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Remediation of Buried Chemical Warfare Materiel (2012)

Chapter: 5 Redstone Arsenal: A Case Study

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Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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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.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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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 committee on November 2, 2011.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
×

TABLE 5-1 Partial List of Chemical Items Produced at RSA Ordnance Plant During the Second World War


Agent Item Quantity

Mustard (H/HS) 105-mm M60 rounds 1,770,000
155-mm M105, M104, M110 rounds 31,000
4.2-in. mortar rounds 54,000
100-lb. M47 and M70 bombs 560,000
Ton containers, 30- and 55-gal drums Unknown
Lewisite Ton containers Unknown
Phosgene 500-lb bombs (M78) and 1,000-lb bombs (M79) Unknown
White phosphorus 4.2-in. shells, 75- and155-mm shells 4,194,000
100-lb bomb (M46, M47) 162,000
M15 hand grenades 951,000

SOURCE: Terry de la Paz, Chief, Installation Restoration Branch, Environmental Management Division, RSA, Alabama, “Remediation of RCWM from Burial Sites,” presentation to the committee on November 2, 2011.

Between 1945 and 1950, major disposal actions were taken to destroy chemical munitions and agents, with most of the toxic chemical agents being processed by 1949. The agent production and ordnance plants at RSA were decontaminated and demolished, and the post-Second-World-War overseas ordnance, reject munitions produced at RSA, and “good” munitions produced there were disposed of, usually by burning in trenches.

Although mustard munitions in pits were burned twice with subsequent refilling of the pits, large quantities of contaminated and potentially contaminated materiel remain at 17 sites, where today there is still a possibility of encountering CWM. Based on excavation of a similar pit at Pine Bluff Arsenal Site 12 in 1987, about 10 percent of the original mustard-filled munitions may have survived the burning and might still need to be destroyed.3 Other munitions may have been partially destroyed, with residual quantities of toxic chemical agent remaining in the munitions, on metal 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

•  Rubberized mustard residue from thickened German mustard in burned 250-kg bombs: 1,660 bomb bodies with probable residue are estimated to remain;

•  H/HS in burned 250-kg and 500-kg bombs: 40-50 lb of heel may remain in each of an estimated 9,000 bomb bodies;

•  Possible concrete-encased 500-kg H/HS-filled bombs;

•  Large quantities of agent-contaminated metal such as burned-out bomb bodies, 55-gal drums, British land mines, and plant production equipment;

•  Over 10,000 CAIS bottles, both intact and damaged, containing surviving H/HS, and

•  Small quantities of CG-filled items.

The total quantities of remaining items cannot be known until source removal action is taken and disposal begins. However, based on archival research and interviews with former employees, there is a potential for significant quantities of munitions, both conventional and chemical, and chemical warfare-related items (e.g., drums and production equipment) to be found in various states within burial sites at RSA.5 These quantities have been assigned to the various SWMUs at RSA and each lot has been characterized by munition or container type (e.g., bomb, canister, mortar) and by agent content (e.g., H, GA, CG). The quantities that could be encountered are divided into three categories, which are defined in the footnotes, and are estimated as follows:

Intact items: 85,000-92,0006

Empty contaminated items: 844,000-855,0007

Empty noncontaminated items: 1,971,000-1,975,008

German Traktor rockets being prepared for disposal in a pit are shown in Figure 5-2.

German Traktor rockets being prepared for disposal in a pit are shown in Figure 5-2.

Processing of Unusual Items at Redstone Arsenal

The burial pits at RSA are expected to contain many items that NSCMP may not have encountered previously. For example, the “empty contaminated” category in the inventory of buried items includes these:9

•  Production plant equipment, chemical with HS, L, and WP: 91,400 items,

•  German Traktor rockets with GA and HN-3: 54 items,

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3William R. Brankowitz, Senior Chemical Engineer, Science Applications International Corporation, “Non-Stockpile Chemical Materiel Project Redstone Arsenal (RSA) Interim Historical Report,” presentation to the committee on January 18, 2012.

4Ibid.

5Ibid.

6An intact item is physically intact enough to hold most or all of the original agent content of the munition. These items will require agent destruction by a suitable technology (e.g., an EDS or an EDT).

7An empty contaminated item is a munition that has been opened and partially burned or decontaminated but can still provide a detectable air monitoring reading. These items will require further treatment to destroy any remaining quantities of chemical agent, smoke, or incendiary fill.

8An empty noncontaminated item is a munition that has been physically opened and burned or decontaminated to a point where no chemical agent, smoke, or incendiary chemical can be detected by air monitoring equipment. 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 commercial disposal facility.

9William R. Brankowitz, Senior Chemical Engineer, Science Applications International Corporation, “Non-Stockpile Chemical Materiel Project Redstone Arsenal (RSA) Interim Historical Report,” presentation to the committee on January 18, 2012.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
×

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FIGURE 5-2 German Traktor rocket t pit at Huntsville (now Redstone) Arsenal, Alabama (photo from 1948). SOURCE: William R. Brankowitz, Senior Chemical Engineer, Science Applications International Corporation, “The Redstone Arsenal Archival Review,” presentation to the committee on January 18, 2012.

•  55-gal drums with CNS, CNB, HS, HT: 21,046 items,

•  Bombs, chemical, 100-lb M47, HS fill: 11,032 items,

•  Bombs, chemical, 115-lb, M70, HS fill: 33,514 items,

•  Bombs, chemical, German, 250 kg, GA fill: 750 items, and

•  Bombs, chemical, German, 500 kg, GA fill: 692 items,

where HS is 60 percent sulfur mustard and 40 percent bis[2-(2-chloroethylthio)ethyl]ether, CNS is phenyacyl chloride (CN) tear gas mixed with chloropicrin and chloroform, and CNB is CN tear gas mixed with carbon tetrachloride and benzene.

TECHNICAL AND OPERATIONAL ISSUES

Remediation at RSA is complicated by a number of technical and operational factors. The arsenal contains a large number and wide variety of munition types (see preceding section) in different stages of degradation and was used for many years as a disposal site for toxic chemicals.10 Additional processing capacity may be needed to safely and efficiently process such quantities of munitions and 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 that are then analyzed by the Materiel Assessment Review Board (MARB). While PINS is a valuable tool, it has not been completely reliable for identifying chemical fills or 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 contaminated items exist at RSA.12 While many of these may be further decontaminated using existing destruction technology 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 explosive destruction technology to access the agent cavity. This would be particularly true for decontaminating the many pieces of production plant equipment that are expected to be found in several of the pits at RSA.

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 appropriate. The suitability of these cleanup options at RSA will depend on the applicable laws, regulations, and U.S. Army policies as well as the development of a constructive relationship between the various stakeholders (including the Army, the state of Alabama, EPA, tenants, and local community groups). A flexible approach to remediation and risk management at RSA has the potential to expedite cleanup while reducing its overall cost.

The strengths and limitations of the current supporting technologies for use in the cleanup of CWM sites are discussed in Chapter 4. The legal and regulatory issues associated with the various options are presented in Chapter 3, with background information presented in Appendix D.

The 17 interim-action sites at RSA with known or suspected CWM fall into two categories when it comes to restoration funding, which complicates and potentially delays the overall remediation process. Of these 17 sites, 5 are eligible for the Defense Environmental Restoration Program (DERP), while the remaining 12 are classified as operational ranges and must seek funding from the Compliance Cleanup Program of the Army’s Operations and Maintenance (OMA) program. Since OMA funding is limited (less than $20 million is available each year), these sites may require many

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10Ibid.

11Dan G. Noble, Project Manager, Spring Valley Baltimore District, U.S. Army Corps of Engineers, “Project Management of Spring Valley: A Corps of Engineers Perspective,” presentation to the committee on November 1, 2012.

12William R. Brankowitz, Senior Chemical Engineer, Science Applications International Corporation, “Non-Stockpile Chemical Materiel Project Redstone Arsenal (RSA) Interim Historical Report,” presentation to the committee on January 18, 2012.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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years for complete remediation.13,14 Overall, it has been estimated that it could take up to 15 years and between $1 billion and $3 billion to complete restoration.15 The committee believes that the current management approach and funding constraints for operational ranges greatly complicate the task of cleanup there. For more details on operational issues that may impact the effectiveness of cleanup operations at RSA and recommendations for operational improvements, see Chapter 6.

RSA is home to more than 130 landowners and tenants, including the Army, NASA, the Tennessee Valley Authority, and the Wheeler National Wildlife Refuge; in addition, an ongoing cleanup program for dichlorodiphenyltrichloroeth-ane (DDT) is being conducted by Olin Corporation. Also, given its location in the Tennessee Valley, on a partial flood plain having a complex hydrogeology, it should be expected that the cleanup program will draw a great deal of scrutiny from regulators and community groups concerned about the protection of the region’s environment.

Coordinating access to all of these facilities and land areas and gaining the cooperation of the tenants will be a significant challenge for NSCMP. The committee believes that community and general stakeholder engagement will be critical for a successful remediation program at RSA, and it points to the important lesson learned at the formerly used defense site (FUDS) of Spring Valley in Washington, D.C. Notwithstanding the difficulties experienced in the early days of the cleanup effort, a collaborative partnership eventually developed that simplified decision making and made it more acceptable to all parties (see the later section “Community Concerns” for more information).

MATCH OF TECHNOLOGY NEEDS WITH NSCMP CAPABILITIES

As indicated earlier in this chapter, it is expected that 85,000-92,000 intact chemical munitions and 844,000-855,000 empty but contaminated items will be encountered. If a remove-and-treat approach is selected, the key technological responsibilities for NSCMP will be to (1) assess the intact munitions, (2) destroy the intact munitions, and (3) decontaminate (remove agent and energetics from) the empty contaminated items.

Assessment of Intact Munitions

The PINS/digital radiography and computed tomography (DRCT)/MARB approach has never been used on a project involving the large number of munitions expected to be found at RSA, where tens to hundreds of thousands of items may still contain detectable quantities of agent and energetics. The current approach would be overwhelmed, and changes to it will be needed to prepare for this massive effort involving diverse agents and energetics. See Chapter 6 for findings and recommendations on this topic.

Destruction of RCWM-Containing Energetics

Technologies are available to NSCMP for the destruction of the intact munitions. The Dynasafe SDC is suited for this purpose because of its high throughput rate and because it can produce scrap metal that is suitable for release for unrestricted use (formerly termed “5X”). The CH2M HILL TDC or the DAVINCH could also be used, but they have slower throughput rates and produce scrap metal that is not suitable for release for unrestricted use. Again, the items expected to be found at RSA are anticipated to contain a wide variety of chemical agents and chemicals, including H, HD, HT, HS, L, WP, CNS, CNB, HN-3, CG, and GA (see Finding 5-2 and Recommendation 5-1).

Some of the munitions, including any intact 500- and 1,000-lb bombs, might be too large to be destroyed in the available EDTs. However, the large item transportable access and neutralization system (LITANS) is an NSCMP-developed technology that could be used for this purpose (U.S. Army, 2011e). LITANS throughput may be too low, however, if a great many items are found.

Processing of Nonenergetic RCWM

Between 844,000 and 855,000 items that are empty but contaminated with agent and energetics, including burned and opened munition bodies, are expected to be encountered. These items will require treatment to the ≤1 VSL (formerly 3X) level or suitable for release for unrestricted use (formerly 5X) level. Processing them through a Dynasafe SDC appears to be a good approach that produces scrap metal suitable for 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 technology selected must be able to destroy the wide range of expected agents while also meeting the applicable waste management and emission requirements. A study to evaluate and rank these technologies is needed and should consider the option of containment in lieu of treatment.

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13Stephen A. Cobb, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011.

14James D. Daniel and Tim Rodeffer, “USACE Operations of Recovered Chemical Warfare Material from Burial Sites: Cleanup and Munitions Response Division,” presentation to the committee on December 12, 2012.

15Stephen A. Cobb, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
×

Dynasafe has said that its SDC 2000 system has been used in Germany for decontaminating large quantities of agent-contaminated metal, including opened contaminated munitions.16 Some of the munitions also contained energetics, agent-contaminated in some cases. To decontaminate these and similar materials in the SDC 1200, no changes would need to be made to the hardware; up to 330 lb of metal 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. Dynasafe expects that optimal use of the SDC 1200 at RSA or a similar site would involve mixing contaminated scrap with explosively configured recovered rounds for each feed cycle.

Finally, very large items, such as the bodies of the 500- and 1,000-lb bombs, sections of the agent production facilities, and 55-gal drums, may require decontamination. These items may be too large to be fed to existing treatment technologies. Means of treating these large items should be to investigated; such a study should consider a containment option in lieu of treatment.

The items expected to be found at RSA are anticipated to contain or be contaminated with a variety of chemical agents and chemicals, including H, HD, HT, HS, L, WP, CNS, CNB, HN-3, CG, and GA. It is not clear that the available explosive destruction technologies (EDTs) would be able to effectively treat all these chemical agents and chemicals without changes to the operating procedures or the equipment. For example, lewisite (L) contains 37 weight percent arsenic, and the air pollution control system would have to be able to remove large amounts of arsenic oxides from the detonation chamber off-gases (NRC, 2009a). Similarly, the entire chemical charge of a munition containing WP would be converted to P2O5, which means that the off-gas treatment system would need to remove and neutralize vastly larger quantities of P2O5 than when the munition contains any other chemical agent or chemical. These technologies include those used for destroying intact munitions and those used for decontaminating agent-contaminated items.

However, the NSCMP cannot be expected to spend huge amounts of money to modify a high-volume destruction or decontamination technology, such as the Dynasafe SDC, to treat small numbers of unusual items, such as munitions containing WP or L. Logically, NSCMP will make these determinations as a matter of course and already has an option—the EDS—for destroying small volumes of problematic items. Also, as discussed earlier in this chapter, it can use decontamination solution for decontaminating problematic items.

Finding 5-1. Many items that are expected to be found at RSA are anticipated to contain agent or to be agent-contaminated but too large to be fed to commonly used decontamination technologies.

Finding 5-2. The items expected to be found at RSA are anticipated to contain or be contaminated with a wide variety of chemical agents and chemicals. The technologies selected to destroy or decontaminate these items must be able to destroy the chemical agents and chemicals while producing air emissions within acceptable limits.

Recommendation 5-1. The Non-Stockpile Chemical Materiel Project should conduct a study of the ability of currently available or other candidate technologies to destroy or contain the wide range of unusual items, including large items or munitions containing chemical agents and chemicals such as H, HD, HT, HS, L, WP, CNS, CNB, HN-3, CG, and GA, while meeting waste management requirements and producing air emissions within acceptable limits. The technologies include those used for destroying intact munitions and those used for decontaminating agent-contaminated items.

Finding 5-3. The overall cleanup at RSA, which will involve conventional munitions, chemical munitions, and conventional pollutant contamination both on operational ranges and on other areas of the installation, will make it one of the largest, most complex, most long-lasting, and costliest responses ever mounted for CWM munitions in the United States.

Recommendation 5-2. The Army should develop organizational, operational, and funding plans for a complex, long-term, costly cleanup project at Redstone Arsenal, with the plans based on the programmatic recommendations discussed in Chapter 7.

REGULATORY ISSUES

In addition to the 17 sites discussed above, the RSA has hundreds of old disposal locations containing chemical and conventional munitions; some locations are also contaminated with industrial chemicals, including pesticides.17 Federal facilities with Resource Conservation and Recovery Act (RCRA) permits or those undergoing RCRA closure are subject to hazardous waste cleanup requirements under both RCRA and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). However, in accordance with a policy memo issued by EPA in 1996 to RCRA/CERCLA National Policy Managers, “in most situations, EPA RCRA and CERCLA site managers can defer cleanup activities for all or part of a site from one program to another with the expectation that no further cleanup will be required under the deferring program” (EPA, 1996c, p. 2). Hence, oversight authority can be deferred, partially or wholly, from one program to the other. Either the CERCLA federal facility agreement (FFA) can delegate authority to the

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16Harley Heaton, Vice President-Research, UXB International, personal correspondence to Nancy Schulte, NRC study director, March 16, 2012.

17See Appendix D for the regulatory background.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
×

state under RCRA, or state RCRA permit documentation can delegate authority to the EPA under CERCLA.

CERCLA Actions at Redstone Arsenal

Background

CERCLA remedy investigation, selection, and implementation related to RSA has been ongoing since 1983, when the state of Alabama, EPA, and Olin Corporation entered into a consent decree requiring Olin to implement a DDT sediment cleanup.18 The facility was first placed on the National Priorities List in 1994.19

At least 10 CERCLA remedies have been or are being implemented at RSA, including the dismantling of the lewisite manufacturing plant sites (RSA-122) and closing the arsenic waste ponds (RSA-056)20 (Shaw, 2009).

Regulatory Oversight

At RSA an FFA has been drafted but not yet agreed upon, primarily owing to a disagreement about the role of the Alabama Department of Environmental Management (ADEM).

According to GAO, “when the Army refuses to enter into an Interagency Agreement and cleanup progress lags because of statutory and other limitations, EPA cannot take steps— such as issuing and enforcing orders—to compel CERCLA cleanup as it would for a private party” (GAO, 2010). Disputes must be resolved through interagency discussions and ultimately, if necessary, would be decided by the Office of Management and Budget.

It is EPA’s goal for RSA to enter into an FFA with the Army (see Chapter 3 and Appendix D) in order to implement the remaining cleanup of the site, including the remediation of the CWM. Oversight authority may be provided by EPA or the state of Alabama, or both. It appears that the role of the state in this oversight is one of the bones of contention.21,22 However, no agreement is yet in place.23 RSA is continuing cleanup of contamination including, but not limited to, CWM sites.

RCRA Action at Redstone Arsenal

The state of Alabama issued a RCRA permit with corrective action requirements in 2010 (EPA, 2010a). The RCRA permit lists over 300 SWMUs, with 17 of these units requiring interim actions under RCRA. Most of these 17 units are located on operational ranges at RSA. They consist of munitions burial sites containing a mix of conventional and chemical munitions and probably conventional pollutants as well.

Cleanup Decision

No action to clean up buried CWM has been taken at these units under CERCLA. While most of the buried munitions are actually remnants of exploded munition bodies and previously decontaminated chemical munitions that may still contain detectable quantities of agent, some explosively configured munitions and unexploded bursters and fuzes can be expected.24,25

In 2011, ADEM mandated interim action at the 17 units that would consist of the immediate removal of the buried CWM.26 Once removed from their interment, the chemical munitions would need to be destroyed, as required by the Chemical Weapons convention (CWC). Additional site investigations are likely to be performed, and it appears that a final RCRA Facility Investigation (RFI) under RCRA has not yet been conducted at these SWMUs. Army guidance requires a risk assessment for final cleanup decisions at all locations, including on and off operational ranges to ensure that the remedy is protective (U.S. Army, 2009b; also, see Chapter 3).

The remedy selection process normally considers many factors, including, but not limited to, the following:

•  Existing land use—for example, whether the material is located on an operational range;

•  Potential future uses (U.S. Army, 2009b)—for example, whether the Army can control access to the

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18Available at http://epa.gov/region4/superfund/sites/npl/alabama/triatenval.html. Accessed February 22, 2012.

19Available at http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0405545. Accessed February 22, 2012.

20Final Record of Decision RSA-122, Dismantled Lewisite Manufacturing Plant Sites; RSA-056, Closed Arsenic Waste Ponds; and RSA-139, Former Arsenic Trichloride Manufacturing Area Disposal Area, Operable Unit 6.

21SMITH/Associates, facilitators. Meeting minutes of the Alabama Tier II Restoration Partnering Team meeting, November 8 and 9, 2011. Available at http://www.altier2team.com/index.cfm/linkservid/A042ACA5-3B10-425D-BA0949A34DBF3747/showMeta/0/. Accessed February 22, 2012.

22Doug Maddox, EPA Federal Facilities Restoration and Reuse Office (FFRRO), conference call with Todd Kimmel and William Walsh, committee members, and Nancy Schulte, NRC study director, on November 21, 2011; Sally Dalzell, EPA Enforcement, Harold Taylor, Region 4 Federal Facilities Branch Chief, and other EPA staff, conference call with Todd Kimmell, Jim Pastorick, and William Walsh, committee members, and Nancy Schulte, NRC study director, on December 5, 2011; Stephen A. Cobb, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011.

23Stephen A. Cobb, ADEM, presentation to the committee on November 2, 2011.

24Terry 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.

25Harley Heaton, Vice President-Research, UXB International, personal communication to Nancy Schulte, NRC study director, March 30, 2012.

26Hazardous Waste Facility Permit AL7 210 020 742, issued by ADEM to U.S. Army Garrison-Redstone, September 30, 2010. Available at http://www.epa.gov/epawaste/hazard/tsd/permit/tsd-regs/sub-x/redstone-final.pdf. Accessed April 18, 2012.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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    site and the potential for exposure for as long as the buried CWM remain on-site; and

•  Short-term and long-term risk.

The final remedy is selected from the protective alternatives. The parties appear to be proceeding in good faith, but whether the cleanup will proceed via a CERCLA FFA or the RCRA corrective action or both regulatory authorities is unresolved as of the drafting of this report. The committee notes that these delays could increase the overall cost of whatever actions are taken at RSA.

Maximizing Regulatory Flexibility

As discussed in Chapter 3, remediation policies provide that the amount and kind of data and the choice between interim action and remedial action are determined on a site-specific, case-by-case basis. The committee believes that, consistent with such policies, the cleanup decision should be based on the regulatory factors just described, including a scientific evaluation of the site-specific risks. What constitutes adequate data will therefore vary. Adequate data may consist of historical information, and be based on geological investigations, limited test-pitting, sampling, and experience with evaluations of the various remediation technologies. At Redstone, site-specific factors have led to the selection of remediation based on interim actions rather than on the conclusions of a feasibility study, and the Army and the state are developing work plans. Particularly at sites containing buried CWM, the committee judges that extensive, new data may not be required to select the remedies. At sites where the efficient use of data allows expeditious decisions on the remedies to be employed, available funding can be focused on risk reduction.

Corrective Action Management Units, Temporary Units, and Area of Contamination Concept

As indicated in Chapter 3 and in Appendix D, the management of remediation waste is complex. While the present discussion is intended to provide broad suggestions on the regulatory issues that pertain to RSA, it is beyond the scope of this report to delve into the intricacies of the regulatory requirements for the wastes that may be generated there. However, the concept of establishing corrective action management units (CAMUs), temporary units (TUs), and areas of contamination, as discussed in Chapter 3 and in Appendix D, is very appealing for a site as large and complex as RSA. Assuming that acceptable locations can be identified for them, the establishment of CAMUs, TUs, and areas of contamination could be a cost-effective approach for RSA. For example, remediation waste placed in a disposal CAMU may include large amounts of contaminated and noncontaminated empty munition bodies, empty agent containers, debris such as equipment from the demolition of agent manufacturing and handling facilities, and contaminated soils and debris. The management of remediation waste in such units and areas may help mitigate the risks and costs of treating materials removed from the trenches and of dealing with residuals from that treatment.

COMMUNITY CONCERNS

Alabama’s Madison County and the town of Huntsville, which surround the RSA, are experiencing significant economic development.27 While some of the area’s recent construction activity can be attributed to RSA’s status as a BRAC “gaining facility,” much of the community’s economic expansion began before that impact. Indeed, the area’s economic growth has been identified as an important factor in ADEM’s preference for a removal and cleanup remedy rather than a leave-in-place remedy.28

Contaminants have been identified in the vicinity of the RSA site, including solvents, metals, pesticides, CWM, and hazardous remnants from rocket fuel R&D and testing, such as perchlorate. These contaminants have impacted ground-water, soil, sediments, and surface waters in the region29 and are of concern for both public health and economic prosperity. The proximity to the Tennessee River, which is used for drinking water and recreation, increases the importance of selecting the best remediation approach.30

Public engagement and education will be critical during the protracted and complex cleanup of RSA. It will be important that the Army, the state of Alabama, the federal regulatory agencies, and the community work closely together to maximize the efficiency of the cleanup program and protect the health and environment of the community.31,32

The committee judges that the long-term cleanup at the Spring Valley FUDS in Washington, D.C., offers an important lesson to be learned for remediation efforts at RSA. The committee received briefings on the Spring Valley FUDS; from EPA Region 3; the Army Corps of Engineers, Baltimore District; the District of Columbia Department of

image

27Huntsville Regional Economic Growth Initiative, 2007. Available at www.huntsvillealabamausa.com/HREGI/hregi_report.pdf. Accessed April16, 2012.

28Terry 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.

29U.S. EPA Superfund Record of Decision: U.S. Army/NASA Redstone Arsenal. EPA/ROD/R04-04/662. 09/29/2004. Available at: http://www.epa.gov/superfund/sites/rods/fulltext/r0404662.pdf. Accessed April 16, 2012.

30Ibid.

31Stephen 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.

32Terry 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.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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the Environment; and a representative of the Spring Valley Restoration Advisory Board established to facilitate public involvement. These briefings spoke of conflict in the early days of the cleanup effort but also of the collaborative partnering that eventually emerged, with all parties having had a voice in determining cleanup objectives, processes, and procedures. While a partnering environment was established, all acknowledged that there were technical, practical, and monetary limitations and that while the path forward was not always agreed on by all parties, all parties at least understood why decisions were made the way they were. One of the most important lessons learned by all parties was the concept of partnering, education of the public, the involvement of all stakeholders, and public participation in bodies like restoration advisory boards and community outreach groups.

Suggested Citation:"5 Redstone Arsenal: A Case Study." National Research Council. 2012. Remediation of Buried Chemical Warfare Materiel. Washington, DC: The National Academies Press. doi: 10.17226/13419.
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As the result of disposal practices from the early to mid-twentieth century, approximately 250 sites in 40 states, the District of Columbia, and 3 territories are known or suspected to have buried chemical warfare materiel (CWM). Much of this CWM is likely to occur in the form of small finds that necessitate the continuation of the Army's capability to transport treatment systems to disposal locations for destruction. Of greatest concern for the future are sites in residential areas and large sites on legacy military installations.

The Army mission regarding the remediation of recovered chemical warfare materiel (RCWM) is turning into a program much larger than the existing munition and hazardous substance cleanup programs. The Army asked the Nation Research Council (NRC) to examine this evolving mission in part because this change is significant and becoming even more prominent as the stockpile destruction is nearing completion. One focus in this report is the current and future status of the Non-Stockpile Chemical Material Project (NSCMP), which now plays a central role in the remediation of recovered chemical warfare materiel and which reports to the Chemical Materials Agency.

Remediation of Buried Chemical Warfare Materiel also reviews current supporting technologies for cleanup of CWM sites and surveys organizations involved with remediation of suspected CWM disposal sites to determine current practices and coordination. In this report, potential deficiencies in operational areas based on the review of current supporting technologies for cleanup of CWM sites and develop options for targeted research and development efforts to mitigate potential problem areas are identified.

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