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