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6 The Path Forward: Recommendations for Targeted Research and Development The organizational and technical approach taken to date spectroscopy, the explosive destruction system (EDS), and by the Army in recovering, assessing, processing, trans- explosive destruction technologies (EDTs) may not be able porting, storing, and destroying recovered chemical war- to keep up with the requirements at a large burial site if tens fare materiel (RCWM) has been effective, although some or hundreds of items are recovered each day. problem areas have been identified by those involved in the Existing administrative procedures, organizational process—for example, at Camp Sibert, in Alabama, deter- responsibilities, lines of reporting, and sources of funding mination of RCWM fill required a “significant amount of may also not be sufficient to cope with the magnitude of this equipment” and was a “lengthy process,” destruction opera- problem. One estimate of the scope of the RCWM effort at tions were “costly,” and waste management and disposal RSA alone was that initial cost projections were in the $1 were “difficult.”1 billion to $3 billion range and that it was expected to take up to 15 years to complete the remediation.5 For sites at which large numbers of items—in the tens to hundreds of thousands—must be processed and where the Similarly, existing destruction hardware may not have destruction of more than a few each day may be required, the capacity to destroy the required number of items. The existing procedures and technologies may be inadequate. highest throughput rates per 10-hr day reported to an earlier An example is Redstone Arsenal (RSA), where there are committee for a representative small and commonly recov- 17 sites requiring interim measures and source removal2 in ered item, a 4.2-in. mortar round, were 40 per day in a TDC over 20,000 linear feet of burial trenches3 and where up to 1 TC-60, 36 per day in a detonation of ammunition in a vacuum million potentially contaminated items could be found,4 as integrated chamber (DAVINCH) DV-65, and 120 per day in a described in Chapter 5. Dynasafe static detonation chamber (SDC) SDC 2000 (NRC, Similar quantities of buried CWM may exist at Deseret 2006). More recently, the SDC 1200 in Anniston, Alabama, Chemical Depot, in Utah, and elsewhere. Existing analytical achieved a processing rate of 100 4.2-in. mortar rounds per 10-hr day.6 Throughput, however, may not be an issue since and assessment methods and destruction technologies such as digital radiography and computed tomography (DRCT), multiple EDT or EDS units can be used if need be. portable isotopic neutron spectroscopy (PINS), Raman Of some significance is whether the CWM to be recov- ered are buried or are above ground in, for example, open 1Karl trenches. If the former, they must be located, unearthed, and E. Blankenship, Formerly Used Defense Sites (FUDS) Project Manager, Mobile District U.S. Army Corps of Engineers, “Remediation of their content assessed, preferably while still in the ground Contaminated Soil at Camp Sibert, Alabama: The Installation Manager’s but otherwise following placement in a container, monitor- Perspective,” presentation to the committee on November 3, 2011. ing, and storage. These items are expected to be in a more 2Terry de la Paz, Chief, Installation Restoration Branch, Environmental deteriorated condition than those that have been above Management Division, RSA, Alabama, “Remediation of Buried CWM at ground in open disposal pits or trenches. Potentially agent- Redstone Arsenal, Alabama: The Installation Manager’s Perspective,” U.S. Army, Presentation to the committee on November 2, 2011. contaminated soil must also be assessed and disposed of. 3Steven A. Cobb, Chief, Governmental Hazardous Waste Branch, Land If the CWM items are above ground, as is the case with Division, Department of Environmental Management (ADEM), “Reme- open disposal pits, processing can proceed more rapidly diation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011. 4William R. Brankowitz, Senior Chemical Engineer, Science Applica - 5Ibid. tions International Corporation, “Non-Stockpile Chemical Materiel Project 6Harley Redstone Arsenal (RSA) Interim Historical Report,” presentation to the Heaton, Vice President-Research, UXB International, to Nancy committee on January 18, 2012. Schulte, NRC study director, personal correspondence on March 16, 2012. 75

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76 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL TECHNOLOGIES WITH NO TARGETED R&D since the subsurface location, excavation, and soil treatment RECOMMENDATIONS steps are not needed. For sealed munitions, it is expected that DRCT (X-ray) Finding 6-1. The committee finds that the following tech- and PINS will be used to determine the quantity of fill nologies are sufficiently developed and identifies no research and the chemical content of the munition. For munitions and development needs for them: that have been previously opened and burned or otherwise treated, as well as for potentially contaminated scrap metal, • Other organizations have large R&D programs under it is expected that agent monitors will be used to determine way in geophysical detection. The best policy for whether further treatment is required. Finally, it is expected NSCMP is to simply track developments in these that recovered items for which no agent is detected will be programs. disposed of in accordance with environmental regulations. • Personal protective equipment. It is not possible know in advance the processing needs for • Conventional excavation equipment. every RCWM at every site. Therefore, the committee cannot • CWM storage (interim holding facilities, igloos, recommend site-specific treatment options. It can only iden- bunkers). tify and recommend general needs for modifications to the • Vapor containment facilities and filtering techniques. supporting technologies listed in the second bullet item of the • Single Chemical agent identification set Access and statement of task. The committee hopes that these modifica- Neutralization System (SCANS). tions will enable the supporting technologies to better meet • Digital radiography and computed tomography. the Army’s needs at RCWM sites, based on the very limited • The CH2M HILL transportable detonation chamber information about the quantities and characteristics of the (TDC). CWM at these sites. • The DAVINCH. Also, it may well be that modifications to existing tech- • The explosive destruction system (EDS). nologies—for example, a more accurate PINS, a faster EDS, • Secondary waste storage and disposal. or more easily transported EDTs—may be necessary but not sufficient to meet the Army’s needs, especially at the large TECHNOLOGIES WITH TARGETED R&D NEEDS burial sites, where hundreds of thousands of potentially contaminated items will have to be assessed and treated and Robotic Excavation Equipment where existing procedures, while effective, may prove to be too slow or cumbersome for the quantities involved. It is As discussed in the section on robotic excavation equip- possible that at these sites, it will be necessary to design and ment in Chapter 4, robotic technology has continued to grow construct facilities where recovered items, whether found in versatility and reliability. To reduce risk to workers, its in burial pits or in the open, can be efficiently assessed for use in the remediation of buried chemical materiel should agent content and remaining contamination and treated be investigated and developed. accordingly. The existing approach has been effective in disposing of Finding 6-2. The committee believes that existing robotic small quantities of RCWM, and processing rates and urgency systems are capable of accessing and removing buried CWM, in identification of fill have not been an issue. For example, resulting in improved safety. at the Pine Bluff Explosive Destruction System (PBEDS) facility in Arkansas, between June 2006 and April 2010, Recommendation 6-1. The Army should demonstrate that two EDS units destroyed 1,225 4.2-in. mortar rounds and robotic systems can be reliably utilized to access and remove Second World War–era German Traktor rockets (an average buried chemical warfare materiel, and, where applicable, it processing rate of nearly 27 munitions per month). For those should use them. sites containing tens to hundreds of thousands of potentially chemically contaminated items, processing at this rate may CWM Packaging and Transportation not be sufficient. For these sites, new technology capabilities may well be required. Technology research that could lead As described in Chapter 4, the Non-Stockpile Chemical to the development of such capabilities is described below, Materiel Project (NSCMP) is developing a universal muni- and technology-related findings and recommendations are tions storage container. It is fabricated from high-density provided. polyethylene, and its use will allow the destruction of over- packed munitions in the EDS without removing them from the overpack.

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77 THE PATH FORWARD: RECOMMENDATIONS FOR TARGETED RESEARCH AND DEVELOPMENT Finding 6-3. Existing overpacks for the EDS may require lengthy, and the Camp Sibert project manager said that the results “are often qualified to the extent that regulators cannot removal and additional handling of the contained munition be satisfied that an item is, or is not, RCWM, thus limiting prior to destruction. the disposal options.”12 The manager also commented that Recommendation 6-2. The Non-Stockpile Chemical War- a better tool is needed to determine whether a munition is CWM or not. fare Materiel Project should complete the development and The NSCMP has R&D projects under way to address testing of a universal munitions storage container. some of these PINS-related issues. These R&D efforts are aimed at generating more definitive analytical results and Assessment of Recovered Munitions lowering the detection limit, plus replacing the radioactive neutron source with a neutron generator to facilitate trans- Before RCWM can be destroyed, an assessment must portation of the PINS equipment. be carried out on each item to determine the nature of the contained agent and energetics. The noninvasive analytical Finding 6-4. Improvements are needed in the portable isoto- method used for this purpose is PINS, which is described in pic neutron spectroscopy (PINS) data processing to provide Chapter 4. While PINS is an essential tool in the assessment more definitive information for the identification of chemical of recovered munitions, it is not totally reliable. For example, fills in recovered munitions. during the destruction of 71 recovered munitions at Schofield Barracks in Hawaii in 2008, a 75-mm projectile was mistak- Recommendation 6-3. Research and development should enly identified as containing phosgene but actually contained continue on the processing of data from portable isotopic chloropicrin (NRC, 2009a). Another example is at the Spring neutron spectroscopy to provide more definitive information Valley remediation effort, where, sometime in 2002 or 2003, for the identification of chemical fills in recovered munitions. three munitions were incorrectly identified as containing diphenylcyanoarsine when they actually contained arsine.7 As explained in Chapter 4, mixed results were obtained When destroying munitions in an EDS or by another EDT, at Camp Sibert when using the Miniature Chemical Agent it is important to know the TNT-equivalent net explosive Monitoring System (MINICAMS) for air monitoring in the weight in order to assess the type and quantity of contained energetics.8 The U.S. Army Corps of Engineers (USACE) area of a detected subsurface object as the object was being investigated and removed. It is expected that a similar expe- project manager at Spring Valley expressed his belief that rience will be encountered during other remediation efforts. some of the munitions processed as “explosively configured” at Spring Valley did not, in fact, contain explosives.9 Process- The problems encountered were as follows: ing a munition as explosively configured places additional • stress on the operators.10 The Spring Valley project manager As part of the MINICAMS calibration procedure, a midday challenge was used. This procedure can delay said that PINS “was not very good” at identifying explosives field operations a few hours. in recovered munitions and that a better method was needed • The MINICAMS is a relatively fragile system, not for this purpose—particularly for small amounts—owing intended to be moved around on a remediation site, to low sensitivity for nitrogen, a key element in explosive materials.11 resulting in a significant amount of downtime. A more rugged system is needed. After conducting the PINS analysis for fill and explosive • In certain parts of Camp Sibert, the presence of content, the Materiel Assessment Review Board (MARB) trichloroethylene interfered with determination of reviews all available information for each RCWM and mustard by MINICAMS. presents its assessment. The procedure is complicated and 7Dan Finding 6-5a. The MINICAMS is a fragile system, not suf- G. Noble, Project Manager, Spring Valley Baltimore District, USACE, personal correspondence to Nancy Schulte, NRC study director, ficiently robust to be moved from site to site. This lengthens February 3, 2012. downtime. 8Dan G. Noble, Project Manager, Spring Valley Baltimore District, USACE, “History of the American University Experiment Station,” presen - Finding 6-5b. A more rugged and portable system for near- tation to the committee on November 2, 2011. 9Dan G. Noble, Project Manager, Spring Valley Baltimore District, real-time air monitoring is needed to reduce downtime. USACE, personal correspondence to Nancy Schulte, NRC study director, February 3, 2012. Fewer than 100 munitions have been assessed at Spring 10Karl E. Blankenship, FUDS Project Manager, Mobile District, USACE, Valley and Camp Sibert. Future large remediation projects— “Remediation of Contaminated Soil at Camp Sibert, Alabama: The Instal - lation Manager’s Perspective,” presentation to the committee on November 12Karl E. Blankenship, FUDS Project Manager, Mobile District, USACE, 3, 2011. 11Dan G. Noble, Project Manager, Spring Valley Baltimore District, “Remediation of Contaminated Soil at Camp Sibert, Alabama: The Instal - USACE, “History of the American University Experiment Station,” presen - lation Manager’s Perspective,” presentation to the committee on November tation to the committee on November 2, 2011. 3, 2011.

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78 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL Explosive Destruction System for example, RSA—might entail assessing tens or hundreds of thousands of munitions or opened munitions that might The EDS has been very effective in destroying munitions still contain small amounts of agent and energetics. As dis- where the processing rate has not been a key factor and cussed above, the PINS/DRCT/MARB assessment approach where the munitions were well characterized—that is, the net has both problems and limitations. If the approach is applied explosive weight and chemical fill to be treated were known. to the assessment of tens or hundreds of thousands of muni- These conditions may not prevail, however, when processing tions, it may be unable to generate assessment opinions in a RCWM where small quantities of residual agent might exist sufficiently timely fashion, and the assessment results may that are not easily identified by PINS. To increase the capa- not be sufficiently definitive and accurate to guarantee the bilities of the EDS, the Project Manager for Non-Stockpile safety of those who operate the treatment equipment. This Chemical Materiel (PMNSCM) is carrying out a product issue needs to be addressed before munitions remediation is development program with two key elements: begun at RSA or at other large burial sites. • Steam injection. Injection of steam into the EDS Finding 6-6. When dealing with tens or hundreds of thou- vessel is to be tested. Its expected advantages are sands of munitions or opened munition bodies that contain twofold: (1) faster heating than is now obtained a gent and energetics, the current PINS/DRCT/MARB by heating with external band heaters only and (2) approach may not be able to carry out its assessments in a less liquid waste. This will reduce the 1-hr, 15-min sufficiently timely fashion, and the results may not be suf- needed to heat the rinse water from 60°C to 100°C, ficiently accurate to guarantee the safety of treatment equip- which originally took from 1315 until 1430 on Day ment operators. 1. Steam injection is being installed and tested on the EDS-2 test fixture mentioned above. Testing with live Recommendation 6-4. The Non-Stockpile Chemical Mate- agent was planned for 2012. riel Project should recommend modifications to the current • Universal reagent. Research has been begun on the P INS/DRCT/MARB assessment approach or adopt an identification of a reagent that will be effective for alternative approach that will function more quickly and all agents. Testing of 10 reagents on mustard and GD with more definitive and more accurate results when tens of (soman) agents has begun, with results pending. thousands or hundreds of thousands of munitions are to be assessed at a single site. Dynasafe SDC 1200 DESTRUCTION OF CONTAMINATED RCWM The committee judges that the Dynasafe technology is a viable approach to processing large numbers—tens or hun- As noted in Chapter 5, RCWM can be placed into three dreds of thousands—of burned and open chemical munition broad categories: agent contaminated and still containing bodies that might contain residual agent or energetics. In fact, energetic components such as fuzes and bursters; agent this technology may be an optimal approach, especially if a contaminated but not containing energetics; and agent non- munition destruction process is also needed at a large burial contaminated and suitable for unrestricted release. In the site such as RSA to destroy intact munitions. A Dynasafe text below, technology options and possible R&D needs are static detonation chamber (SDC) system could then process described for RCWM in the first two categories. There are both types, easily shifting back and forth between intact no technology needs for the third category, and items in that munitions that contain energetics and previously opened category can be sent off-site for recycling or, if they contain munition bodies that do not. The SDC is the only one of the a listed waste, sent to a hazardous waste treatment, storage, four technologies that produces scrap metal that is suitable and disposal facility (TSDF) for management in accordance for release for unrestricted use (formerly “5X”). with the state’s hazardous waste disposal regulations. As described in Chapter 4, many problems were encoun- tered when the SDC 1200 was operating on chemical muni- Destruction of RCWM That Contains Energetics tions at the Anniston Chemical Agent Disposal Facility (ANCDF), and work was begun on correcting these problems. Some of the RCWM to be destroyed will still contain This effort was continuing as this report was being written, energetic components. For most of these items, existing with conventional munitions of necessity being employed EDTs are expected to be adequate. (There are exceptions; since Anniston no longer has any chemical munitions. The see “Processing of Unusual Items at Redstone Arsenal” in continued effort has been designated as a throughput, reli- Chapter 5.) Possible developmental needs for these technolo- ability, availability, and maintainability (TRAM) study. gies are described below. The committee believes that this study is well planned and will increase both the throughput rate and the reliability of the process. Dynasafe, the vendor, is involved in the effort

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79 THE PATH FORWARD: RECOMMENDATIONS FOR TARGETED RESEARCH AND DEVELOPMENT and is incorporating the design improvements developed use of dry lime scrubbing, as done in the CH2M HILL TDC, at Anniston into future units. As also noted in Chapter 4, could be considered. since the SDC for Anniston was manufactured, Dynasafe has enlarged the thermal oxidizer for its SDC 1200s.13 This Finding 6-8. The SDC spray dryer does not prevent the will allow better control of excess oxygen and hence more formation of dioxins and furans, and solids sometimes accu- reliable combustion of CO. mulate on the interior walls of the dryer. Finding 6-7. Dynasafe has enlarged the thermal oxidizer in its Recommendation 6-6. The Non-Stockpile Chemical Mate- standard SDC 1200 design. Installation of this larger oxidizer riel Project should evaluate the costs and benefits of improv- is expected to aid in controlling excess oxygen and hence ing the reliability of the Dynasafe static detonation chamber result in more complete and consistent combustion of CO. system by replacing the spray dryer with a water-cooled heat exchanger and continuing to rely on activated carbon Recommendation 6-5. The Non-Stockpile Chemical Mate- adsorbers to capture the dioxins and furans formed as off- riel Project should investigate the benefits of the larger gas from the thermal oxidizer is cooled. If disposal of liquid thermal oxidizer now used in Dynasafe’s standard SDC waste (i.e., spent scrubber solution) becomes a problem, 1200. If, as expected, the larger oxidizer aids in controlling the Project Manager for Non-Stockpile Chemical Materiel excess oxygen, leading to the more complete and consistent should consider replacing the caustic scrubbers with a dry combustion of carbon monoxide, the project should con- lime injection system. sider replacing the current thermal oxidizer with the larger Finding 6-9. The ongoing development program for the oxidizer. Dynasafe SDC 1200 system at the ANCDF is well justified The committee, however, continues to be concerned about and well planned. It is expected to increase the reliability of the performance of the spray dryer used at the ANCDF. The the process. The throughput rate of the process, already high, vendor of the SDC 1200 claimed that the spray dryer would is also expected to increase. minimize the formation of dioxins (polychlorinated dibenzo- Recommendation 6-7. The Non-Stockpile Chemical Mate- p-dioxins) and furans (polychlorinated dibenzofurans) as the hot gases exiting the thermal oxidizer were cooled in the riel Project should continue its efforts to improve throughput dryer (NRC, 2010b). Dioxins and furans are highly toxic and reliability of the Dynasafe static detonation chamber materials. Because they accumulate in the human body, they system. are of great concern to the public. Emissions of dioxins and furans are regulated by the state of Alabama (NRC, 2010b) The Kobe Steel DAVINCH and the CH2M HILL Transportable and other regulatory authorities. Since the SDC system was Detonation Chamber started up, it has become clear that the spray dryer does not prevent the formation of dioxins and furans, and the acti- The DAVINCH and the TDC are similar in that they both vated carbon adsorbers in the off-gas treatment system must use external donor charges to access munition bodies and be depended on to capture the dioxins and furans formed destroy agent fill. Both technologies have been extensivly there. Also, the solids formed in the spray dryer sometimes used to destroy chemical munitions, and both have been accumulate on its interior walls. Eliminating the spray dryer modified by their respective developers in light of this experi- and using a heat exchanger to cool the hot gases from the ence. Consequently, the committee has not identified any key detonation chamber, as is done in the CH2M HILL TDC R&D needs that could make these technologies more suitable process, might improve the reliability of the process. The for processing intact RCWM that still contains an agent fill. existing activated carbon adsorbers would continue to cap- The primary solid waste produced by both technologies is ture the dioxins and furans formed as the off-gas from the scrap metal from munition bodies that has been decontami- nated to ≤1VSL but not to a more stringent level that would thermal oxidizer is cooled. The committee notes that neither the CH2M HILL TDC nor the DAVINCH system employs allow the scrap metal to be released for unrestricted use. a rapid quench to minimize the formation of dioxins and Additional development work on both technologies could furans, instead relying on activated carbon adsorbers to be carried out to allow this to happen. capture the dioxins and furans that are formed. However, the For the DAVINCH, the need for R&D to make it more larger Dynasafe system installed at Munster, Germany, does suitable for RCWM destruction will depend on site-specific employ a venturi quench for that purpose. Elimination of requirements. For example, if the DAVINCH is used to destroy the spray dryer would result in generation of a liquid waste RCWM, a reduction in the quantity of donor and shaped stream, the spent scrubber solution. If this is a problem, the charges could reduce both costs and risks associated with explosives handling. For larger and heavier munitions, it takes a long time to manually load the munition into the DAVINCH 13Harley Heaton, Vice President-Research, UXB International, personal vessel, and use of robotic equipment, as practiced in Japan, correspondence to Nancy Schulte, NRC study director, March 16, 2012.

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80 REMEDIATION OF BURIED CHEMICAL WARFARE MATERIEL • could reduce the loading time and any safety issues associated Using the Dynasafe SDC 1200 as noted above. The with manual handling of the overpacked munitions. SDC 1200 relies on heat to destroy agent in munitions Both the DAVINCH and the CH2M HILL TDC system still containing an agent fill, whether explosively con- have suitable air pollution control systems and are already figured or not. It can also be used to destroy residual designed to withstand detonations of energetics. Although quantities of agent in previously opened and treated both technologies use donor explosives to access the muni- munitions and to treat contaminated scrap metal, tion bodies and destroy the agent fill, it may be possible to assuming that the metal can fit into the SDC loading use only enough donor charges to access the munition cavi- chambers. ties (as is the case with the EDS) and to then use an external Finding 6-10. A program to investigate technologies such source of hot gas to destroy the agent rather than using the donor charge to do this. This could alleviate safety concerns as the SDC that can process burned and opened munition associated with the handling of energetics and would reduce bodies that might still contain residual agent and energetics stresses on the containment vessels associated with the is justified. detonations. An approach of this nature was once used to R ecommendation 6-8. N SCMP should evaluate the eliminate residual agent from the TDC (NRC, 2006). Dynasafe static detonation chamber for its ability to destroy recovered chemical warfare materiel, including burned and Processing of Nonenergetic RCWM previously opened munition bodies that still contain detect- Some of the RCWM at large burial sites will not contain able traces of agent and agent-contaminated scrap metal. energetics such as bursters and fuzes but may still con - This evaluation should include possible modifications to the tain detectable quantities of agent. This materiel includes SDC feed system, changes in the residence time in the SDC previously opened and drained munition bodies, scrap metal, chamber, and changes to its off-gas treatment system. and former production plant equipment, as is expected to be Recommendation 6-9. If a Dynasafe static detonation cham- found at RSA, for example. Rather than destroying residual agent using donor charges in explosive containment vessels ber is not available for destroying agent in recovered open such as the TDC or the DAVINCH, other options exist. These munition bodies, or is needed full time for the destruction include, but are not limited to, the following: of intact munitions, the Project Manager for Non-Stockpile Chemical Materiel should evaluate available alternatives for • Processing through high-temperature furnaces simi- decontaminating non-energetic recovered chemical warfare lar to the Blue Grass metal parts treater or the Pueblo materiel. metal treatment unit or the metal parts furnaces used Finding 6-11. Many items that are expected to be found at at the now-closed U.S. chemical munition incinera- tion facilities. In all cases, the systems would need to Redstone Arsenal are anticipated to contain agent or to be be gas tight and have appropriate air pollution control agent-contaminated. At the same time, they will be too large trains. to be fed to available or commonly used decontamination • Processing through a commercial transportable haz- technologies. ardous waste incinerator with a rotary kiln. These R ecommendation 6-10. T he Non-Stockpile Chemical systems are gas-tight and are equipped with suitable air pollution control systems. Materiel Project should begin preparations for treatment of • Processing through a car bottom furnace. Such fur- unusually large agent-contaminated or agent-filled items at naces feature cars (carts) on which the munitions Redstone Arsenal. would be loaded that can be rolled on rails into and out of the furnace. A car bottom furnace used for the Soil and sludge contaminated with agent, degradation munition body application would need to be of gas- products from agent and energetics and, as mentioned in tight construction and have an air pollution control Chapters 4 and 5, industrial chemicals, including pesticides train for discharge of the off-gases. and solvents, will be found at CWM remediation sites. In • Treating with decontamination solution and then the remediation projects at Camp Sibert and Spring Valley, analyzing the headspace. This is repeated until the contaminated soil was sent to commercial TSDFs for dis- headspace concentration is below the VSL. The posal. The Camp Siebert project manager briefed the com- decontaminated waste can then be shipped off-site mittee on one waste analysis issue, difficulties in obtaining for recycling.14 toxicity characteristic leaching procedure analyses on soil contaminated with agent; these difficulties caused delays. TSDFs require such analyses before accepting the soil for 14Raymond Cormier, Director, Mission Support, Deseret Chemical land disposal. The Edgewood Chemical Biological Center Depot, personal communication to Nancy Schulte, NRC study director, laboratories do not perform these analyses, and commercial April 2, 2012.

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81 THE PATH FORWARD: RECOMMENDATIONS FOR TARGETED RESEARCH AND DEVELOPMENT laboratories cannot accept agent-contaminated samples.15 The committee is passing along these comments, which impact the timing and cost of a remediation project, but without presenting any findings or recommendations. 15Karl E. Blankenship, FUDS Project Manager, Mobile District USACE, “Remediation of Contaminated Soil at Camp Sibert, Alabama: The Instal - lation Manager’s Perspective,” presentation to the committee on November 3, 2011.