Appendix A
Reprinted 2010 Letter Report

The following report is a reprint of National Research Council, “Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report” (The National Academies Press, Washington, D.C., 2010), available online at http://www.nap.edu/catalog.php?record_id+12838.



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appendix a reprinted 2010 letter report The following report is a reprint of National Research Council, “Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report” (The National Academies Press, Washington, D.C., 2010), available online at http://www.nap.edu/catalog. php?record_id+12838. 

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 anticipated that both facilities will stay under Army control after closure as part of the Mailing Address: nearby Tooele Army Depot. Board on Army Science and Technology 500 Fifth Street, NW TOCDF is a large, active facility where disposal operations for mustard agent Washington, DC 20001 www.nationalacademies.org munitions and ton containers will continue until well into 2011. In addition to the baseline facility, a small skid-mounted liquid combustion unit, complete with a pollution January 7, 2010 abatement system, is being designed and will be constructed in the adjacent munitions storage area known as Area 10 to dispose of small quantities of the nerve agent tabun Mr. Conrad F. Whyne (GA) and lewisite. It is further anticipated that an explosive destruction technology Director chamber will be brought on-site to handle mustard agent munitions referred to as Chemical Materials Agency “rejects,” which present problems for processing through the TOCDF disassembly and 5183 Blackhawk Road destruction processes. A further complication affecting the closure of TOCDF is the Edgewood Area approximately 2 million pounds of legacy secondary wastes in storage that must be Aberdeen Proving Ground, MD 21010-5424 managed and disposed of during closure operations. Closure planning for TOCDF, including the disposal of legacy wastes and the RE: Letter Report on Review and Assessment of Closure Plans for the Tooele planning for the new units noted above, is presently at an early stage. While a general Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal closure plan was initially submitted as part of the initial permit application for TOCDF, a System more detailed closure plan is expected to be submitted to the state for TOCDF in June 2010. This and other information on the use of specific processes and analyses will be the Dear Mr. Whyne: subject of the full NRC report, to be prepared. Discussions with the state of Utah Department of Environmental Quality (UDEQ) are already under way to identify The Chemical Materials Agency (CMA), under your direction, requested the challenges that will eventually be addressed in the more detailed closure plan. National Academies’ Board on Army Science and Technology to examine the current The closure of CAMDS is at an entirely different stage, and except for the state of closure activities for the Tooele Chemical Agent Disposal Facility (TOCDF) and laboratories (discussed below), CAMDS is no longer operational. It was the pilot facility the Chemical Agent Munitions Disposal System (CAMDS). In this brief interim report, for the U.S. Army’s chemical demilitarization activities and operated between 1979 and the Committee on Review and Assessment of Closure Plans for the Tooele Chemical 2005. The CAMDS site encompasses 61 hazardous waste management units, a Agent Disposal Facility and the Chemical Agent Munitions Disposal System addresses ventilation system, and a number of buildings, some of which were used in testing some of the issues pertaining to closure at the TOCDF and CAMDS facilities. It also equipment for chemical agent destruction processes. Initial closure activities were carried provides insights into what the committee believes are important parameters to ensure the out by personnel affiliated with the Tennessee Valley Authority, who have recently been success of the CMA’s closure program for these and CMA facilities at other locations. As replaced by the TOCDF systems contractor, the EG&G Division of URS Corporation. indicated in the statement of task for the committee (see Attachment A), this interim Closure has progressed, with some equipment already removed from the buildings. More report is to be followed by another report, referred to hereinafter as “the full report,” detailed closure plans are being written for CAMDS, and their approval is being which will use these parameters to conduct a comprehensive assessment of closure requested on a unit-by-unit basis from the UDEQ. Final closure is expected to be activities and issues. completed by the first quarter of 2012. The main challenges associated with CAMDS For this interim report, the committee examined the current status of closure plans closure stem from its age, its use as a pilot facility, and to the site having many for both the TOCDF and CAMDS based on presentations by key members of your staff interconnected buildings and common utility services whose closure requires careful and the systems contractor. It then developed a set of parameters based on this high-level staging. evaluation that it believes are important in ensuring a consistently effective approach to Laboratory capabilities at CAMDS are being upgraded and will be used the closures of the four currently operating CMA chemical agent disposal facilities. The throughout the remaining disposal operations at DCD and the closure campaigns for committee also assessed regulatory requirements imposed by the state of Utah, where CAMDS and TOCDF. It is anticipated that the laboratory closure will take place in 2015. TOCDF and CAMDS are located. The committee is not aware of any current detailed closure plans for the laboratory. TOCDF and CAMDS are totally different facilities with different missions and The committee spoke with the chair of the Citizens Advisory Commission (CAC), different life cycles. They are located at Deseret Chemical Depot (DCD) near Tooele, who indicated that the CAC fully understands that the closures of the TOCDF and Utah, and share the same systems contractor for closure. Likewise, both are under the CAMDS facilities are a separate issue from the disposition of other solid waste jurisdiction of the same Utah state regulatory authorities and share many of the same management units (SWMUs) on the site that will require remediation. The CAC chair regulatory challenges. They are often viewed by the public as one facility. At present, it is further indicated that at this time closure has not yet become an important issue except -1- -2-

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for concern about loss of jobs. The Army and community have not so far developed a sufficiently emphasized in either the briefings the committee received or the plan for community involvement during closure. Programmatic Closure Planning document. The committee also spoke with members of the UDEQ that oversee compliance with state hazardous waste laws and requirements. In its exercise of regulatory Recommendation 1. The management of the Tooele Chemical Agent Disposal Facility jurisdiction over the TOCDF and CAMDS, the state of Utah developed some unique and the Chemical Agent Munitions Disposal System should consider safety the primary regulatory requirements. 1 Authority to regulate hazardous waste facilities and closure value in all of its decisions and work activities, and it should make its commitment to a under the Resource Conservation and Recovery Act (RCRA) was delegated to the state safe operation highly visible to all workforce personnel and site visitors. by the federal Environmental Protection Agency (EPA). Utah requirements generally adhere to all the EPA RCRA regulations, but in addition to these, waste listings specific Finding 2. Parameters and metrics provide important guidance for planning, organizing, to chemical agent operations have been added to the regulations. That is, “Nerve, Military and implementing efficient closure of chemical demilitarization sites. and Chemical Agents” is a class of materials listed as acute P999 hazardous waste. “Residues from Treatment and Testing of Nerve Military and Chemical Agents” are a Recommendation 2.The Army should consider the parameters and metrics presented in class of materials listed as F999 hazardous waste. In addition, all wastes that have been Table 1 (in the main body of this report) as it plans for the closure of the Tooele potentially exposed to agent liquid or vapor are considered a P999 or F999 “listed waste.” Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System. Any hazardous waste that meets the waste control limits (WCL) for agent by chemical analysis is an F999 waste that, on a case-by-case basis, can be considered for shipment Finding 3. As deconstruction activities proceed over the course of closure operations at off-site for additional treatment if necessary and subsequently sent to a hazardous waste the Chemical Agent Munitions Disposal System and the Tooele Chemical Agent landfill. Used (spent) activated carbon poses a particular challenge in this regard because Disposal Facility, a separate workforce will be on-site specifically to conduct demolition. Utah considers any activated carbon from chemical agent disposal operations, whether or This situation raises the possibility that safety performance could degrade because the not it was actually exposed to one or more chemical agents, to be a P999 waste that must new demolition workforce may be unfamiliar with the dangers of agent and agent be treated on-site. Utah’s practices for chemical agent wastes and residues are atypical degradation products and unfamiliar with the background circumstances regarding any within Utah; commercial hazardous wastes within the state are not so regulated. That is, demolition work done before its arrival. these practices are considered more restrictive and may impede the efficient disposition of wastes and the closure of the TOCDF and CAMDS sites. Recommendation 3. The Tooele Chemical Agent Disposal Facility/Chemical Agent In this interim study, the committee also considered prior closure experiences for Munitions Disposal System management should establish a cross-training and hazards three other chemical agent disposal facilities: the prototype baseline Johnston Atoll familiarization program to ensure continued strong safety performance and effective Chemical Agent Disposal System on Johnston Island in the Pacific Ocean and the utilization of personnel. hydrolysis-based facilities in Aberdeen, Maryland, and Newport, Indiana, where, respectively, bulk mustard agent and VX nerve agent were destroyed. In doing so, the Finding 4. The Utah Department of Environmental Quality (UDEQ) and the Army and committee remained mindful of the differentiating characteristics of these facilities in contractor continue to have good relations. Some UDEQ regulatory practices differ from relation to TOCDF and CAMDS. After evaluating these earlier closures and the closure those in force for commercial hazardous waste management facilities in Utah and, in planning to date for TOCDF and CAMDS, the committee identified parameters that are some cases, in other states that host chemical demilitarization facilities. All wastes from key to the successful closure of the still-operating CMA facilities. These are discussed in agent operations are considered listed wastes even if there is only a potential for exposure more detail in Table 1 of the main body of this interim report, which follows the to vapor, and they often require treatment on-site to meet waste control limits before they committee’s findings and recommendations. are transported off-site and ultimately disposed of in a hazardous waste landfill. Recommendation 4. The Army should negotiate risk-based criteria based on attainable FINDINGS AND RECOMMENDATIONS waste control limits with Utah Department of Environmental Quality to establish the reuse, recycling, on-site treatment, off-site treatment (if necessary), and off-site disposal Finding 1. The Tooele Chemical Agent Disposal Facility operates with a strong safety for all major waste streams especially metal, activated carbon, and concrete. culture, but this admirable approach to safety as an overriding parameter was not Finding 5a. The Army and its contractor have been planning for the Tooele Chemical 1 Unique in this context has two meanings. Utah’s regulations and practices for chemical Agent Disposal Facility closure for some time. Plans are to submit a request for a demilitarization activities located in Utah differ from those of other states. Utah also regulates chemical Resource Conservation and Recovery Act (RCRA) permit modification that will establish demilitarization facilities and the wastes they produce in a manner different from how it regulates other details for meeting relevant regulatory requirements applicable to the closure plan by hazardous waste facilities in Utah that is, facilities that do not produce chemical agent wastes. June 2010. Although some early closure activities have been initiated as approved partial  -3- -4-

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 closure authorizations under RCRA, formal closure operations of the munitions regulatory community to obtain less restrictive, but safe, regulatory practices that allow demilitarization building are expected to begin in September 2011, with closure of the for more efficient closure operations. metal parts furnace and liquid incinerators later on (mid-2013) to allow their availability for continued waste processing, including closure waste processing. The committee finds Finding 8. Through the Citizens Advisory Commission, Outreach Office, and other this schedule optimistic. forums, the Army has created a successful public participation program. The Army and community have not developed a plan for community involvement during closure. Finding 5b. Based on the information provided in the basic closure plan of the current permit, which will be combined into a single permit covering both the Chemical Agent Recommendation 8. The Army should discuss with the Citizens Advisory Commission Munitions Disposal System and the Tooele Chemical Agent Disposal Facility, there ways to establish a continuing, constructive public involvement between the end of appears to be sufficient time to meet the Army’s indicated milestones for closure of the demilitarization and formal closure. Chemical Agent Munitions Disposal System. Finding 9. A comprehensive Lessons Learned program for operations has been Recommendation 5. The Army should confirm with the regulators their willingness to implemented by Tooele Chemical Agent Disposal Facility (TOCDF) management, and is consider partial closure with attendant more detailed closure plans and permit also being applied to the TOCDF and the Chemical Agent Munitions Disposal System modifications. It should establish a realistic accelerated schedule for submitting its closure. For example, a comprehensive worker retention program for use during closure Tooele Chemical Agent Disposal Facility Resource Conservation and Recovery Act operations is in place. Closure Plan to ensure that closure operations are not delayed. Finding 6. At the time of this report, it is anticipated that the Tooele Chemical Agent Sincerely, Disposal Facility and the Chemical Agent Munitions Disposal System sites will be closed to an industrial use specification and have an end use that involves becoming part of the Tooele Army Depot. Still, a risk-based closure performance standard that would reflect an industrial end use, in the form of specific concentrations of specific constituents in the Peter B. Lederman, Ph.D., Chair various waste types and media, has not been negotiated. It is also unclear whether Committee on Review and analytical methods have been approved in Utah that are capable of measuring the Assessment of Closure Plans for the analytes at the selected performance standard. Tooele Chemical Agent Disposal Facility and the Chemical Agent Recommendation 6. The end use for the Tooele Chemical Agent Disposal Facility and Munitions Disposal System Chemical Agent Munitions Disposal System sites should remain as defined at the start of closure planning to avoid extensive delays. The Army should expedite its discussions with Utah Department of Environmental Quality on specific risk-based closure Attachments: performance standards that must be achieved. Further, if necessary, the Army should expedite its effort to gain approval of analytical methods. A Statement of Task B Acronyms and Abbreviations Finding 7. The risk of exposure to chemical agents during closure operations is expected C Committee on Review and Assessment of Closure Plans for the Tooele Chemical to be significantly lower than what potentially could be encountered during agent Agent Disposal Facility and the Chemical Agent Munitions Disposal System disposal operations. The regulatory standards and practices used by the state of Utah for D Acknowledgement of Reviewers controlling agent-contaminated materials were developed early in the program when there was little experience with managing the risks of materials exposed to agent. These practices and regulations may be more restrictive than necessary considering the nature of the closure operations. Recommendation 7. The Army should evaluate the reduced risk of exposure to chemical agents and their degradation products from closure operations and waste materials in view of Utah’s restrictive regulatory practices and consider negotiating with the Utah -5- -6-

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Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS CLOSURE PARAMETERS AND RELATED METRICS In satisfying the statement of task, the committee identified a series of key parameters for overall program management of the closure of the Tooele Chemical Agent Disposal Facility (TOCDF) and the Chemical Agent Munitions Disposal System (CAMDS). The committee considered the lessons learned by the U.S. Army Chemical Materials Agency (CMA) at earlier facility closures, specifically, the closure of the Johnston Atoll Chemical Agent Disposal System (JACADS), which was the first full- scale incineration-based disposal facility; the Aberdeen Chemical Agent Disposal System (ABCDF), which was the first neutralization-based disposal facility; and the Newport Chemical Agent Disposal Facility (NECDF), another neutralization-based facility. It used the information from these closure experiences and committee member expertise and knowledge of the plans and activities for TOCDF and CAMDS as the basis for developing the parameters in Table 1, which are discussed below. The parameters in Table 1 are shown along with associated metrics for promoting a safe and successful program for facility closure. These metrics are of two kinds: leading metrics, which help predict performance, and lagging metrics, which indicate the actual performance. While the metrics listed are considered important by the committee, they should not be considered all-inclusive. Moreover, it is important to note that as has been the practice during agent disposal operations, all plans and actions regarding closure need to be fully documented for future use and analysis. Safety, Health, and Security The committee believes that safety must continue to be at the forefront during closure operations. Both leading and lagging metrics for safety, health, and security (as well as other parameters) need to be tracked and documented as part of the normal deconstruction process. While not an exhaustive list, the metrics provided in Table 1 for this parameter represent a strong start. Good outcomes concerning safety and health are supported by the establishment of systemic data collection, site observations, and incident reporting and investigation processes. Also, the committee believes that the existing operations workforce should be briefed on the hazards of the deconstruction activities. Communications for Promoting Safety Culture The committee likewise believes that a strong, positive, safety culture will continue to prevail at TOCDF/CAMDS if the management maintains an active and involved safety communication and audit program. A good safety and operations culture rests on frequent formal and informal sharing of information and ongoing dialogue.  -7-

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 Letter Report on TOCDF-CAMDS Closure Planning MAR Draft: January 7, 2010 TABLE 1 Facility Closure Parameters and Associated Leading and Lagging Metricsa Parameter Leading Metrics Lagging Metrics Safety, health, and security Near misses (potential injury, potential exposure, potential breach) First aid cases by body part Site orientation for visitors and workforce Recordable injuries and exposures Incident investigations completed within 30 days Lost-time injuries (number) Cross training for workforces and supervisors Days away from work due to workplace incident/injury Appropriate personal protective equipment for all tasks (goal is 100 percent) Fatalities (all causes) Closure of open safety items in a timely manner Transportation incidents on-site/off-site Random drug testing Fires (ranging from smoke through explosion) Security (actual breach of fence line, procedures) Communications for Periodically survey employees, supervisors, and managers with Document frequency of safety communication promoting safety culture respect to criteria important to a strong safety culture sessions where employee leadership and participation are encouraged Maintenance Planning and scheduling of all maintenance work Audit maintenance process regularly Appropriate maintenance for construction equipment Monitor maintenance Preventive maintenance program for key equipment Predictive maintenance program for key equipment Appropriate calibration and checking of instrumentation and controls Training and development Cross train and educate for critical operation and deconstruction Not applicable positions Continuing education: at least 40 hours per year of technical coursework Workforce training on the facility and on non-normal process situations for operation personnel, including drills for abnormal conditions Workforce training on the facility and on non-normal process situations for deconstruction personnel, including emergency and abnormal conditions -8-

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Parameter Leading Metrics Lagging Metrics Communications with Scheduled communications with a local community action Measure response to meetings scheduled with various stakeholders committee with a consistent agenda stakeholders Communications with the state of Utah regulatory personnel on a regular and as needed basis Regularly scheduled two-way communications with the workforce throughout the life cycle of the site Track the lessons-learned program to ensure that the lessons are utilized throughout the chemical demilitarization program Quality criteria Identify complete inventory of units to be closed and the end state Track engineering changes plan for each Regularly track project schedule milestones from Ensure the environmental health and safety management system is preplanning to completion complete and operating with appropriate data analysis and management Develop project schedule milestone projections for the next period (week, month) Cost criteria Project program costs over similarly selected periods and verify Track program costs over selected periods Operations and Monitor lockout-tag-clear-and-try process Document excursions outside operating conditions deconstruction Establish and document safe operating conditions for all major Document frequency and duration of safety process equipment interlock bypasses Establish expected frequency and duration of “hot” electrical work Document frequency and duration of “hot” electrical work Track deconstruction progress (e.g., weight, volume, or number of units) -9- 

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0 Parameter Leading Metrics Lagging Metrics Management Ensure that supervisors and managers have appropriate experience Monitor implementation of personnel development with respect to operations, maintenance, or laboratory skills for high- and retention plan hazard processes Develop processes by which top managers regularly audit and assess all key activities Environmental regulatory Establish facility end-state conditions Monitor compliance with RCRA permit compliance Establish performance standards for closure wastes Monitor compliance with closure plans Modify Resource Conservation and Recovery Act (RCRA) permit to Monitor compliance with other permits include detailed closure plans Modify other applicable permits to include closure Monitoring plan compliance Develop waste analysis plan and waste characterization protocols Monitor implementation of waste analysis plan Develop monitoring plans for air and other media Analytical Establish criteria for use of generator knowledge Not applicable Identify validated analytical methods to be used Obtain regulatory acceptance of validated analytical methods Materials management Identify reuse and recycling options for deconstruction materials Implement control of inventory of hazardous and nonhazardous materials Develop protocols for segregation of generated hazardous and nonhazardous materials Obtain prior regulatory agreement for reuse, recycling, or disposal of all materials Identify means for control of inventory of hazardous and nonhazardous materials Establish a time line for risk-based disposition of all materials resulting from closure a A leading indicator is a prospective metric or set of metrics that can be used to develop strategies for project success; a lagging indicator is a retrospective metric or set of metrics that can point to a need for corrective action (NRC, 2009). -10-

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Maintenance Operations and Deconstruction Many injuries can be prevented through well-managed maintenance work The committee identified some common work activities for this parameter and processes. Basic maintenance begins with planning and scheduling, and it is a good goal listed them in Table 1). If done safely, these activities can lead to a safe and reliable to have at least 85 percent of all maintenance activities planned and scheduled at least closure operation. one week in advance. To minimize worker exposure, it would be advantageous to implement both preventive and predictive maintenance programs for equipment that will Management operate during closure, such as the metal parts furnace. Training and Development With all work activities, management sets the tone and leads the site effort by its example and their leadership. The metrics listed for this parameter in Table 1 offer ways to consider how management may want to measure their activities and their effectiveness Training and development of the workforce is a key strategic element for along with exercising appropriate oversight of all leading and lagging metrics in Table 1. successful program completion. The technical aspects of the TOCDF and CAMDS closure operations mandate that the workforce be properly prepared through education Environmental Regulatory Compliance and training provided by their employer. Additionally, it is imperative that an effective communication strategy be developed to ensure that there is open two-way dialogue with the workforce, regulators, and the community on critical issues. The committee believes Obtaining regulatory agreement to the closure plan in a timely manner is key to that a concerted effort should be made to train the deconstruction workforce on hazards achieving efficient closure. This requires close coordination with the regulatory awareness pertinent to the site situation. This cross training between personnel familiar community to obtain early agreement on closure performance standards. Before closure with operations at the site and the deconstruction workforce is believed to be essential for performance standards can be negotiated, the end state must be established. Based on this the safe outcomes that all stakeholders are interested in seeing. Establishing a program to anticipated end use, environmental standards and guidelines can be established, closure assess the effectiveness of the training provided is also necessary. plans completed, and permits modified. Continued monitoring for meeting the permit requirements will minimize delays. Communications with Various Stakeholders Monitoring Plan Compliance TOCDF/CAMDS management must actively lead and support communications with key stakeholders. Good communications build trust and provide more opportunities Development of the waste analysis plan requires agreement between the site to understand the changing nature of risk. contractor, the Army, and the Utah Department of Environmental Quality (UDEQ). This requires determination of what is to be analyzed and what analytical methods are to be Quality Criteria used. If methods have to be developed or validated, this activity requires a long lead time. If waste is to be shipped off-site, the recipient of the off-site waste may require additional testing and certification of the waste. Program quality is a key strategic element for successful program completion. Quality elements, such as adequate and appropriate analytical capabilities and retention of key personnel, comprise critical program management items that can significantly affect the outcome. Integrating quality into the operation supports all activities for continuous improvement. Cost Criteria Program cost objectives are a key strategic parameter of the successful completion of site closure. Management should be able to both forecast anticipated costs and to effectively explain all expenditures both committed and expended during any period. -12- -11- 

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 Analytical TOCDF CLOSURE STATUS AND ISSUES For closure wastes, there are several methods for determining whether the waste Facility Description poses residual hazards. Typically, generator knowledge 2 and standard methods such as those provided in the EPA publication SW-846 are used to determine if a waste meets the To dispose of chemical agents, TOCDF uses an incineration process comprising release criteria. When these are not available, new methods may have to be developed five interconnected systems: and validated. This may be time- and resource-intensive. System for unloading and unpacking system for munitions from the adjacent Materials Management Area 10 storage of the Deseret Chemical Depot (DCD); Separate disassembly systems for rockets, bulk containers, mines, and Careful materials management is a key to successful facilities closure. projectiles; Decontamination, reuse, recycle, and disposal options for equipment and secondary waste Furnace and incinerator systems that include a deactivation furnace system for materials generated during closure should be identified. Protocols for segregation of energetic materials, a metal parts furnace, and two liquid incinerators for generated hazardous and nonhazardous materials should then be implemented, including agent; planning for prevention of cross-contamination. This will require proper identification Various safety systems that include areas for explosive containment, a and inventory control of these materials. A time line for risk-based disposition of all cascaded ventilation system that moves plant air from less contaminated to materials resulting from closure should be developed. Prior regulatory agreement and more contaminated areas, airborne agent monitoring, fire protection, and door approval should be obtained for reuse, recycling, and disposal of all materials. In access monitoring; and addition, protocols that have been established to prevent releases from stored waste Various support systems, including pollution abatement systems, and controls should be continued. for electric, fuel gas, instrumentation, compressed air, hydraulics, and cooling. The pollution abatement system has recently been upgraded by the addition of a postcombustion mercury abatement system to capture various degrees of mercury contamination in mustard agent ton containers and projectiles. Current Operations TOCDF began agent disposal operations in August 1996 and completed disposal of GB nerve agent and munitions in March 2002. Disposal operations for VX nerve agent began in March 2003 and were completed in June 2005. The mustard agent campaign 2 began in July 2006 and is projected for completion in the third quarter of 2011. This date “Generator knowledge” is an evaluation method for hazardous waste that is commonly accepted will meet the treaty obligation date of April 29, 2012. and defined by the EPA and individual states based on some or all of the following information (EPA, 2005): Closure Planning Status 1. Facility process flow diagram or narrative description of the process generating the waste (should be used in most cases). 2. Chemical makeup of all ingredients or materials used in the process that generates the waste Closure planning for TOCDF is in early stages. A project management approach (should be used in most cases). is envisioned, with experienced senior management personnel presently assigned to 3. List of constituents that are known or believed to be by-products or side reactions of the process closure planning and implementation as their chief responsibilities. Moreover, that produces the waste. 4. Material safety data sheets and/or product labels or substances used in the process that generates experienced technical personnel familiar with the facility will be engaged during closure the waste. planning and implementation. Subject matter experts and proven procedures are also 5. Data obtained from approved methods of sampling and laboratory analysis of waste generated expected to be used as much as possible during closure. Closure planning will employ from the same process using the same ingredients/materials. best practices and approaches based on lessons learned from JACADS and other closures. 6. Data obtained from literature regarding waste produced from a similar process using the same Detailed plans and procedures have yet to be developed, but a general framework and ingredients/materials. 7. Documentation of product specifications or input materials and output products. time line have been established. The committee anticipates that these plans and -13- -14-

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procedures for closure would include an appropriate emphasis on safety, which were not Current Permit Status discussed fully in the closure documents and presentations obtained while this letter report was being prepared. Approval of the basic closure plan is expected to be requested The currently approved version of the TOCDF RCRA permit includes a basic from the UDEQ in June 2010. The target date for planning completion is January 2011, closure plan (Army, June 2009). The Army is presently pursuing a permit modification and the expanded plans will include development of new documentation for unit-by-unit for both CAMDS and TOCDF that combines active operations of both facilities, closure and the closure implementation schedule. including closure, under the TOCDF permit. 4 Utah officials have indicated that they will TOCDF closure planners are maintaining good relations and cooperation with the soon be ready to act on permit modification approvals, following RCRA public UDEQ. Closure operations, including those for the munitions demilitarization building, involvement and administrative actions. 5 are projected to begin in September 2011, but some advance work was being carried out TOCDF has held initial discussions with the UDEQ regarding closure, focusing as this report was being prepared (as discussed below). The metal parts furnace and liquid on specific issues. A RCRA permit modification to establish details for the regulatory- incinerators will be closed later in the schedule (mid-2013) to allow for their availability required closure plan is planned for submittal by June 2010. TOCDF closure plans within to process closure waste process. the existing (prepermit modification) permits indicate that the closure performance Present planning for TOCDF closure is based on a strategy of decontamination by standard will be based on an industrial future use scenario. moving progressively from the most contaminated to the least contaminated areas and The TOCDF closure plans also indicate that the incinerators and other units will structures. In general, this will involve removal of any residual agent and explosive be decontaminated as needed and dismantled. Some structures for TOCDF (primarily material residues, followed by removal of agent-exposed equipment and subsequent those used for nonagent operations) may remain following closure. Presently, TOCDF decontamination of occluded spaces and exposed surfaces. Scabbling will be used if in- plans to remove all materials, including scrap metal and demolition wastes (e.g., progress sampling shows it is needed. 3 When an area and structure have been completely concrete) from structures. Current requirements call for all of these materials to be decontaminated, the strategy for decontaminating the cascaded ventilation systems is to disposed of in a hazardous waste landfill as designated F999 wastes. Some wastes, such use a final washdown, certify that occluded spaces have been appropriately as demilitarization protective ensemble suits, may retain the combined P999/F999 waste decontaminated, and, finally, use ventilated and unventilated testing to measure internal code (discussed later under Utah Regulatory Requirements) following decontamination. ambient air agent concentrations in a controlled manner. Waste analysis to meet waste control limits (WCLs) and other criteria have been Certain closure tasks, such as decontamination and removal of equipment, will be required for both chemical agent and for agent degradation products prior to the off-site performed under partial-closure plans when possible without disrupting disposal transport of various wastes generated during disposal operations (such as decontaminated operations. Already a number of such tasks have been completed. Early closure activities munitions casings). However, analytical methods for these analytes in certain closure are projected to continue through August 2011. wastes (such as concrete and carbon) are still under development and will require A large quantity of stored legacy secondary waste, secondary waste being regulatory approval. generated during continuing munitions disposal operations, and waste from TOCDF closure operations is projected to be either processed on-site and/or shipped off-site. End Use and End Use Status Treatment, if necessary, and shipment of such wastes will take place during continuing disposal operations as scheduling opportunities present themselves or, alternatively, during closure operations. Secondary waste from all sources is projected to be disposed The site is envisaged at present to be closed to meet an industrial end use of by the third quarter of 2014. specification and will become part of the Tooele Army Depot following closure. The time line for TOCDF closure indicated above takes into consideration Complete closure of the TOCDF site and remediation to levels of residual contamination uncertainties concerning the UDEQ determinations on allowable standards for secondary for industrial use is envisioned. waste treatment and off-site disposal. Site deconstruction is projected to continue until June 2014, with final administrative closure of TOCDF in February 2016. Notwithstanding the planning described above, and based largely on committee members’ collective experience and observations in obtaining permit changes, the committee believes that the current schedule is optimistic. Moreover, certain members of the public are known to take great issue with some of the activities surrounding the chemical demilitarization program. Generally speaking, the more contentious the issues, the longer the permitting processes are likely to take. 4 Information here has been taken from a question-and-answer session between Ted Ryba, Site Project Manager, TOCDF Field Office, and the committee, on October 22, 2009. 5 Information in the final sentence of this paragraph and from the next three paragraphs is from a question-and-answer session between Dennis Downs, Director, Utah Department of Solid and Hazardous 3 Scabbling is the removal of a surface layer of material (such as concrete) to a specified depth. Waste, and the committee, on October 22, 2009. -15- -16- 

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 CAMDS CLOSURE STATUS AND ISSUES Current Closure Operations Current operations are limited to closure activities and the on-site laboratory, the Description last mentioned of which continues to provide analytical support for the DCD, including capabilities not found elsewhere at DCD. Closure activities are focused on 61 hazardous CAMDS was constructed to develop and test equipment and technologies for waste management units, including the following: dismantling and treating the stockpile of chemical agents and munitions stored on Johnston Island and at eight storage sites in the continental United States. The CAMDS 14 Subpart I units (chemical storage areas) facility was originally constructed between 1974 and 1978 and began munitions 43 Subpart J units (tank systems) processing on September 10, 1979. CAMDS was a pilot plant for various processes later 1 Subpart O unit (incinerator) constructed as fixed units at either baseline incineration or chemical hydrolysis-based 3 Subpart X units (miscellaneous) chemical agent disposal facilities. Some of the processes developed and tested at the facility are listed in Table 2. A total of 98,051 munitions and 363,524 pounds of chemical Closure activities will involve the facility ventilation system as well, including the agents, including GB, VX, and mustard agent, were destroyed at the facility ending in carbon filter units; the destruction of a number of buildings from which the bulk of the March 2005. 6 Many of the process units and much of the equipment at CAMDS have processing units have already been removed and that will also require asbestos abatement been dismantled. CAMDS closure is complicated by a number of factors, including the measures; and outside chemical and agent transfer lines. following: (1) the age of the various units, resulting in incomplete knowledge of the operating history; (2) its use as a pilot plant, resulting in use for a wide variety of Closure Planning Status chemical demilitarization operations; and (3) its configuration as multiple interconnected buildings having a common ventilation system and common utility services that require careful attention to the order of shutting down parts of the system. The current operator of the CAMDS facility, the EG&G Division of URS Corporation, only recently assumed control of the facility, and final closure planning is TABLE 2 Examples of Equipment Developed at CAMDS not complete. However, many of the processing units were dismantled and removed by Process type Equipment an earlier contractor. The current contractor has prepared partial closure plans for the Bulk neutralization Area detection system material treatment facility and chemical test facility, and acceptance is being negotiated Instrumented ton container with the UDEQ. Current efforts are directed toward the material treatment facility to refine and test closure procedures. They will be followed by deconstruction of the Incineration Liquid incinerator remaining buildings, from the most contaminated to the least contaminated. For each Deactivation furnace system building, decommissioning work packages will be prepared that recognize the unique Metal parts furnace processes and contamination history of the building and utilize a 10-step approach for each building as follows: Hydrolysis (Assembled Chemical Weapons Projectile washout system Alternative [ACWA] program) (1) Establishment of engineering controls and monitoring, (2) Preliminary survey, Thermal destruction (ACWA program) Metal parts treater (3) Preparation for work execution, (4) Decontamination and equipment disposition, SOURCE: Elizabeth Lowes, Deputy General Manager, Closure Integration, EG&G, “CAMDS and (5) Post-disposition survey, TOCDF closure approach/status,” Presentation to the committee, October 21, 2009. (6) Ventilated vapor screening level (VSL) monitoring, 7 (7) Unventilated VSL monitoring, (8) Final isolation, (9) Demolition, and 7 The VSL concentrations are equivalent to the short-term limit (STL) value, which is a concentration typically expressed in milligrams of specific agent per cubic meter of air. STLs are similar to short-term exposure limits (STELs) but without the 15-minute exposure time component. The VSL and 6 Elizabeth Lowes, Deputy General Manager, Closure Integration, EG&G, “CAMDS and TOCDF short-term limit values for agents of interest are as follows: GB, 0.0001 mg/m3; VX, 0.00001 mg/m3; closure approach/status,” Presentation to the committee, October 21, 2009. mustard agent, 0.003 mg/m3 (NRC, 2007). -17- -18-

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(10) Closure verification sampling. below the CAMDS site, is being addressed under a general permit corrective action program for DCD and thus is not an issue for TOCDF or CAMDS closure. CAMDS closure involves some unique complications. Because different process units were originally constructed over time, their closure involves dismantling numerous ENVIRONMENTAL REGULATORY ISSUES APPLICABLE TO CAMDS AND buildings with potentially different challenges. The buildings are also tied together with TOCDF common utilities, including ventilation and sump drains, which could also complicate the decontamination procedures. In closing CAMDS and TOCDF, the Army must comply with regulations The analytical laboratory at CAMDS is not a hazardous waste management unit established by the UDEQ under its delegated authority for a number of different identified within the permit covering CAMDS, so no specific permit actions are required environmental regulatory programs, including the Clean Air Act, the Clean Water Act to remove it from the applicable RCRA permit. However, it is anticipated that the and hazardous waste management regulations established under RCRA. The most heating, ventilation, and air conditioning filters for the laboratory will need to be worked challenging of these for CAMDS and TOCDF are the facility closure regulations under out in the future. RCRA (40 CFR Part 264, Subpart G). Finally, current closure planning does not address issues that will limit reuse of the property, such as the presence of subsurface fuel oil contamination. This RCRA Regulatory Background contamination, unrelated to the destruction of agent, is designated Solid Waste Management Unit (SWMU) 13. This and other SWMUs on DCD are separate from the closure of CAMDS. Utah has adopted EPA’s RCRA closure regulations established under 40 CFR Part 264, Subpart G (Utah R315-8-7). These require facilities to comply with a closure Current Permit Status performance standard. The performance standard for closing a facility is typically translated into risk-based quantitative criteria (such as concentrations) for specific constituents in waste materials. These criteria depend on the future use of the site. A pending permit modification for both CAMDS and TOCDF provides for Criteria for unrestricted (residential) use are generally more protective than those for combining the active operations of both facilities, including closure, under the TOCDF industrial use. The RCRA closure regulations also require facilities to submit detailed permit. 8 Utah officials have indicated that they will soon be ready to act on permit closure plans when applying for the permit. The plan then becomes part of the permit modification approvals, following RCRA public involvement and administrative actions. when it is issued. It may dictate a simple closure that applies to the entire unit or facility The resulting permit will contain basic closure plans for CAMDS, which will eventually or may propose a series of partial closures for specific units that will eventually lead to need to be expanded into unit-by-unit detailed closure plans and approved by the state final closure for the entire facility. Further, the closure plan includes waste inventory prior to execution. 9 CAMDS has already started work on these more detailed closure estimates, identification of the closure performance standard, and a schedule for closure, plans, which were not, however, made available to the committee in time for this report. among other information. Closure plans may be revised as needed as closure operations In the interim, CAMDS has proceeded with preclosure decommissioning activities (e.g., proceed, but such revision would require a formal permit modification. decontamination, removal of equipment) with the knowledge and oversight of the UDEQ. 10 Utah Regulatory Requirements and Practices End Use and End Use Status Utah has imposed regulations and practices with respect to chemical agents, many of which can be considered more restrictive than the usual RCRA requirements. These Like TOCDF, the CAMDS site will become part of the Tooele Army Depot upon unique regulations and practices have evolved over the years and are currently applicable closure. Closure will involve decontamination and disposal of all agent-contaminated to closure. Specific Utah regulations and practices are identified below. facilities and all buildings and facilities not needed by the depot. Closure of the CAMDS site will not resolve outstanding contamination issues, if any, associated with the Utah Regulatory Requirements analytical laboratory. In addition, subsurface fuel oil contamination from SWMU 13, 8 Information from a question-and-answer session between Ted Ryba, Site Project Manager, P999 and F999 Waste Codes. Utah has listed “Nerve, Military, and Chemical Agents” TOCDF Field Office, and the committee, on October 22, 2009. as acute hazardous waste under hazardous waste code P999 and “Residues from 9 Information from a question and-answer session between Dennis Downs, Director, Utah Demilitarization, Treatment and Testing of Nerve Military and Chemical Agents” as Department of Solid and Hazardous Waste, and the committee, on October 22, 2009. 10 Information from a question-and-answer session between Jerold Lynn, Site Project Manager, CAMDS, and the committee, October 22, 2009. -19- -20- 

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 listed hazardous waste under hazardous waste code F999. 11 Throughout the demilitarization campaign at CAMDS and TOCDF, restrictions were placed on Waste Activated Carbon and P999. Waste carbon that is actually or potentially management of acutely hazardous waste P999, and wastes resulting from treatment of the contaminated with chemical agent is designated P999 under Utah regulations. Under P999 wastes were designated F999. Residues from treatment, storage, or disposal of F999 present Utah restrictions, P999 wastes may not be sent off-site for treatment and disposal. wastes retain the hazardous waste designation and the code F999. Thus, wastes produced For example, much of the activated carbon (the final four of six banks) of the heating, during closure, even those that result from treatment of F999 wastes, are required to be ventilation, and air conditioning system has not, based on generator knowledge, been managed as F999 hazardous wastes, even if they are known to contain no detectable exposed to agent. It will also be necessary to evaluate in detail the disposal of carbon agent or other hazardous constituents. 12 from the TOCDF pollution abatement system filter system, which is likely to contain mercury or mercury compounds from the processing of mustard agent munitions having Cleanup Action and Risk-Based Closure Standards. Utah has established specific mercury contamination. requirements for closure of industrial sites: “Cleanup Action and Risk-Based Closure Standards” (UDEQ, 2001). Closure performance standards are developed in accordance Dual Waste Code for Some Materials. Some waste materials, primarily permeable with RCRA regulations. Risk-based closure performance standards are determined case solids, can be difficult to sample and analyze for chemical agents. Others, such as by case for nearly all facility closures. demilitarization protective ensemble suits that become waste after use, can be difficult to sample. In these cases, Utah has required decontamination of the materials and application of a dual P999/F999 waste code prior to off-site transport for disposal. Utah Regulatory Practices The standards and practices that Utah uses to address demilitarization disposal Agent Vapors. Utah includes materials contaminated as a result of actual or potential operations were developed before chemical agent began to be destroyed at CAMDS and contact with agent vapors as F999 waste. The result is that significant additional volumes TOCDF. Now, however, there will not be any significant amount of agent present during of various types of materials would become regulated as hazardous waste once generated closure. Furthermore, decontamination procedures will further reduce any agent residues during closure. that may be contaminating waste materials. Thus, the risks to human health and the environment from agent and its degradation products during closure operations will be Off-site Restrictions. Utah places restrictions on the off-site transportation of potentially reduced. This should provide the basis for considering less restrictive practices than the agent-contaminated materials for further treatment and/or disposal. In Utah, wastes must present UDEQ requirements, based on an evaluation of the risks of managing the closure be tested against the WCLs and may be transported off-site only if these levels are met. wastes. The WCLs were initially developed as drinking water standards for soldiers in the field (HQDA, 2005; HQDA, 2008). Even if the WCL is met, these wastes are still controlled PUBLIC PARTICIPATION as hazardous waste under the Utah F999 waste code. Waste Characterization. Since the early days of the chemical demilitarization program, Community involvement at the Utah demilitarization facilities is conducted the Army, being concerned primarily with worker exposure to agent vapor hazards, has primarily through the Citizens Advisory Commission (CAC), appointed by the Governor relied on the vapor screening of materials and wastes that have been exposed to chemical of Utah. The committee expects the CAC to provide opportunities for public participation agents (HQDA, 2008). In contrast, RCRA has historically used direct chemical analysis in closure planning. Thus far, although the CAC is aware that closure planning is under of wastes for constituents of concern (EPA, 2009). Utah has been reluctant to accept way, it is still engaged in the oversight of demilitarization operations. Although the vapor screening as a means of characterizing wastes that may have been exposed to liquid committee found the community was concerned that the end of demilitarization or vapor chemical agent. In those limited cases where it has accepted vapor screening, operations might lead to layoffs or have other economic consequences, it did not find any Utah has required the Army to apply more stringent criteria than the Army itself has community concerns that the closure of TOCDF and CAMDS would affect the established. For example, whereas the Army’s screening level for protection of workers is environment. The CAC, as well as other community bodies, such as the Restoration 1.0 VSL, Utah requires the Army to apply a more stringent standard, 0.5 VSL, as added Advisory Board for the entire DCD, are concerned about munitions response, corrective protection. Further, some waste streams, in particular those that may absorb chemical action, and related disposal activities, but those issues are beyond the scope of the task agent, must be decontaminated before vapor screening. for this committee. The Army and community have not yet developed a plan for community 11 Acute hazardous wastes are established under the RCRA program at 40 CFR 261.33(e) (Utah involvement during closure other than the requisite state forums under RCRA. While R315-2-9). F999 is added by the UDEQ to the listing of hazardous wastes from nonspecific sources found closure oversight is likely to be less intense than discussions of demilitarization, the CAC in 40 CFR 261.31 (Utah R315-2-11). 12 or a similar body can serve a valuable role during closure. The committee urges the Army While RCRA and the Utah regulations provide means of demonstrating that F999 wastes are not hazardous (that is, of “delisting”), the demonstration required is often arduous and prohibitively expensive. -21- -22-

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to discuss with the CAC ways to continue constructive public involvement between the Attachment A end of demilitarization and formal closure. Statement of Task REFERENCES The NRC will form a committee to provide two reports. The first is an EPA (U.S. Environmental Protection Agency). 2005. RCRA Hazardous Waste interim report assessing the following: Identification Training Module, 40 CFR 261, September, Washington, D.C.: Environmental Protection Agency. Examine the current closure plans for TOCDF and CAMDS and EPA. 2009. SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical make recommendations as required. Methods. Available online at Recommend key parameters to assess an integrated approach to http://www.epa.gov/waste/hazard/testmethods/sw846/online/index.htm. Last accessed common closure requirements. November 23, 2009. Assess planning for compliance with unique regulatory requirements of the State of Utah towards closure of the two HQDA (Headquarters Department of the Army). 2005. TB Med 577 Sanitary Control and chemical disposal facilities. Surveillance of Field Water Supplies. Available online at http://chppm- www.apgea.army.mil/documents/TBMEDS/TBMed577-15Dec2005.pdf. Last Following the issuance of the interim TOCDF-CAMDS closure report, accessed November 19, 2009. the National Research Council will issue a comprehensive report as HQDA. 2008. DA-PAM 385-61 Toxic Chemical Agent Safety Standards. Washington, follows: D.C.: Department of the Army. NRC (National Research Council). 2007. Review of Chemical Agent Secondary Waste Update the 2002 NRC report, Closure and Johnston Atoll Disposal and Regulatory Requirements. Washington, D.C.: The National Academies Chemical Agent Disposal System Report, as required. Press. Using the key parameters to assess an integrated approach to common closure requirements (as recommended in the interim NRC. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at TOCDF-CAMDS closure report), determine applicable lessons- Chemical Agent Disposal Facilities. Washington, D.C.: The National Academies learned from the closure of JACADS, ABCDF, and the ongoing Press. closure of NECDF for potential use during TOCDF and CAMDS TOCDF (Tooele Chemical Agent Disposal Facility). 2009. Closure Plan Attachment 10. closure. Stockton, Utah: Tooele Chemical Agent Disposal Facility. The interim report will be issued not later than six months after receipt UDEQ (Utah Department of Environmental Equality). 2001. Title V Operating Permit. of the contract and the comprehensive report will be issued no later than Available online at twelve months after the release of the interim report. http://www.airquality.utah.gov/Permits/DOCS/11339pmt.20060502.pdf. Last accessed November 19, 2009. UDEQ. 2001. R315-101: Cleanup Action and Risk-Based Closure Standards. Available online at http://www.hazardouswaste.utah.gov/Rules/Adobe/HazardousWasteRules/R315- 101.pdf. Last accessed December 17, 2009. -23- -24- 

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 Attachment B Attachment C Acronyms and Abbreviations Committee Members ABCDF Aberdeen Chemical Agent Disposal Facility COMMITTEE TO REVIEW AND ASSESS CLOSURE PLANS FOR THE ACWA Assembled Chemical Weapons Alternatives (program) TOOELE CHEMICAL AGENT DISPOSAL FACILITY AND THE CHEMICAL AGENT AND MUNTIONS DISPOSAL SYSTEM CAC Citizens Advisory Commission CAMDS Chemical Agent Munitions Disposal System PETER B. LEDERMAN, Chair, New Jersey Institute of Technology (retired), New CMA Chemical Materials Agency Providence, New Jersey JOHN B. CARBERRY, E.I. du Pont de Nemours & Company (retired), Newark, DCD Deseret Chemical Depot Delaware DEBORAH L. GRUBBE, Operations and Safety Solutions, LLC, Chadds Ford, EPA Environmental Protection Agency Pennsylvania JOHN R. HOWELL, The University of Texas, Austin GA a nerve agent (tabun) TODD A. KIMMELL, Argonne National Laboratory, Washington, D.C. GB a nerve agent (sarin) DANNY D. REIBLE, The University of Texas, Austin LEONARD M. SIEGEL, Center for Public Environmental Oversight, Mountain View, JACADS Johnston Atoll Chemical Agent Disposal System California DAVID A. SKIVEN, General Motors Corporation (retired), Brighton, Michigan NECDF Newport Chemical Agent Disposal Facility RCRA Resource Conservation and Recovery Act Staff SWMU solid waste management unit MARGARET N. NOVACK, Study Director (until January 2010) TOCDF Tooele Chemical Agent Disposal Facility NANCY T. SCHULTE, Study Director (from January 2010) HARRISON T. PANNELLA, Senior Program Officer UDEQ Utah Department of Environmental Quality NIA D. JOHNSON, Senior Research Associate UDSHW Utah Division of Solid and Hazardous Waste JAMES C. MYSKA, Senior Research Associate ALICE V. WILLIAMS, Senior Program Assistant VSL vapor screening level VX a nerve agent WCL waste control limit -25- -26-

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Attachment D Acknowledgement 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 National Research Council’s (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: Harold K. Forsen, NAE, Bechtel Corporation (retired), George W. Parshall, NAS, E.I. du Pont de Nemours & Company (retired), John A. Pendergrass, Environmental Law Institute, William R. Rhyne, Consultant, W. Leigh Short, Consultant, Charles F. Zukoski, NAE, University of Illinois. 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 Hyla S. Napadensky, NAE. Appointed by the National Research Council, she 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. -27-