5
Redstone Arsenal: A Case Study

INTRODUCTION

Although its tasks are addressed in detail in the individual chapters of this report, the committee believes that the challenges facing the Non-Stockpile Chemical Materiel Project (NSCMP) can be examined in a more holistic manner by conducting a case study of one of the small number of sites that contain especially large quantities of chemical warfare materiel (CWM). There are 249 known and suspected sites in the United States that contain CWM (DOD, 2007), including several sites that could contain large quantities of CWM: Black Hills Air Force Base, South Dakota; Deseret Chemical Depot, Utah; and Redstone Arsenal (RSA), Alabama. RSA in Huntsville, Alabama, has 17 suspected CWM sites for which the state regulatory authority is requesting removal as an interim measure to satisfy the Resource Conservation and Recovery Act (RCRA). RSA is also believed to be the largest and most challenging of the sites in terms of estimated quantities, the condition and variety of items, operational complexity, regulatory issues, and potential remediation costs.

In this chapter, the committee uses RSA to illustrate the technological and operational challenges and community relations issues faced by NSCMP as it proceeds with the cleanup of large CWM sites. It also offers recommendations to improve the efficiency and effectiveness of the remediation activities.

THE CHALLENGES AT REDSTONE ARSENAL

The cleanup at RSA is a huge challenge for a number of reasons. The site comprises some 38,300 acres of land containing over 300 solid waste management units (SWMUs), 17 of which are designated by the regulatory authority as subject to interim measures involving CWM removal. Each of these units not only is likely to require a customized approach but also has more than 5 mi of disposal trenches and various burn and disposal areas for chemical munitions and related wastes as a result of operations that began in the early 1940s.1,2 Further, the combination of active and former operational areas supports a large number of tenants and is situated in a region with a growing economy and a growing population. The magnitude of the problem is illustrated to some extent in Figure 5-1. Note especially the large size of the facility and the many CWM sites within its 38,000 acres. These factors and others discussed below call for a very carefully considered and deliberate approach to remediation.

CHEMICAL WARFARE MATERIEL INVENTORY

From 1940 until 1945, this was the site of three chemical agent plants at the Huntsville Arsenal, where toxic agents such as mustard (H/HS), lewisite, phosgene (CG), and adamsite (DM) were produced and where the RSA Ordnance Plant assembled and packaged chemical munitions such as 75-mm to 155-mm shells and 30-lb and 100-lb chemical bombs. These plants also produced many munitions filled with smoke and incendiary chemicals. Examples of the items produced are listed in Table 5-1.

Following the Second World War, the Ammunition Returned from Overseas (ARFO) program brought up to 1 million munition items to RSA for evaluation and demilitarization. These munitions came from Germany, Japan, and Great Britain and contained agents not produced in the United States, such as British mustard (HT), the German nerve agent tabun (GA), German mustard, thickened German mustard, and nitrogen mustard (HN-3). Destroying these agents presented challenges to the Army at the time.

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1Stephen A. Cobb, Chief, Government Hazardous Waste Branch, Land Division, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011.

2Terry de la Paz, Chief, Installation Restoration Branch, Environmental Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspective,” presentation to the committee on November 2, 2011.



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5 Redstone Arsenal: A Case Study INTRODUCTION early 1940s.1,2 Further, the combination of active and former operational areas supports a large number of tenants and is Although its tasks are addressed in detail in the individual situated in a region with a growing economy and a growing chapters of this report, the committee believes that the chal- population. The magnitude of the problem is illustrated to lenges facing the Non-Stockpile Chemical Materiel Project some extent in Figure 5-1. Note especially the large size of (NSCMP) can be examined in a more holistic manner by the facility and the many CWM sites within its 38,000 acres. conducting a case study of one of the small number of sites These factors and others discussed below call for a very that contain especially large quantities of chemical warfare carefully considered and deliberate approach to remediation. materiel (CWM). There are 249 known and suspected sites in the United States that contain CWM (DOD, 2007), includ- CHEMICAL WARFARE MATERIEL INVENTORY ing several sites that could contain large quantities of CWM: Black Hills Air Force Base, South Dakota; Deseret Chemical From 1940 until 1945, this was the site of three chemical Depot, Utah; and Redstone Arsenal (RSA), Alabama. RSA agent plants at the Huntsville Arsenal, where toxic agents in Huntsville, Alabama, has 17 suspected CWM sites for such as mustard (H/HS), lewisite, phosgene (CG), and which the state regulatory authority is requesting removal as adamsite (DM) were produced and where the RSA Ordnance an interim measure to satisfy the Resource Conservation and Plant assembled and packaged chemical munitions such as Recovery Act (RCRA). RSA is also believed to be the largest 75-mm to 155-mm shells and 30-lb and 100-lb chemical and most challenging of the sites in terms of estimated quan - bombs. These plants also produced many munitions filled tities, the condition and variety of items, operational com- with smoke and incendiary chemicals. Examples of the items plexity, regulatory issues, and potential remediation costs. produced are listed in Table 5-1. In this chapter, the committee uses RSA to illustrate the Following the Second World War, the Ammunition technological and operational challenges and community Returned from Overseas (ARFO) program brought up to 1 relations issues faced by NSCMP as it proceeds with the million munition items to RSA for evaluation and demili- cleanup of large CWM sites. It also offers recommendations tarization. These munitions came from Germany, Japan, to improve the efficiency and effectiveness of the remedia- and Great Britain and contained agents not produced in the tion activities. United States, such as British mustard (HT), the German nerve agent tabun (GA), German mustard, thickened German THE CHALLENGES AT REDSTONE ARSENAL mustard, and nitrogen mustard (HN-3). Destroying these agents presented challenges to the Army at the time. The cleanup at RSA is a huge challenge for a number of reasons. The site comprises some 38,300 acres of land con- taining over 300 solid waste management units (SWMUs), 17 of which are designated by the regulatory authority as 1Stephen A. Cobb, Chief, Government Hazardous Waste Branch, Land Division, ADEM, “Remediation of Buried CWM in Alabama: The State subject to interim measures involving CWM removal. Each Regulator’s Perspective,” presentation to the committee on November 2, of these units not only is likely to require a customized 2011. approach but also has more than 5 mi of disposal trenches 2Terry de la Paz, Chief, Installation Restoration Branch, Environmental and various burn and disposal areas for chemical munitions Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried and related wastes as a result of operations that began in the CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspec - tive,” presentation to the committee on November 2, 2011. 66

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67 REDSTONE ARSENAL: A CASE STUDY FIGURE 5-1 Map of Redstone Arsenal, Alabama. SOURCE: Terry de la Paz, Chief, Installation Restoration Branch, Environmental Management Division, RSA, Alabama, presentation to the com- mittee on November 2, 2011. FIGURE 5-1 Map of Redstone Arsenal Alabama.eps BITMAP

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68 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL • TABLE 5-1 Partial List of Chemical Items Produced at Large quantities of agent-contaminated metal such as RSA Ordnance Plant During the Second World War burned-out bomb bodies, 55-gal drums, British land mines, and plant production equipment; Agent Item Quantity • Over 10,000 CAIS bottles, both intact and damaged, Mustard (H/HS) 105-mm M60 rounds 1,770,000 containing surviving H/HS, and 155-mm M105, M104, M110 31,000 • Small quantities of CG-filled items. rounds 4.2-in. mortar rounds 54,000 100-lb. M47 and M70 bombs 560,000 The total quantities of remaining items cannot be known Ton containers, 30- and Unknown until source removal action is taken and disposal begins. 55-gal drums However, based on archival research and interviews with Lewisite Ton containers Unknown former employees, there is a potential for significant quan- Phosgene 500-lb bombs (M78) and 1,000- Unknown tities of munitions, both conventional and chemical, and lb bombs (M79) White phosphorus 4.2-in. shells, 75- and 4,194,000 chemical warfare-related items (e.g., drums and production 155-mm shells equipment) to be found in various states within burial sites 100-lb bomb (M46, M47) 162,000 at RSA.5 These quantities have been assigned to the various M15 hand grenades 951,000 SWMUs at RSA and each lot has been characterized by SOURCE: Terry de la Paz, Chief, Installation Restoration Branch, Environ- munition or container type (e.g., bomb, canister, mortar) mental Management Division, RSA, Alabama, “Remediation of RCWM and by agent content (e.g., H, GA, CG). The quantities that from Burial Sites,” presentation to the committee on November 2, 2011. could be encountered are divided into three categories, which are defined in the footnotes, and are estimated as follows: Between 1945 and 1950, major disposal actions were Intact items: 85,000-92,0006 taken to destroy chemical munitions and agents, with most Empty contaminated items: 844,000-855,0007 of the toxic chemical agents being processed by 1949. The Empty noncontaminated items: 1,971,000-1,975,008 agent production and ordnance plants at RSA were decon- taminated and demolished, and the post-Second-World-War German Traktor rockets being prepared for disposal in a overseas ordnance, reject munitions produced at RSA, and pit are shown in Figure 5-2. “good” munitions produced there were disposed of, usually by burning in trenches. Although mustard munitions in pits were burned twice Processing of Unusual Items at Redstone Arsenal with subsequent refilling of the pits, large quantities of con- The burial pits at RSA are expected to contain many taminated and potentially contaminated materiel remain at 17 items that NSCMP may not have encountered previously. For sites, where today there is still a possibility of encountering example, the “empty contaminated” category in the inventory CWM. Based on excavation of a similar pit at Pine Bluff of buried items includes these:9 Arsenal Site 12 in 1987, about 10 percent of the original mustard-filled munitions may have survived the burning • Production plant equipment, chemical with HS, L, and might still need to be destroyed.3 Other munitions may and WP: 91,400 items, have been partially destroyed, with residual quantities of • German Traktor rockets with GA and HN-3: 54 toxic chemical agent remaining in the munitions, on metal items, surfaces, or within the soil or other fill materials. Examples of chemical items that could remain in trenches and pits at RSA include the following:4 5Ibid. 6An intact item is physically intact enough to hold most or all of the origi- nal agent content of the munition. These items will require agent destruction • Rubberized mustard residue from thickened German by a suitable technology (e.g., an EDS or an EDT). mustard in burned 250-kg bombs: 1,660 bomb bodies 7An empty contaminated item is a munition that has been opened and with probable residue are estimated to remain; partially burned or decontaminated but can still provide a detectable air • H/HS in burned 250-kg and 500-kg bombs: 40-50 monitoring reading. These items will require further treatment to destroy any lb of heel may remain in each of an estimated 9,000 remaining quantities of chemical agent, smoke, or incendiary fill. 8An empty noncontaminated item is a munition that has been physically bomb bodies; opened and burned or decontaminated to a point where no chemical agent, • Possible concrete-encased 500-kg H/HS-filled bombs; smoke, or incendiary chemical can be detected by air monitoring equip- ment. These items should be clean enough to not require further processing and can be disposed of as nonhazardous waste or sent to a smelter or other 3William R. Brankowitz, Senior Chemical Engineer, Science Applica - commercial disposal facility. 9William R. Brankowitz, Senior Chemical Engineer, Science Applica - tions International Corporation, “Non-Stockpile Chemical Materiel Project Redstone Arsenal (RSA) Interim Historical Report,” presentation to the tions International Corporation, “Non-Stockpile Chemical Materiel Project committee on January 18, 2012. Redstone Arsenal (RSA) Interim Historical Report,” presentation to the 4Ibid. committee on January 18, 2012.

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69 REDSTONE ARSENAL: A CASE STUDY small quantities of explosives in recovered munitions,11 and the MARB review process is likely to result in long delays when large numbers of items are being processed at RSA (see “Assessment of Recovered Munitions” in Chapter 7 for more information on this issue). As described in the preceding section, large numbers— perhaps as many as 1 million—of empty but still contami- nated items exist at RSA.12 While many of these may be further decontaminated using existing destruction technol- ogy equipment such as the explosive destruction system, these technologies are not expected to have the capacity to destroy such a large number of items in a reasonable time frame. Other options, such as soaking in a decontamination solution or heating in a furnace, may be preferable, especially if the energetics have been removed and the munition casing has already been opened, thus eliminating the need for an IGURE 5-2 German Traktor rocket pit at Redstone at Huntsville (now c. 1948.eps destruction technology to access the agent cavity. Arsenal, Alabama, explosive FIGURE 5-2 German Traktor rocket pit BITMAP This would be particularly true for decontaminating the many Redstone) Arsenal, Alabama (photo from 1948). SOURCE: William pieces of production plant equipment that are expected to be R. Brankowitz, Senior Chemical Engineer, Science Applications In- ternational Corporation, “The Redstone Arsenal Archival Review,” found in several of the pits at RSA. presentation to the committee on January 18, 2012. Other solutions that may be examined include disposal- in-place or consolidated disposal in a suitable location on-site, with land use controls and continued monitoring as • 55-gal drums with CNS, CNB, HS, HT: 21,046 items, appropriate. The suitability of these cleanup options at RSA • Bombs, chemical, 100-lb M47, HS fill: 11,032 items, will depend on the applicable laws, regulations, and U.S. • Bombs, chemical, 115-lb, M70, HS fill: 33,514 items, Army policies as well as the development of a constructive • Bombs, chemical, German, 250 kg, GA fill: 750 relationship between the various stakeholders (including the items, and Army, the state of Alabama, EPA, tenants, and local com- • Bombs, chemical, German, 500 kg, GA fill: 692 munity groups). A flexible approach to remediation and risk items, management at RSA has the potential to expedite cleanup while reducing its overall cost. where HS is 60 percent sulfur mustard and 40 percent bis[2- The strengths and limitations of the current supporting (2-chloroethylthio)ethyl]ether, CNS is phenyacyl chloride technologies for use in the cleanup of CWM sites are dis- (CN) tear gas mixed with chloropicrin and chloroform, and cussed in Chapter 4. The legal and regulatory issues associ- CNB is CN tear gas mixed with carbon tetrachloride and ated with the various options are presented in Chapter 3, with benzene. background information presented in Appendix D. The 17 interim-action sites at RSA with known or sus- TECHNICAL AND OPERATIONAL ISSUES pected CWM fall into two categories when it comes to res- toration funding, which complicates and potentially delays Remediation at RSA is complicated by a number of the overall remediation process. Of these 17 sites, 5 are technical and operational factors. The arsenal contains a eligible for the Defense Environmental Restoration Program large number and wide variety of munition types (see pre- (DERP), while the remaining 12 are classified as operational ceding section) in different stages of degradation and was ranges and must seek funding from the Compliance Cleanup 10 used for many years as a disposal site for toxic chemicals. Program of the Army’s Operations and Maintenance (OMA) Additional processing capacity may be needed to safely program. Since OMA funding is limited (less than $20 mil- and efficiently process such quantities of munitions and lion is available each year), these sites may require many contaminated materials and media if they are removed. The conventional approach for identifying the contents of a sealed munition suspected of containing CWM is to use portable isotopic neutron spectroscopy (PINS) to collect data 11Dan G. Noble, Project Manager, Spring Valley Baltimore District, U.S. that are then analyzed by the Materiel Assessment Review Army Corps of Engineers, “Project Management of Spring Valley: A Corps Board (MARB). While PINS is a valuable tool, it has not of Engineers Perspective,” presentation to the committee on November 1, 2012. been completely reliable for identifying chemical fills or 12William R. Brankowitz, Senior Chemical Engineer, Science Applica- tions International Corporation, “Non-Stockpile Chemical Materiel Project Redstone Arsenal (RSA) Interim Historical Report,” presentation to the 10Ibid. committee on January 18, 2012.

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70 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL Assessment of Intact Munitions years for complete remediation.13,14 Overall, it has been estimated that it could take up to 15 years and between $1 bil- The PINS/digital radiography and computed tomography lion and $3 billion to complete restoration.15 The committee (DRCT)/MARB approach has never been used on a project believes that the current management approach and funding involving the large number of munitions expected to be found constraints for operational ranges greatly complicate the at RSA, where tens to hundreds of thousands of items may task of cleanup there. For more details on operational issues still contain detectable quantities of agent and energetics. that may impact the effectiveness of cleanup operations at The current approach would be overwhelmed, and changes to RSA and recommendations for operational improvements, it will be needed to prepare for this massive effort involving see Chapter 6. diverse agents and energetics. See Chapter 6 for findings and RSA is home to more than 130 landowners and tenants, recommendations on this topic. including the Army, NASA, the Tennessee Valley Authority, and the Wheeler National Wildlife Refuge; in addition, an Destruction of RCWM-Containing Energetics ongoing cleanup program for dichlorodiphenyltrichloroeth- ane (DDT) is being conducted by Olin Corporation. Also, Technologies are available to NSCMP for the destruction given its location in the Tennessee Valley, on a partial flood of the intact munitions. The Dynasafe SDC is suited for this plain having a complex hydrogeology, it should be expected purpose because of its high throughput rate and because it that the cleanup program will draw a great deal of scrutiny can produce scrap metal that is suitable for release for unre- from regulators and community groups concerned about the stricted use (formerly termed “5X”). The CH2M HILL TDC protection of the region’s environment. or the DAVINCH could also be used, but they have slower Coordinating access to all of these facilities and land throughput rates and produce scrap metal that is not suitable areas and gaining the cooperation of the tenants will be a for release for unrestricted use. Again, the items expected to significant challenge for NSCMP. The committee believes be found at RSA are anticipated to contain a wide variety of that community and general stakeholder engagement will be chemical agents and chemicals, including H, HD, HT, HS, critical for a successful remediation program at RSA, and it L, WP, CNS, CNB, HN-3, CG, and GA (see Finding 5-2 and points to the important lesson learned at the formerly used Recommendation 5-1). defense site (FUDS) of Spring Valley in Washington, D.C. Some of the munitions, including any intact 500- and Notwithstanding the difficulties experienced in the early days 1,000-lb bombs, might be too large to be destroyed in the of the cleanup effort, a collaborative partnership eventually available EDTs. However, the large item transportable developed that simplified decision making and made it more access and neutralization system (LITANS) is an NSCMP- acceptable to all parties (see the later section “Community developed technology that could be used for this purpose Concerns” for more information). (U.S. Army, 2011e). LITANS throughput may be too low, however, if a great many items are found. MATCH OF TECHNOLOGY NEEDS WITH NSCMP CAPABILITIES Processing of Nonenergetic RCWM As indicated earlier in this chapter, it is expected that Between 844,000 and 855,000 items that are empty but 85,000-92,000 intact chemical munitions and 844,000- contaminated with agent and energetics, including burned 855,000 empty but contaminated items will be encountered. and opened munition bodies, are expected to be encountered. If a remove-and-treat approach is selected, the key techno- These items will require treatment to the ≤1 VSL (formerly logical responsibilities for NSCMP will be to (1) assess the 3X) level or suitable for release for unrestricted use (formerly intact munitions, (2) destroy the intact munitions, and (3) 5X) level. Processing them through a Dynasafe SDC appears decontaminate (remove agent and energetics from) the empty to be a good approach that produces scrap metal suitable for contaminated items. release for unrestricted use. Other candidate technologies include the CH2M HILL TDC, a high-temperature furnace similar to the Blue Grass (BGCAPP) metal parts treater or the Pueblo (PCAPP) metal treatment unit; a commercial transportable hazardous waste incinerator; a car bottom furnace; and treatment with decontamination solution. Any 13Stephen A. Cobb, ADEM, “Remediation of Buried CWM in Alabama: technology selected must be able to destroy the wide range The State Regulator’s Perspective,” presentation to the committee on No- of expected agents while also meeting the applicable waste vember 2, 2011. 14James D. Daniel and Tim Rodeffer, “USACE Operations of Recovered management and emission requirements. A study to evaluate Chemical Warfare Material from Burial Sites: Cleanup and Munitions and rank these technologies is needed and should consider Response Division,” presentation to the committee on December 12, 2012. the option of containment in lieu of treatment. 15Stephen A. Cobb, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on No- vember 2, 2011.

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71 REDSTONE ARSENAL: A CASE STUDY Finding 5-2. The items expected to be found at RSA are Dynasafe has said that its SDC 2000 system has been used in Germany for decontaminating large quantities of anticipated to contain or be contaminated with a wide variety agent-contaminated metal, including opened contaminated of chemical agents and chemicals. The technologies selected munitions.16 Some of the munitions also contained energet- to destroy or decontaminate these items must be able to ics, agent-contaminated in some cases. To decontaminate destroy the chemical agents and chemicals while producing these and similar materials in the SDC 1200, no changes air emissions within acceptable limits. would need to be made to the hardware; up to 330 lb of metal Recommendation 5-1. The Non-Stockpile Chemical Mate- could be fed per cycle as long as the agent quantity does not exceed 2 lb per feed. The cycle time would be 7 min. riel Project should conduct a study of the ability of currently Dynasafe expects that optimal use of the SDC 1200 at RSA or available or other candidate technologies to destroy or con- a similar site would involve mixing contaminated scrap with tain the wide range of unusual items, including large items explosively configured recovered rounds for each feed cycle. or munitions containing chemical agents and chemicals such Finally, very large items, such as the bodies of the as H, HD, HT, HS, L, WP, CNS, CNB, HN-3, CG, and GA, 500- and 1,000-lb bombs, sections of the agent production while meeting waste management requirements and produc- facilities, and 55-gal drums, may require decontamination. ing air emissions within acceptable limits. The technologies These items may be too large to be fed to existing treatment include those used for destroying intact munitions and those technologies. Means of treating these large items should be used for decontaminating agent-contaminated items. to investigated; such a study should consider a containment Finding 5-3. The overall cleanup at RSA, which will involve option in lieu of treatment. The items expected to be found at RSA are anticipated to conventional munitions, chemical munitions, and conven- contain or be contaminated with a variety of chemical agents tional pollutant contamination both on operational ranges and chemicals, including H, HD, HT, HS, L, WP, CNS, and on other areas of the installation, will make it one of CNB, HN-3, CG, and GA. It is not clear that the available the largest, most complex, most long-lasting, and costliest explosive destruction technologies (EDTs) would be able responses ever mounted for CWM munitions in the United to effectively treat all these chemical agents and chemicals States. without changes to the operating procedures or the equip- Recommendation 5-2. The Army should develop orga- ment. For example, lewisite (L) contains 37 weight percent arsenic, and the air pollution control system would have to nizational, operational, and funding plans for a complex, be able to remove large amounts of arsenic oxides from the long-term, costly cleanup project at Redstone Arsenal, with detonation chamber off-gases (NRC, 2009a). Similarly, the the plans based on the programmatic recommendations dis- entire chemical charge of a munition containing WP would cussed in Chapter 7. be converted to P2O5, which means that the off-gas treat- ment system would need to remove and neutralize vastly REGULATORY ISSUES larger quantities of P2O5 than when the munition contains any other chemical agent or chemical. These technologies In addition to the 17 sites discussed above, the RSA has include those used for destroying intact munitions and those hundreds of old disposal locations containing chemical used for decontaminating agent-contaminated items. and conventional munitions; some locations are also con- taminated with industrial chemicals, including pesticides.17 However, the NSCMP cannot be expected to spend huge amounts of money to modify a high-volume destruction or Federal facilities with Resource Conservation and Recovery decontamination technology, such as the Dynasafe SDC, Act (RCRA) permits or those undergoing RCRA closure are to treat small numbers of unusual items, such as munitions subject to hazardous waste cleanup requirements under both containing WP or L. Logically, NSCMP will make these RCRA and the Comprehensive Environmental Response, determinations as a matter of course and already has an Compensation and Liability Act (CERCLA). However, in option—the EDS—for destroying small volumes of prob- accordance with a policy memo issued by EPA in 1996 to lematic items. Also, as discussed earlier in this chapter, RCRA/CERCLA National Policy Managers, “in most situ- it can use decontamination solution for decontaminating ations, EPA RCRA and CERCLA site managers can defer problematic items. cleanup activities for all or part of a site from one program to another with the expectation that no further cleanup will Finding 5-1. Many items that are expected to be found at be required under the deferring program” (EPA, 1996c, RSA are anticipated to contain agent or to be agent-contam- p. 2). Hence, oversight authority can be deferred, partially or inated but too large to be fed to commonly used decontami- wholly, from one program to the other. Either the CERCLA nation technologies. federal facility agreement (FFA) can delegate authority to the 16Harley Heaton, Vice President-Research, UXB International, personal 17See correspondence to Nancy Schulte, NRC study director, March 16, 2012. Appendix D for the regulatory background.

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72 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL However, no agreement is yet in place.23 RSA is continu- state under RCRA, or state RCRA permit documentation can delegate authority to the EPA under CERCLA. ing cleanup of contamination including, but not limited to, CWM sites. CERCLA Actions at Redstone Arsenal RCRA Action at Redstone Arsenal Background The state of Alabama issued a RCRA permit with correc- CERCLA remedy investigation, selection, and implemen- tive action requirements in 2010 (EPA, 2010a). The RCRA tation related to RSA has been ongoing since 1983, when the permit lists over 300 SWMUs, with 17 of these units requir- state of Alabama, EPA, and Olin Corporation entered into ing interim actions under RCRA. Most of these 17 units are a consent decree requiring Olin to implement a DDT sedi- located on operational ranges at RSA. They consist of muni- ment cleanup.18 The facility was first placed on the National tions burial sites containing a mix of conventional and chemi- Priorities List in 1994.19 cal munitions and probably conventional pollutants as well. At least 10 CERCLA remedies have been or are being implemented at RSA, including the dismantling of the lew- Cleanup Decision isite manufacturing plant sites (RSA-122) and closing the arsenic waste ponds (RSA-056)20 (Shaw, 2009). No action to clean up buried CWM has been taken at these units under CERCLA. While most of the buried muni- tions are actually remnants of exploded munition bodies and Regulatory Oversight previously decontaminated chemical munitions that may At RSA an FFA has been drafted but not yet agreed upon, still contain detectable quantities of agent, some explosively primarily owing to a disagreement about the role of the Ala- configured munitions and unexploded bursters and fuzes can be expected.24,25 bama Department of Environmental Management (ADEM). According to GAO, “when the Army refuses to enter into In 2011, ADEM mandated interim action at the 17 units an Interagency Agreement and cleanup progress lags because that would consist of the immediate removal of the buried CWM.26 Once removed from their interment, the chemi- of statutory and other limitations, EPA cannot take steps— such as issuing and enforcing orders—to compel CERCLA cal munitions would need to be destroyed, as required by cleanup as it would for a private party” (GAO, 2010). Dis- the Chemical Weapons convention (CWC). Additional site putes must be resolved through interagency discussions and investigations are likely to be performed, and it appears that ultimately, if necessary, would be decided by the Office of a final RCRA Facility Investigation (RFI) under RCRA has Management and Budget. not yet been conducted at these SWMUs. Army guidance It is EPA’s goal for RSA to enter into an FFA with the requires a risk assessment for final cleanup decisions at all Army (see Chapter 3 and Appendix D) in order to implement locations, including on and off operational ranges to ensure the remaining cleanup of the site, including the remediation that the remedy is protective (U.S. Army, 2009b; also, see of the CWM. Oversight authority may be provided by EPA Chapter 3). or the state of Alabama, or both. It appears that the role of the The remedy selection process normally considers many state in this oversight is one of the bones of contention.21, 22 factors, including, but not limited to, the following: • Existing land use—for example, whether the material 1 8 Available at http://epa.gov/region4/superfund/sites/npl/alabama/ is located on an operational range; triatenval.html. Accessed February 22, 2012. • Potential future uses (U.S. Army, 2009b)—for 19 Available at http://cfpub.epa.gov/supercpad/cursites/csitinfo. example, whether the Army can control access to the cfm?id=0405545. Accessed February 22, 2012. 20Final Record of Decision RSA-122, Dismantled Lewisite Manufactur- ing Plant Sites; RSA-056, Closed Arsenic Waste Ponds; and RSA-139, Former Arsenic Trichloride Manufacturing Area Disposal Area, Operable ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Unit 6. Perspective,” presentation to the committee on November 2, 2011. 21SMITH/Associates, facilitators. Meeting minutes of the Alabama 23Stephen A. Cobb, ADEM, presentation to the committee on November Tier II Restoration Partnering Team meeting, November 8 and 9, 2011. 2, 2011. 24Terry de la Paz, Chief, Installation Restoration Branch, Environmental Available at http://www.altier2team.com/index.cfm/linkservid/A042A CA5-3B10-425D-BA0949A34DBF3747/showMeta/0/. Accessed February Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried 22, 2012. CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspec - 22Doug Maddox, EPA Federal Facilities Restoration and Reuse Office tive,” presentation to the committee on November 2, 2011. 25Harley Heaton, Vice President-Research, UXB International, personal (FFRRO), conference call with Todd Kimmel and William Walsh, commit- tee members, and Nancy Schulte, NRC study director, on November 21, communication to Nancy Schulte, NRC study director, March 30, 2012. 26Hazardous Waste Facility Permit AL7 210 020 742, issued by ADEM 2011; Sally Dalzell, EPA Enforcement, Harold Taylor, Region 4 Federal Facilities Branch Chief, and other EPA staff, conference call with Todd to U.S. Army Garrison-Redstone, September 30, 2010. Available at http:// Kimmell, Jim Pastorick, and William Walsh, committee members, and www.epa.gov/epawaste/hazard/tsd/permit/tsd-regs/sub-x/redstone-final. Nancy Schulte, NRC study director, on December 5, 2011; Stephen A. Cobb, pdf. Accessed April 18, 2012.

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73 REDSTONE ARSENAL: A CASE STUDY site and the potential for exposure for as long as the and handling facilities, and contaminated soils and debris. buried CWM remain on-site; and The management of remediation waste in such units and • Short-term and long-term risk. areas may help mitigate the risks and costs of treating materi- als removed from the trenches and of dealing with residuals The final remedy is selected from the protective alterna- from that treatment. tives. The parties appear to be proceeding in good faith, but whether the cleanup will proceed via a CERCLA FFA or COMMUNITY CONCERNS the RCRA corrective action or both regulatory authorities is unresolved as of the drafting of this report. The commit- Alabama’s Madison County and the town of Huntsville, tee notes that these delays could increase the overall cost of w hich surround the RSA, are experiencing significant economic development.27 While some of the area’s recent whatever actions are taken at RSA. construction activity can be attributed to RSA’s status as a BRAC “gaining facility,” much of the community’s eco- Maximizing Regulatory Flexibility nomic expansion began before that impact. Indeed, the area’s As discussed in Chapter 3, remediation policies provide economic growth has been identified as an important factor that the amount and kind of data and the choice between in ADEM’s preference for a removal and cleanup remedy rather than a leave-in-place remedy.28 interim action and remedial action are determined on a site- specific, case-by-case basis. The committee believes that, Contaminants have been identified in the vicinity of the consistent with such policies, the cleanup decision should RSA site, including solvents, metals, pesticides, CWM, and be based on the regulatory factors just described, including hazardous remnants from rocket fuel R&D and testing, such a scientific evaluation of the site-specific risks. What consti- as perchlorate. These contaminants have impacted ground- water, soil, sediments, and surface waters in the region29 and tutes adequate data will therefore vary. Adequate data may consist of historical information, and be based on geological are of concern for both public health and economic prosper- investigations, limited test-pitting, sampling, and experience ity. The proximity to the Tennessee River, which is used for with evaluations of the various remediation technologies. drinking water and recreation, increases the importance of selecting the best remediation approach.30 At Redstone, site-specific factors have led to the selection of remediation based on interim actions rather than on the Public engagement and education will be critical during conclusions of a feasibility study, and the Army and the state the protracted and complex cleanup of RSA. It will be impor- are developing work plans. Particularly at sites containing tant that the Army, the state of Alabama, the federal regula- buried CWM, the committee judges that extensive, new data tory agencies, and the community work closely together to may not be required to select the remedies. At sites where maximize the efficiency of the cleanup program and protect the health and environment of the community.31,32 the efficient use of data allows expeditious decisions on the remedies to be employed, available funding can be focused The committee judges that the long-term cleanup at the on risk reduction. Spring Valley FUDS in Washington, D.C., offers an impor- tant lesson to be learned for remediation efforts at RSA. The committee received briefings on the Spring Valley Corrective Action Management Units, Temporary Units, FUDS; from EPA Region 3; the Army Corps of Engineers, and Area of Contamination Concept Baltimore District; the District of Columbia Department of As indicated in Chapter 3 and in Appendix D, the man- agement of remediation waste is complex. While the present 27Huntsville Regional Economic Growth Initiative, 2007. Available discussion is intended to provide broad suggestions on the at www.huntsvillealabamausa.com/HREGI/hregi_report.pdf. Accessed regulatory issues that pertain to RSA, it is beyond the scope April16, 2012. 28Terry de la Paz, Chief, Installation Restoration Branch, Environmental of this report to delve into the intricacies of the regulatory Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried requirements for the wastes that may be generated there. CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspec - However, the concept of establishing corrective action man- tive,” presentation to the committee on November 2, 2011. agement units (CAMUs), temporary units (TUs), and areas 29U.S. EPA Superfund Record of Decision: U.S. Army/NASA Redstone of contamination, as discussed in Chapter 3 and in Appendix Arsenal. EPA/ROD/R04-04/662. 09/29/2004. Available at: http://www.epa. D, is very appealing for a site as large and complex as RSA. gov/superfund/sites/rods/fulltext/r0404662.pdf. Accessed April 16, 2012. 30Ibid. Assuming that acceptable locations can be identified for 31Stephen A. Cobb, Chief, Government Hazardous Waste Branch, Land them, the establishment of CAMUs, TUs, and areas of con- Division, ADEM, “Remediation of Buried CWM in Alabama: The State tamination could be a cost-effective approach for RSA. For Regulator’s Perspective,” presentation to the committee on November 2, example, remediation waste placed in a disposal CAMU may 2011. 32Terry de la Paz, Chief, Installation Restoration Branch, Environmental include large amounts of contaminated and noncontaminated Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried empty munition bodies, empty agent containers, debris such CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspec - as equipment from the demolition of agent manufacturing tive,” presentation to the committee on November 2, 2011.

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74 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL the Environment; and a representative of the Spring Valley monetary limitations and that while the path forward was not Restoration Advisory Board established to facilitate public always agreed on by all parties, all parties at least understood involvement. These briefings spoke of conflict in the early why decisions were made the way they were. One of the most days of the cleanup effort but also of the collaborative part- important lessons learned by all parties was the concept of nering that eventually emerged, with all parties having had partnering, education of the public, the involvement of all a voice in determining cleanup objectives, processes, and stakeholders, and public participation in bodies like restora- procedures. While a partnering environment was established, tion advisory boards and community outreach groups. all acknowledged that there were technical, practical, and