor AEGL acute exposure guideline AEL airborne exposure limit CAIS chemical agent identification set(s) CAS Chemical Abstract Service CDC Centers for Disease Control and Prevention CFR Code of Federal Regulations CG phosgene CHPPM (U.S. Army) Center for Health Promotion and Preventive Medicine CK cyanogen chloride CMA (U.S. Army) Chemical Materials Agency CPT chemical process trailer CWC Chemical Weapons Convention CWM chemical warfare materiel DA diphenylchloroarsine DAAMS depot area air monitoring system(s) DCD Deseret Chemical Depot (Utah) DET detonation chamber DF binary chemical agent precursor DM adamsite DPE demilitarization protective ensemble EA-2192 product of VX hydrolysis EDS explosive destruction system(s) EIS environmental impact statement FPD flame photometric detector GA tabun (a nerve agent) GB sarin (a nerve agent) GC gas chromatograph GD soman (a nerve agent) GDL gross detection level GPL general population limit GS diethyl malonate GTR German Traktor rocket H sulfur mustard HD sulfur mustard (distilled) HN nitrogen mustard HT sulfur mustard, T-mustard combination HVAC heating, ventilation, and air conditioning IDLH immediately dangerous to life and health L lewisite LAMS large area maintenance shelter LOAEL lowest observed adverse effect level MASP mobile analytical support platform MCE maximum credible event MDU metal decontamination unit(s) MEA monoethanolamine mg milligram MINICAMS low-level, near-real-time air monitor(s) mm millimeter MMD munitions management device MPL maximum permissible limit MSD mass spectrometry detector NaOH sodium hydroxide NECD Newport Chemical Depot NIOSH National Institute for Occupational Safety and Health NOAEL no observed adverse effect level NRC National Research Council NRT near real time NSCM non-stockpile chemical materiel NSCMP Non-Stockpile Chemical Materiel Product
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Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities NSCWCC Non-Stockpile Chemical Weapons Citizens’ Coalition O,S-DMP O,S-diethyl methylphosphonothiolate, a by-product in the manufacture of VX OSHA Occupational Safety and Health Administration P&A precision and accuracy PD phenyldichloroarsine PFPD pulsed flame photometric detector PIG container for shipping CAIS PINS portable isotopic neutron spectroscopy PMNSCM Product Manager for Non-Stockpile Chemical Materiel PPE personal protective equipment PS chloropicrin psig pounds per square inch gauge PWS projectile washout system QA/QC quality assurance/quality control QL binary chemical agent precursor RAP regulatory approval and permitting RCRA Resource Conservation and Recovery Act RCWM recovered chemical weapons materiel RD&D research, development, and demonstration RRS rapid response system SCANS single CAIS access and neutralization system SCBA self-contained breathing apparatus SDS spent decontamination solution STEL short-term exposure limit TAP toxicological agent protective TP triphosgene TPA triphenylarsine TRO diethyl methylphosphonate, an oxidation product of a VX precursor TSDF treatment, storage, and disposal facility TWA time-weighted average U.S.C. United States Code VCS vapor containment structure VX a nerve agent WPL worker population limit XSD halogen-selective detector 3X level of agent decontamination (suitable for transport for further processing) 5X level of agent decontamination (suitable for commercial release)