1

Introduction

A notable achievement by the U.S. Army as of early 2012 is that 90 percent of the legacy chemical weapons and other chemical warfare materiel (CWM) from the Second World War and cold war eras and then stockpiled by the United States have been safely destroyed.1 Whatever cumulative risk had been posed by the existence of this CWM to communities surrounding the six military sites where it was guarded and safely maintained since the mid-twentieth century is now zero. Within a decade, the remaining 10 percent of the stockpiled CWM at two other military sites will likewise no longer exist. This monumental mission, spanning several decades, has been and continues to be accomplished safely in compliance with stringent federal and state environmental and health and safety requirements.

While the initial mission is phasing out after having overcome various scientific, regulatory, and political obstacles, an important and perhaps equally challenging mission remains that will become increasingly important over the next two decades. The international Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons, known informally as the Chemical Weapons Convention (CWC) treaty (CWC, 1997), to which the United States is a signatory, and U.S. legislation pertaining to such materiel required destruction only of CWM that was in storage (i.e., stockpiled), former production facilities that have since also been demolished, and CWM that was incidentally found and recovered from burial sites in various locations throughout the United States (so-called “small finds”) (EPA, 1980). However, since the First World War, the existence and locations of hundreds of thousands of other individual CWM items that remain buried have been identified and inventoried. Much of this materiel had been buried either after open burning or, sometimes, after being fired in munition ranges and was not considered part of the declared “stockpile” for CWC compliance purposes. These buried CWMs pose a huge challenge to the nation and the Department of Defense (DOD) as the need for usable land encroaches on these burial sites.

Approximately 250 sites in 40 states, the District of Columbia, and 3 territories are known to have or are suspected of having buried CWM, including some sites where large quantities are located (DOD, 2007). Nonetheless, much of the buried CWM is likely to continue to consist of small finds that necessitate continuation of the Army’s ability to transport treatment systems to such locations for their destruction (this rapid, short-term response is often called the “firehouse” function). Of greatest concern are sites in residential areas—the now urban Spring Valley section of Washington, D.C., and large sites on legacy military installations such as Redstone Arsenal, Alabama, where over 5 miles of disposal trenches have been identified. In general, large quantities of buried CWM are collocated with active or retired munition firing ranges or commingled with other hazardous substances and wastes that are routinely being cleaned up by the DOD’s Military Munitions Response Program (MMRP) and other remediation programs.

Neither the CWC treaty nor existing CWM domestic legislation requires recovery of buried CWM. Thus, the decision to contain the CWM in place or to recover it, at which point it becomes recovered chemical warfare materiel (RCWM) and is subject to the international requirement that it be destroyed, is an environmental remediation decision driven by federal and state environmental law. Such decisions are inherently site-specific and require consideration of the unique circumstances of the individual site, such as risk, the maturity and appropriateness of the technology that could be used, the presence of other toxic chemicals, existing and future land use (e.g., active installation or range), and the costs. The cost of characterization, remedy selection, and remediation of these large buried CWM sites is likely to be

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1See graph at http://www.cma.army.mil/aboutcma.aspx#. Accessed April 10, 2012.



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1 Introduction A notable achievement by the U.S. Army as of early 2012 declared “stockpile” for CWC compliance purposes. These is that 90 percent of the legacy chemical weapons and other buried CWMs pose a huge challenge to the nation and the chemical warfare materiel (CWM) from the Second World Department of Defense (DOD) as the need for usable land War and cold war eras and then stockpiled by the United encroaches on these burial sites. States have been safely destroyed.1 Whatever cumulative risk Approximately 250 sites in 40 states, the District of had been posed by the existence of this CWM to communi- Columbia, and 3 territories are known to have or are sus- ties surrounding the six military sites where it was guarded pected of having buried CWM, including some sites where and safely maintained since the mid-twentieth century is large quantities are located (DOD, 2007). Nonetheless, now zero. Within a decade, the remaining 10 percent of the much of the buried CWM is likely to continue to consist of stockpiled CWM at two other military sites will likewise no small finds that necessitate continuation of the Army’s abil- longer exist. This monumental mission, spanning several ity to transport treatment systems to such locations for their decades, has been and continues to be accomplished safely destruction (this rapid, short-term response is often called in compliance with stringent federal and state environmental the “firehouse” function). Of greatest concern are sites in and health and safety requirements. residential areas—the now urban Spring Valley section of While the initial mission is phasing out after having over- Washington, D.C., and large sites on legacy military instal- come various scientific, regulatory, and political obstacles, an lations such as Redstone Arsenal, Alabama, where over 5 important and perhaps equally challenging mission remains miles of disposal trenches have been identified. In general, that will become increasingly important over the next two large quantities of buried CWM are collocated with active decades. The international Convention on the Prohibition or retired munition firing ranges or commingled with other of the Development, Production, Stockpiling and Use of hazardous substances and wastes that are routinely being Chemical Weapons, known informally as the Chemical cleaned up by the DOD’s Military Munitions Response Pro- Weapons Convention (CWC) treaty (CWC, 1997), to which gram (MMRP) and other remediation programs. the United States is a signatory, and U.S. legislation pertain- Neither the CWC treaty nor existing CWM domestic ing to such materiel required destruction only of CWM that legislation requires recovery of buried CWM. Thus, the was in storage (i.e., stockpiled), former production facilities decision to contain the CWM in place or to recover it, at that have since also been demolished, and CWM that was which point it becomes recovered chemical warfare materiel incidentally found and recovered from burial sites in vari- (RCWM) and is subject to the international requirement that ous locations throughout the United States (so-called “small it be destroyed, is an environmental remediation decision finds”) (EPA, 1980). However, since the First World War, driven by federal and state environmental law. Such decisions the existence and locations of hundreds of thousands of are inherently site-specific and require consideration of the other individual CWM items that remain buried have been unique circumstances of the individual site, such as risk, the identified and inventoried. Much of this materiel had been maturity and appropriateness of the technology that could buried either after open burning or, sometimes, after being be used, the presence of other toxic chemicals, existing and fired in munition ranges and was not considered part of the future land use (e.g., active installation or range), and the costs. The cost of characterization, remedy selection, and remediation of these large buried CWM sites is likely to be 1See graph at http://www.cma.army.mil/aboutcma.aspx#. Accessed April 10, 2012. 11

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12 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL several billion dollars.2 Although it is impossible to predict 1. Destruction of binary chemical warfare materiel; at this time the ultimate cost of completely remediating all 2. Destruction of former chemical weapons production CWM buried during the last century, the DOD should ini- facilities; tially plan for a multi-billion-dollar program lasting many 3. Destruction of miscellaneous chemical warfare mate- years. This estimate should be revised as more information riel covered by the CWC—for example, chemical about the quantities and condition of the CWM to be recov- samples, empty ton containers, and metal parts; and ered becomes available. 4. Destruction of recovered chemical warfare materiel [chemical agent identification sets (CAIS) 4 and The Army’s remediation of RCWM is becoming a very large program, greatly exceeding the existing smaller muni- chemical weapons]. tion and hazardous substance cleanup programs. The organi- zational structure of the Army achieves its original mission Mission areas 1, 2, and 3 have been completed. Efforts in of handling ad hoc CWM finds. Numerous organizations mission area 4 have been under way since the establishment within the Army, as well as several offices within DOD, are of NSCMP and are expected to continue for the foreseeable involved in remediating existing RCWM sites. At present, future. different offices design and acquire the specialized CWM Over the past two decades the Army has prepared several destruction and other equipment, and other offices operate reports addressing DOD’s potential liabilities for locating, the equipment; another unit transports the equipment and excavating, and destroying decontaminated buried CWM and personnel. Moreover, various offices within the U.S. Army for managing any associated contaminated soil or ground- Corps of Engineers (USACE) and the Offices of the Secre- water. Cost estimates for these activities have varied widely tary of the Army and of the Secretary of Defense (OSD) play because multiple agencies have been creating cost estimates significant roles in setting policy, obtaining federal funding, using different assumptions about the number of sites need- prioritizing sites for remediation, participating in the selec - ing remediation, the amount of CWM to be excavated and tion of remedies, and directing the overall cleanup. destroyed or decontaminated at each site, and the amount Because of the imminent dramatic change in mission of contaminated soil or groundwater to be managed at each scope and the recognized complexity of the decision mak- site. The total estimated 30-year life-cycle cost of the RCWM ing and organizational issues involved, the Army asked the program ranges from a low of $2.5 billion to a high of $17 National Research Council (NRC) to examine this emerging billion (DOD, 2007). mission with a view to improving its efficiency. In addition As shown in Figure 1-1, past mission area 4 activities to examining the organizations and roles and the funding, were carried out in five areas: the NRC was asked to review the technology tools used in • the detection, excavation, packaging, storage, transportation, Emergency response to assess or destroy RCWM; • assessment, and destruction of buried CWM now available Planned responses and support to planning and per- and those that may be needed in the future. mitting activities; • The committee was provided the latest information avail- Research and development activities primarily able and was given unfettered access to the full range of per- related to the Army’s explosive destruction system sonnel involved in the process (including briefings and other (EDS), explosive destruction technologies (EDTs), communication with regulators). The committee benefited and portable isotopic neutron spectroscopy (PINS); • from the insight and candor provided by Army and DOD Assessment support for the U.S. Army’s Chemical staff, contractors, and other stakeholders. Materials Agency (CMA) and the Assembled Chemi- cal Weapons Alternatives (ACWA) Army element; and THE NATURE OF THE RECOVERED CWM PROBLEM • Assessment support at overseas locations. The mission of the U.S. Army’s Non-Stockpile Chemical Materiel Project (NSCMP) is “to provide management and There are planned response activities in Alaska, South direction to the United States Department of Defense for Dakota, Utah, Alabama, Florida, and Arkansas. Some of the the disposal of non-stockpile chemical materiel in a safe, sites listed, along with sites not shown here (see following environmentally sound, cost-effective manner, while ensur- section), are expected to contain substantial quantities of ing compliance with the Chemical Weapons Convention.”3 buried CWM, the remediation of which might be advanced To this end, the NSCMP has pursued four mission areas: through the findings and recommendations of this report. More detailed information on the specifics of activities in all four mission areas is presented in Figure 1-2. 2Deborah A. Morefield, Environmental Management, Office of the Deputy Under Secretary for Installations and Environment Department of Defense, “Remediation Operations from an OSD Installations and Environ - ment Perspective,” presentation to the committee on November 2, 2011. 3Laurence G. Gottschalk, PMNSCM, “Non-Stockpile Chemical Materiel 4Chemical agent identification sets (CAIS) were produced in large quanti- Project Status and Update,” presentation to the committee on September ties for training purposes from 1928 through 1969. A CAIS holds several 27, 2011. glass vessels, each containing a blister or choking agent.

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13 INTRODUCTION FIGURE 1-1 NSCMP mission area 4 past and projected schedule. RSA, Redstone (Alabama) Arsenal; APG, Aberdeen Proving Ground; OD, ordnance depot; T&E, testing and evaluation; CNB, CN tear gas mixed with carbon tetrachloride and benzene; TDC, transportable detonation chamber; PCD, Pueblo (Colorado) Chemical Depot. SOURCE: Personal communication from Laurence G. Gottschalk, Project FIGURE 1-1 NSCMP mission area 4 past and projected schedule.eps Manager for Non-Stockpile Chemical Materiel, to Nancy Schulte, NRC study director, March 7, 2012. BITMAP Figure 1-2 shows a wide range of information, including sites, formerly used defense sites (FUDS), base realignment the following: and closure (BRAC) sites, and active military ranges (DOD, 2007, Tables B-1, B-2, and B-3).5 A 2011 estimate by the • States with known or possible buried CWM; NSCMP raises to 40 the number of states with known or • possible buried CWM.6 Locations of past or planned NSCMP activities under all four mission areas, including assessment; destruc- The sites in the Army inventory where remediation work tion of agent, facilities, and munitions; and research is planned during the FY 2012-2018 budget cycle are listed and development; and in Table 1-1. These include active, BRAC, and FUDS sites at • The number and types of CWM destroyed in past which site investigations and/or cleanup work are expected operations or for which destruction is planned. to take place based on the Army’s current understanding of site-specific conditions.7 Known and suspected CWM sites include former manu- facturing facilities, former demilitarization operations, Non-Stockpile Chemical Warfare Material in the United former storage areas, disposal trenches and pits, chemical States warfare demonstration areas, test sites, and training facilities. CWM is defined by the DOD as follows: An early overview of the possible attributes of buried CWM is found in the Survey and Analysis Report, second edition, Items generally configured as a munition containing a chemi- produced by the Program Manager for Chemical Demilitar- cal compound that is intended to kill, seriously injure or ization (U.S. Army, 1996). The executive summary of that incapacitate a person through its physiological effects. CWM report says, “although documentation surveys, interviews, includes V- and G-series nerve agents or H-series (mustard) and L-series (lewisite) blister agents in other-than-munition configurations; and certain industrial chemicals (e.g., hy- drogen cyanide (AC), cyanogen chloride (CK), or carbonyl 5There are also 699 locations for which there exists only anecdotal evi - dichloride (called phosgene or CG)) configured as a military dence for the presence of CWM. munition. (DOD, 2007) 6Laurence G. Gottschalk, PMNSCM, “Non-Stockpile Chemical Materiel Project Status and Update,” presentation to the committee on September 27, 2011. The Army’s 2007 RCWM Program Implementation Plan 7Personal communication from Bryan M. Frey, Office of the Assistant lists 249 known or suspected CWM sites in 35 states, the Chief of Staff for Installation Management, Installation Services Director- District of Columbia, Guam, and the U.S. Virgin Islands ate, Environmental Division, Department of the Army, to Nancy Schulte, (DOD, 2007). They include active environmental restoration NRC study director, February 3, 2012.

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14 OCONUS Assessments Umatilla Chemical Depot, Oregon • Columboola, Australia Blue Grass Army • Okinawa, Japan • Category 3 CW Depot, Kentucky Newport Chemical • Philippines • Binary Aberdeen Proving Ground, Stockpile Depot, Indiana Maryland Assessment Former Production • 11 Munitions Destroyed Facility (FPF) Using EDS Fort Richardson and • Chemical Samples Tin City, Alaska • FPF 2 CAIS Recovery and • Binary Destruction–(RRS) • Ton Containers • Category 3 CW EDS/TDC/SCANS Testing Dugway Proving Ground, Utah Dover Air Force Base, • 71 RCWM Destroyed–EDS Delaware • DOT Containers 11 Munitions Destroyed–EDS Deseret Chemical Depot, Utah • Binary Spring Valley, • Ton Containers Rocky Mountain Washington, D.C. • Category 3 CW Arsenal, Colorado • CAIS Destruction–RRS 20 Munitions 10 Munitions Destroyed–EDS Destroyed–EDS Pueblo Chemical Redstone Arsenal, Depot, Colorado Fort Bragg, Alabama Fort Benning, Georgia North Carolina Stockpile Assessment • 16 Munitions Holloman AFB, New Destroyed–EDS CAIS Recovery and Mexico; CAIS Recovery and • CAIS Recovery and Destruction–SCANS Camp Bullis, Texas Destruction–SCANS Destruction–SCANS Former Williams AFB, CAIS Recovery and Pine Bluff Arsenal, Arkansas Porton Down, United Arizona Destruction–SCANS Camp Sibert, Alabama Schofield Army Barracks, Hawaii Kingdom CAIS–1 Item • 1,227 Munitions Destroyed 11 Munitions • EDS Testing • FPF Destroyed–EDS 71 Munitions Destroyed–TDC (P1U1 and P2U1 Units) • Binary • Category 3 CW RCWM RCWM • CAIS Destruction–RRS • Ton Containers KEY Possible Chemical No Known Chemical Complete Future Warfare Sites Warfare Sites FIGURE 1-2 Past and future mission areas 1-4 activities; locations and munitions destroyed. RRS, rapid response system, DOT, Department of Transportation; SCANS, single (chemi - FIGURE 1-2 Past and future mission areas activities.eps cal agent identification set) accessing and neutralization system; FPF, former production facility. SOURCE: Laurence G. Gottschalk, Project Manager for Non-Stockpile Chemical LANDSCAPE Materiel, presentation to the committee on September 27, 2011.

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15 INTRODUCTION TABLE 1-1 Inventory of Army RCWM Sites Also discussed in this report are the capabilities the NSCMP and the Edgewood Chemical Biological Center/ Name of Installation Type of Installation Chemical Biological Applications and Risk Reduction Redstone Arsenal, Ala. Active (ECBC/CBARR) program have been developing and imple- Pine Bluff Arsenal, Ark. Active menting for conducting emergency responses and for sup- Aberdeen Proving Ground, Md. Active porting remediation efforts of substantial size. Examples Dugway Proving Ground, Utah Active of the latter type of effort include those at Spring Valley in Schofield Barracks, Hawaii Active Washington, D.C., and Camp Sibert in Alabama. Thus, a Deseret Chemical Depot, Utah Active Pueblo Chemical Depot, Colo. BRAC critical mass of technology and experience now exists that Spring Valley, Washington, D.C. FUDS can be applied to remediation of larger sites that contain Camp Sibert, Ala. FUDS buried chemical weapons. Former Schilling AFB, Kans. FUDS State and federal regulators have taken note of the regula- Fort Glenn, Alaska FUDS tory situation and the availability of technology and exper- Withlacoochee, Fla. FUDS Black Hills, S.Dak. FUDS tise, and they are advocating moving forward with reme- diation efforts. A state regulator involved with the Redstone SOURCE: Bryan M. Frey, Office of the Assistant Chief of Staff for In- Arsenal in Alabama pointed out the following: stallation Management, Installation Services Directorate, Environmental Division, Department of the Army, briefing to the committee on January 18, 2012. • A combination of expertise, technology, personnel exists; • Growth of the Redstone area will require property and site visits have been conducted, much information con- reuse; cerning buried CWM remains unknown.” • Groundwater is known to impact areas in and around The little that is known about the nature of the buried disposal sites; CWM at each site is summarized in that report as follows: • It may take several years to develop, design, and implement remedies that adequately reduce the risks The CWM that may be found at these potential buried CWM to human health and the environment associated with sites includes CAIS, mortar rounds, aerial bombs, rockets, the identified exposure pathways8; and projectiles, and storage containers of agent in cylinders, • If you never start, you will never finish.9 55-gallon drums, and ton containers (TCs). Buried chemical agents include, but are not limited to, blister agents [mus- Other factors have been identified as well: tard (H) and lewisite (L)], nerve agents (GA, GB, and VX), blood agents [hydrogen cyanide (AC) and cyanogen chloride • Many military sites have a combination of buried (CK)], and choking agent [phosgene (CG)]. chemical weapons, buried conventional weapons, industrial pollutants, and contaminated soil and More up-to-date information about the quantities of groundwater. To clean up such a site, the project man- CWM at each site, the agents that may be contained in the agers will need to ensure that their cleanup capabili- CWM, and the condition of the CWM items is being devel- ties encompass the complete range of potential haz- oped by the Army site by site using historical records and ards, including CWM, conventional ordnance, and documents, visual observation of exposed materials found at environmentally contaminated media (soil, water, sites, and interviews with retired Army personnel who have and air). According to the CWC, once an item has knowledge of chemical materiel at specific sites. been determined to fall into one of the categories of chemicals covered by the treaty, steps must be taken Study Context to declare and destroy it.10 The Army’s efforts to demilitarize chemical weapons are transitioning from programs designed to destroy smaller finds subject to the emergency response function, former 8An exposure pathway is the route of contaminants from the source of production facilities, and individual CWM that are periodi- contamination to potential contact with a medium (air, soil, surface water, or groundwater) that represents a potential threat to human health or the cally discovered in areas where exposure may occur, to a pro- environment). gram of CWM remediation that continues to implement an 9Stephen A. Cobb, Chief, Government Hazardous Waste Branch, Land emergency response function but also recovers and destroys Division, Alabama Department of Environmental Management, “Reme- or provides containment of CWM that is present in pits and diation of Buried CWM in Alabama: The State Regulator’s Perspective,” trenches at identified sites. This effort will occur amidst a presentation to the committee on November 2, 2011. 10Personal communication from Lynn Hoggins, Director, CBW Treaty complex web of environmental regulations and guidance, Management, Office of the Deputy Assistant Secretary of Defense, Nuclear which are also examined in this report. Chemical, Biological, to Nancy Schulte, NRC study director, January 6, 2012.

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16 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL • Addressing the Statement of Task Once a military facility is no longer active, the forces that push it into non-military control can become Chapter 1 has provided an overview of the issues sur- intense. Local governments will want the property rounding current programs and plans for the demilitarization to become subject to property tax. Developers will of non-stockpile chemical materiel and the remediation of want parts of the property to become available for sites where such materiel is located. A description of the residential or commercial development. Prior to use contents of the remaining chapters of this report follows. for these purposes, buried chemical weapons, along Each chapter examines a different aspect of the overall with conventional weapons and contaminated soil, effort and how it impinges on the transitioning of the cur- must be removed, and contaminated groundwater rent program activities to larger-scale remediation efforts to must be appropriately managed. recover CWM. • Mechanisms have been established for providing the Chapter 2 delves into the very complicated web of orga- funding for remediation efforts. See Chapter 6 for a nizations in which NSCMP functions. The history of the discussion of this topic. chemical demilitarization program, including the establish- ment of NSCMP, is described briefly. The numerous DOD To facilitate the increased emphasis on remediation of and Department of the Army offices and organizations with buried chemical weapons in an efficient and cost-effective which the NSCMP is involved are listed and described. The manner, the roles and responsibilities of many of the rel- current reporting relationships and the flow of funding to evant organizations within the Army and DOD may need to NSCMP are described. Finally, the management practices change. This report addresses that issue. employed by NSCMP to carry out its RCWM remediation mission are discussed. Statement of Task Chapter 3 summarizes the regulatory framework for NSCMP’s RCWM program. The need to remediate known The National Research Council (NRC) will establish a or suspected chemical weapon burial sites—especially the committee to larger sites—has become more urgent in recent years. The factors responsible for this situation are examined in this • Survey the organizations involved with remediation chapter. The CWC, the treaty governing all activities involv- of suspected CWM disposal sites to determine current ing chemical weapons, is described. The impact of the two practices and coordination. At a minimum, the NRC will main relevant U.S. regulatory programs, RCRA (EPA, 1976) seek briefings from the following offices/organizations: and CERCLA (EPA, 1980), is briefly described. Finally, the Deputy Assistant Secretary of the Army, Environment, roles and responsibilities of NSCMP with respect to public Safety and Occupational Health; Deputy Assistant Secre- tary of the Army for the Elimination of Chemical Weap- involvement are discussed. Regulatory background is pro- ons; Chemical Materials Agency; Corps of Engineers vided in Appendix D. Huntsville, Engineering and Support Center; Chemical Chapter 4 summarizes the technologies that are currently Biological Radiological Nuclear (enhanced) Analysis and owned by or are available to NSCMP and closely related Remediation Activity; Edgewood Chemical and Biologi- organizations for the range of activities involved in locat- cal Center; and other directly involved entities identified ing a buried chemical munition, bringing it to the surface, as playing a role in CWM burial site remediations. assessing the munition, and destroying the munition. Recent • Review current supporting technologies for clean-up of remediation activities that have employed these technolo- CWM sites. This review would encompass excavation gies, recent advances in technology, and ongoing research equipment and techniques, containment facilities, filter- and development activities by NSCMP and others are listed ing techniques, personal protective equipment, monitor- and discussed. ing, assessment, packaging, storage, transportation (on- site and intrastate), destruction technologies, and waste Chapter 5 presents a discussion of several aspects of the storage and disposal. possible future remediation of the buried chemical warfare • Identify potential deficiencies in operational areas based materiel at Redstone Arsenal in Huntsville, Alabama, which on the review of current supporting technologies for is very likely the largest and most complex of the burial clean-up of CWM sites and develop options for targeted sites in the United States. A history of the existence and research and development efforts to mitigate potential disposal of non-stockpile chemical materiel at this very problem areas. large and complex site has been compiled by the Army and • Suggest means by which the coordination among organi- is described. Munitions and other items expected to be found zations involved in conducting investigations, recoveries, are listed. The abilities of technologies currently available and clean-up activities concerning non-stockpile CWM to NSCMP to assess the expected recovered items and to can be made more efficacious and effective. destroy or decontaminate them are discussed. Regulatory considerations and a possible organizational partnering concept for the effort at the Redstone Arsenal are described.

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17 INTRODUCTION Chapter 6 provides recommendations for targeted research in Chapter 2, and the impact of the future diminished role and development in the areas of (1) munition assessment, (2) of the CMA is discussed. Recommendations for changes in destruction of intact munitions, and (3) decontamination of both NSCMP organizational relationships and the flow of empty contaminated items. funding for remediation of CWM sites are then presented Chapter 7 presents a review the current NSCMP orga- and discussed. nizational relationships and flow of funding as presented