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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.
OCR for page 74
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
