5
Community Interaction and Planning

The Stockpile Committee report, Recommendations for the Disposal of Chemical Agents and Munitions (NRC, 1994c), addressed the committee's concern for citizen involvement in and perceptions of the Army's Chemical Stockpile Disposal Program in the following recommendation:

The Army should develop a program of increased scope aimed at improving communications with the public at the storage sites. In addition, the Army should proactively seek out greater community involvement in decisions regarding the technology selection process, oversight of operations, and plans for decommissioning facilities. Finally, the Army should work closely with the Chemical Demilitarization Citizens Advisory Commissions, which have been (or will be) established in affected states. There must be a firmer and more visible commitment to engaging the public and addressing its concerns in the program. (REC-6)

Even before this recommendation in 1994, the Army had briefed the Stockpile Committee on a regular basis concerning efforts to establish and implement a public affairs and community relations program for the Chemical Stockpile Disposal Program (CSDP). In the fall of 1994, the Army expanded efforts considerably by establishing the current Public Outreach Program (Busbee, 1994). In addition, the Stockpile Committee adopted a community involvement plan to consider more fully the views of stakeholders and citizens in deliberations, as well as to gather information that could be used as a basis for future recommendations for the Army's public outreach efforts.

With respect to the Tooele Chemical Agent Disposal Facility (TOCDF) and the neighboring communities, the Stockpile Committee has met twice with representatives of the Utah Citizens Advisory Commission (CAQ (March 1994 and 1995), held a public meeting in Tooele (March 29, 1995), monitored various newspaper reports from the area, and met with various representatives of stakeholder and regulatory groups in Utah. In addition, the Stockpile Committee has reviewed a great deal of information provided by the Army concerning public outreach, including the Battelle studies of community viewpoints prepared for Science Applications International Corporation (SAIC) and the Army (Bradbury et al., 1994).

Based on these activities and an analysis of the information received and collected, the committee offers the following observations concerning the Army's efforts to involve the local community and to work closely with the Utah Citizens Advisory Commission, the Chemical Stockpile Emergency Preparedness Program (CSEPP) in Utah, and planned future community communications and citizen involvement programs in the state.

Utah Community Involvement

Community outreach can be encouraged through a variety of mechanisms. The Army's current efforts and plans include: grassroots information campaigns, civic organization meetings and public forums, community relations and special events programs such as tours of facilities, the development and distribution of brochures and videotapes, legislative information support programs, speakers' bureaus, coalition building with regulators, efforts to coordinate interagency information campaigns, and crisis information action plans (Busbee, 1994).

The limited resources of the Stockpile Committee have not permitted direct oversight of all of the Army's community involvement efforts. However, the committee did meet with representatives of the citizens advisory commissions from several states in March 1994, including the chair of the Utah Citizens Advisory Commission. In addition, members of the Stockpile Committee met in March 1995 with the Utah Citizens Advisory Commission, along with representatives of the Utah regulatory community and other state and local agencies with programmatic responsibilities resulting from the disposal program. The other agencies included several divisions of the



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--> 5 Community Interaction and Planning The Stockpile Committee report, Recommendations for the Disposal of Chemical Agents and Munitions (NRC, 1994c), addressed the committee's concern for citizen involvement in and perceptions of the Army's Chemical Stockpile Disposal Program in the following recommendation: The Army should develop a program of increased scope aimed at improving communications with the public at the storage sites. In addition, the Army should proactively seek out greater community involvement in decisions regarding the technology selection process, oversight of operations, and plans for decommissioning facilities. Finally, the Army should work closely with the Chemical Demilitarization Citizens Advisory Commissions, which have been (or will be) established in affected states. There must be a firmer and more visible commitment to engaging the public and addressing its concerns in the program. (REC-6) Even before this recommendation in 1994, the Army had briefed the Stockpile Committee on a regular basis concerning efforts to establish and implement a public affairs and community relations program for the Chemical Stockpile Disposal Program (CSDP). In the fall of 1994, the Army expanded efforts considerably by establishing the current Public Outreach Program (Busbee, 1994). In addition, the Stockpile Committee adopted a community involvement plan to consider more fully the views of stakeholders and citizens in deliberations, as well as to gather information that could be used as a basis for future recommendations for the Army's public outreach efforts. With respect to the Tooele Chemical Agent Disposal Facility (TOCDF) and the neighboring communities, the Stockpile Committee has met twice with representatives of the Utah Citizens Advisory Commission (CAQ (March 1994 and 1995), held a public meeting in Tooele (March 29, 1995), monitored various newspaper reports from the area, and met with various representatives of stakeholder and regulatory groups in Utah. In addition, the Stockpile Committee has reviewed a great deal of information provided by the Army concerning public outreach, including the Battelle studies of community viewpoints prepared for Science Applications International Corporation (SAIC) and the Army (Bradbury et al., 1994). Based on these activities and an analysis of the information received and collected, the committee offers the following observations concerning the Army's efforts to involve the local community and to work closely with the Utah Citizens Advisory Commission, the Chemical Stockpile Emergency Preparedness Program (CSEPP) in Utah, and planned future community communications and citizen involvement programs in the state. Utah Community Involvement Community outreach can be encouraged through a variety of mechanisms. The Army's current efforts and plans include: grassroots information campaigns, civic organization meetings and public forums, community relations and special events programs such as tours of facilities, the development and distribution of brochures and videotapes, legislative information support programs, speakers' bureaus, coalition building with regulators, efforts to coordinate interagency information campaigns, and crisis information action plans (Busbee, 1994). The limited resources of the Stockpile Committee have not permitted direct oversight of all of the Army's community involvement efforts. However, the committee did meet with representatives of the citizens advisory commissions from several states in March 1994, including the chair of the Utah Citizens Advisory Commission. In addition, members of the Stockpile Committee met in March 1995 with the Utah Citizens Advisory Commission, along with representatives of the Utah regulatory community and other state and local agencies with programmatic responsibilities resulting from the disposal program. The other agencies included several divisions of the

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--> Utah Department of Environmental Quality, the Utah Division of Comprehensive Emergency Management (CEM), and the Tooele County Department of Emergency Management. Further, the committee held a sparsely attended public forum to hear the viewpoints of community residents. Based on these discussions and the review of materials provided by the Army, several concerns need to be raised that have potential adverse effects on either the scheduled disposal in Utah or the larger continental program. Utah Citizens Advisory Commission and Risk Assessment: Problems of Communication The Congress in October 1992 (Public Law 102-484, Section 172, see appendix A) mandated that the Army establish citizens advisory commissions in each state where low-volume chemical weapons sites existed and, at the request of the governor, in any state where there is a chemical weapons storage site. The Army was further mandated to meet with these commissions to hear citizen and state concerns regarding the disposal program. The citizens advisory commissions were to be appointed by the governor of each state, with seven of the nine members of each commission representing the area near the site and two members representing the state government and having ''direct responsibilities related to the chemical demilitarization program'' (Public Law 102-484, Section 172(c)). The Army was informed of the formation of the Utah Citizens Advisory Commission by Governor Leavitt on August 16, 1993 (Leavitt, 1993). The mission of the Utah commission, as specified in its objectives, includes reviewing and advising the governor on issues pertaining to the health and safety of citizens within the state regarding incineration procedures and standards; on issues pertaining to permitting and compliance of the facility with regard to federal and state regulations; with regard to emergency preparedness; on alternative technologies; and on issues relating to the transportation of chemical agents. The first chair of the Utah commission was also the science advisor to the governor. The Stockpile Committee's March 1995 meeting with the Utah commission revealed that there were communications difficulties between the Army and the commission relating to the site-specific risk assessments being conducted at the TOCDF. The Utah Citizens Advisory Commission indicated that they had not been consulted and that their input had not been solicited by the Army or its contractors for the ongoing risk assessment. The Stockpile Committee's view of the importance of local involvement to the site-specific risk assessments is a matter of record. In a letter (to then Assistant Secretary of the Army Susan Livingstone) on risk assessments for facilities in the continental U.S., the committee stated: Local representatives of neighboring communities must be involved early. Their concerns about the CSDP may be substantial, and will warrant consideration throughout the analysis process (NRC, 1993a). In addition, the committee has pursued the matter of community involvement in site-specific risk assessments with representatives from the Army at almost every meeting since the letter was written. The Utah Citizens Advisory Commission's comment on the lack of Army solicitation of input into the site-specific risk assessment was of considerable concern to the committee because of the importance of this study, not only to the Tooele Army Depot, but also to the other continental sites where site-specific risk assessments are already under way or are scheduled to begin shortly. The Army has documented numerous occasions when the Army or its contractors explained the purpose of the site-specific risk assessment and solicited input from the Citizens Advisory Commission. For example, on July 27, 1994, Dr. Chris Amos from SAIC provided the commission with an overview of the site-specific risk assessment schedule and solicited input from the commission about perceived risks or scenarios that were perceived to be particularly important (Amos, 1994). The Army also solicited input from the commission chair about the makeup of the risk assessment Expert Panel, and ensured that one member of the panel was from Utah (St. Pierre, 1994). Indeed, in January 1994, the Program Manager for Chemical Demilitarization wrote the chair of the Utah Citizens Advisory Commission advising her of the scheduled risk assessment and suggesting ways the commission might wish to become involved in the process (Baronian, 1994). Quite clearly, the perceptions of the Utah Citizens Advisory Commission concerning the lack of opportunity for their input into the risk assessment (provided to the committee at the March 1995 meeting) are not congruent with the actions the Army is able to document of solicitation of Citizens Advisory Commission involvement in the risk assessments. The ultimate responsibility for

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--> ensuring community involvement in the site-specific risk assessments must rest with the Army. The Army and its contractors met again with the Citizens Advisory Commission and members of the public to discuss the quantitative risk assessment and some of the preliminary results on April 27, 1995. In addition, a public workshop was held in May 1995 to discuss the preliminary results of the risk assessments. The committee finds the Army's efforts in Utah to obtain community input into the risk assessments were substantial, but not very productive. The committee believes that citizen involvement both prior to and during the work of the risk assessment is essential to improve communications and the ultimate public acceptance of the risk studies. Personal Protective Equipment At the Stockpile Committee's public meeting in Tooele, Utah, on March 29,1995, considerable concern was expressed both by members of the Utah Citizens Advisory Commission and representatives of the Utah CEM about the Chemical Stockpile Emergency Preparedness Program. The single major concern was the lack of Occupational Safety and Health Administration (OSHA) approval of personal protective equipment (masks and protective clothing) for state and local first-responders. The former chairperson of the Citizens Advisory Commission, who was science advisor to the governor of Utah, suggested that the lack of approved equipment constituted a "potential showstopper" for plans to begin incineration because public perceptions would prevent agent burning until the equipment was provided. The Utah CEM expressed the belief that chemical incineration would not be permitted until personal protective equipment (PPE) is provided to first-responders and they have adequate time to train in the gear. A Utah CEM representative estimated that training would take about six months (Cobb, 1995). Representatives of the Utah Division of Solid and Hazardous Waste indicated that the personal protective equipment is not, strictly speaking, part of the permit process, but they believed the issue needed to be resolved before the start of agent operations (Downs, 1995). The committee believes this issue requires quick resolution because of the continuing larger risk associated with stockpile storage and the need to begin agent operations. During the committee's March visit, the issue of personal protective equipment for first-responders was clearly critical in the minds of members of the Citizens Advisory Commission, the Utah CEM, and possibly the public. The Army cooperated with local and state officials to try to speed OSHA's approval of alternative personal protective equipment (battle dress overgarment), which Army personnel have used elsewhere. The issue had been on the table for approximately seven years, according to one member of the Citizens Advisory Commission. The director of the Tooele County Department of Emergency Management told the Stockpile Committee that adequate training for the use of personal protective equipment need not take six months, but that failure to complete training could threaten start of agent operations in early 1996 (Sagers, 1995a). As of this writing, OSHA approval for another type of personal protective equipment has been received. The director of the Tooele County Department of Emergency Management, however, made it clear that the department's reliance on volunteer response personnel would nonetheless not provide for adequate public safety and that county volunteers still needed adequate training in the newly approved personal protective equipment (Lee, 1995). The county department has insisted on federal funding of a "core team" of well-trained responders who would be available to respond to an incident at any time. The importance of this issue can be readily seen in the testimony by the director of the county department to the Procurement Subcommittee of the U.S. House Committee on National Security on July 13, 1995 (Sagers, 1995b): Until our public safety needs are met, we cannot in good conscience allow hot operational burns at the Tooele Chemical Agent Demilitarization Facility. Tooele County's position is to let the facility sit out in the desert gathering dust until these matters are resolved. The Stockpile Committee considers this continuing difficulty to be the result of inadequate integrated planning by the Army of off-site and on-site emergency preparedness and response, and inadequate information about local needs and concerns. The importance of personal protective equipment, the adequate training of personnel, and the response capacity of the community are not new issues. Nevertheless, as of this writing, they threaten start-up of the TOCDF.

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--> Community Emergency Planning The Stockpile Committee has been aware of the Chemical Stockpile Emergency Preparedness Program for some time, as well as some of the difficulties the program has encountered (U.S. General Accounting Office, 1993a, 1993b, 1994, 1995). Of particular concern to the committee has been whether communities participating in the program are prepared to respond to off-site emergencies (U.S. General Accounting Office, 1993a). The committee has been briefed by a representative of the new joint office of CSEPP (now under the Program Manager for Chemical Demilitarization) concerning new organizational arrangements between the Federal Emergency Management Agency (FEMA) and the Army (Shandle, 1995). In addition, the Utah CEM also briefed the committee on the CSEPP program in Utah, and Tooele County emergency management personnel conducted a tour of their emergency operations center for the committee on the occasion of the committee's March 1995 public meeting. Finally, the committee has been provided with the Utah and Tooele County Emergency Operations Plans (Tooele County, 1994a) and related CSEPP appendices. The committee believes it is essential that a coordinated and effective chemical event emergency management capacity be in place as soon as possible because the existence of the stockpile poses a continuing risk. As discussed above, the March 29, 1995, meeting in Tooele revealed to the committee the continuing problem with the personal protective equipment for first-responders. In the unlikely event of a release of agent and an off-site emergency, it is essential that local and state responders be adequately equipped and trained and that they be well prepared through emergency exercises for any eventuality. In addition, potential evacuations, coordinated response, decontamination sites, restoration and reentry activities, and public warning/notification measures all require excellent communication systems. The committee is not prepared to undertake an exhaustive review of either the adequacy of national CSEPP emergency planning or the various subjects addressed in the General Accounting Office reports. Nor is the committee prepared to address all of the facets of various state and local efforts at emergency preparedness or the coordination in planning efforts between the three Utah counties in the emergency planning zone (EPZ), the state Division of Comprehensive Emergency Management, and the Army emergency response personnel at the TOCDF. Instead, the committee has chosen to state some findings and concerns, based only upon meetings in Utah, review of the emergency preparedness plans from the state and Tooele County, briefings to the committee by Army representatives, and interviews with Tooele County emergency management personnel. These findings are then used as the basis for additional recommendations. Training Several issues related to training have been brought to the committee's attention. First, the Utah CEM has pointed out the lack of attention at the national CSEPP level to "critical first-responder operations training" (e.g., personal protective equipment) (Cobb, 1995). The Utah CEM has indicated that, because of a lack of national planning standards, guidance with regard to reentry, emergency medical services, and recovery phase operations has been incomplete and has led to less than effective training and exercises. The issue of reentry is particularly disturbing because Army officials, at the meeting of March 29, 1995, in Tooele, stated they believed reentry would be handled by Army personnel, but Utah CEM officials felt this was a state function. In addition, at the March 29 meeting, a representative from Utah County, one of the three counties in the emergency planning zone, indicated that the county had not participated in the last emergency response exercise because of frustration over the issue of personal protective equipment. In follow-up discussions with representatives of the Tooele County Department of Emergency Management, it was learned that both Utah and Salt Lake counties have played minimal roles in exercises for the same reason (Rutishauser, 1995a). Exercising emergency response plans is critical to preparedness and actual response. County participation is at their discretion. But, the lack of participation by some counties raises concerns about their level of preparedness for an emergency. In addition, the Utah CEM has raised the issue of whether there are adequate national guidelines for training in several other areas. The Army and FEMA have divided responsibilities for providing adequate training, exercises, and preparedness guidelines. FEMA, according to a Memorandum for the Record signed in February 1994, supports the Army by "working with state and local governments in developing off-post emergency preparedness plans, upgrading

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--> response capabilities, and conducting necessary training" (FEMA and the Department of the Army, 1994). These issues were unresolved as of this writing (Lee, 1995). Emergency Planning The Army and FEMA have provided detailed CSEPP planning guidelines to state and local communities in many important areas of emergency planning (FEMA and the Department of the Army, 1994). In the event of emergency, off-site efforts are the responsibility of the appropriate state and local governments. The guidance provided by the national agencies suggests that CSEPP emergency plans should be appended to the existing all-hazards emergency plan of state and local governments as functional appendices specifically geared to chemical agent response (FEMA and the Department of the Army, 1994). The committee has had the opportunity to review the Tooele County Emergency Operations Plan and the functional appendices directed to chemical agent response (Tooele County, 1994a). In addition, the committee has been briefed and has toured the Tooele County emergency operations center. The review of the Tooele County functional appendices dealing with chemical agent incidents and intended for emergencies related to the Tooele South Area raises several concerns. First, many of the draft appendices were only completed in the fall of 1994 and were still in draft form as of April 18, 1995 (Rutishauser, 1995a). Second, probably because they are still drafts or preliminary in nature, some parts of the appendices are not well integrated. The appendices available for committee review included; Communications; Fire/Rescue; Health and Emergency Medical Services; the Community Command Post Concept; the Emergency Operations Plan; and Disaster Reception Center Standard Operating Procedures. In addition, the CSEPP program manager has indicated that the Health and Emergency Medical Services Appendix is in "very draft form." The Reentry and Restoration Appendix was still in progress as of February 11, 1995 (Rutishauser, 1995b). Consistent with Army and FEMA guidelines, the committee believes it is essential that these plans be fully prepared and exercised in order to provide complete and comprehensive emergency response capability to a chemical event (FEMA and the Department of the Army, 1994). The finding of the committee is that the local CSEPP emergency planning efforts are not complete, as evidenced by the draft version of the appendices. Emergency Communications As FEMA and the Army have pointed out, "the emergency communications system must have both a high reliability factor and redundancy." A communications network consisting of redundant telephone and radio systems should be designed and installed to link the Army installation Emergency Operations Center (EOC) and notification point with the EOCs and notification points of all immediate response zone (IRZ) counties and states (FEMA and Department of the Army, 1994). Effective communications systems are essential for notification and warning, incident command, emergency operations center functions, linkage to state and Army EOCs, linkage to sheltering centers and decontamination sites, communications with local elected officials, and linkage to all immediate response zone first-responders. The importance of effective communications for disaster response and effective public warning and evacuation is well documented in the disaster and emergency response literature (FEMA and Department of the Army, 1994). The Tooele County Communications Plan is a comprehensive document despite its preliminary nature. The plan allows for redundancy and provides sites for coverage of the CSEPP counties to include microwave, VHF, 400-MHz, 800-MHz, and 900-MHz channels (Tooele County, 1994b). Indoor alert and notification system radios (990 Tone Alert Radios) have only recently been funded and were expected to be in place in the community in the fall of 1995. In addition, Phase II of the 800-MHz system, which was scheduled for completion in 1994, has been delayed again and was not funded by FEMA in the FY 1995–1996 budget received by Tooele County (Lee, 1995). This system was to have enabled, among other functions, direct communications with the other two counties in the emergency planning zone and will require some additional training of personnel. In addition, some repeaters for Salt Lake and Utah counties have been delayed because of funding, and as a result, communications are problematic in parts of southern Tooele County, including Rush Valley (McCall, 1995). In short, the committee has found that the communication plan for Tooele County and the planned

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--> implementation of the communications system linking important operations centers in the emergency planning zone are not yet complete. The Army has not yet authorized funding for implementation of the communications system (Lee, 1995). Emergency Medical Care The Tooele Valley Regional Medical Center is the primary local medical facility and is working with the Army on issues of emergency medical service. The medical center has asked the Army to provide funding to keep the hospital emergency room open on a 24-hour basis and to train hospital personnel in procedures applicable to agent exposure. In congressional testimony, the director of the Tooele County Department of Emergency Management stated her concerns over delays in funding as well as the small fraction of the Army's CSEPP budget that has been allocated in Utah (Sagers, 1995b). She stated that Tooele County is not presently prepared to respond appropriately to an emergency involving agent release. Army Citizens Involvement Program in Utah The Stockpile Committee has stressed the importance of citizen and community involvement not only in the risk assessment process but also in decisions relating to the technology selection process, oversight of operations, and plans for decommissioning (NRC, 1994c). Involvement of citizens and the community in the selection of technology at the TOCDF was not possible because incineration had already been selected for the site by the time the committee made its recommendation. Based on briefings by Army personnel, the Stockpile Committee meetings in Utah with citizens, and reports prepared for various governmental entities, the committee can now comment on several aspects of the Army community involvement program in Utah. Consistent with the memorandum and plan sent from Brigadier General Walter Busbee to the principal Deputy Assistant Secretary of the Army on September 30, 1994 (Busbee, 1994), a public outreach program has been developed and should be implemented in Utah. The overall Army outreach effort consists of at least the following: community tours of the TOCDF; media tours of the TOCDF; CSEPP tours; state regulator tours; and tours for legislators and other governmental officials. The following educational materials are also planned: production of a systemization video; fact sheets for distribution to community and civic groups; speaking package materials; and educational materials for schools. Outreach activities include: planned risk assessment workshops; planned outreach to the schools; special events, including tours and community events; planned speakers' bureaus; expanded and updated mailing lists; and involvement of CSEPP representatives in community outreach activities. The committee has also been briefed on the hiring of additional staff for the program in Tooele, including a storefront office (Fournier, 1995). The Army also contracted with Battelle Pacific Northwest Laboratories through Science Applications International Corporation to conduct a series of interviews and focus groups in Tooele and at the other depot sites to better understand how people interpret the demilitarization program, "why they respond in certain ways and what the Army could do to design effective ways to interact with the public" (Bradbury et al., 1994). Finally, the Tooele County Department of Emergency Management contracted with Insight Research in Salt Lake City to conduct a survey of Utah and Tooele county residents on issues related to CSEPP and emergency management (Insight Research, 1994). This report indicates that about 20 percent of the residents felt they were familiar with the program, 20 percent had heard the name only, and 60 percent had never heard of it. The Battelle study in Tooele indicates that residents want the chemicals destroyed and are concerned about future use of the incinerator at the TOCDF, the transport of chemical weapons from other sites, and long-term health and environmental effects from environmental contamination at Tooele, Dugway Proving Ground, and other commercial incineration facilities nearby. In addition, there is substantial concern over cumulative environmental and health effects from incineration at the TOCDF and the other facilities (Bradbury et al., 1994). The Stockpile Committee efforts to solicit public input in Tooele were disappointing (i.e., citizen turnout was low). Although numerous invitations were mailed (appendix D), only four citizens from the area appeared on March 29, 1995, to comment on the TOCDF and other elements of the program. One citizen commented that local residents trust the people working at Tooele Army Depot. Another individual, a member of a group associated with the Chemical Weapons Working Group, expressed concerns about the potential change in

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--> requirements in the agent trial burn from 6-nines (99.9999 percent) to 4-nines (99.99 percent). Other issues raised by this individual related to the long-term effects of products of incomplete combustion, the possibilities for reconfiguring the stockpile by draining the agent first and then using neutralization (chemical hydrolysis), and what was perceived as a National Research Council (NRC) bias toward incineration. Another citizen, a member of the Sierra Club, raised issues related to the 4-nines for trial burns, neutralization alternatives to incineration, CSEPP's evacuation planning, liability issues related to hazardous materials teams that might aid in an emergency, and, finally, the lack of decontamination equipment in the county hospital facility. There remained some ambiguity about the expertise of the county in terms of both hazardous materials teams and equipment and decontamination units other than mobile facilities. After reviewing these materials and after public discussions, the committee finds that the Army has begun to implement a large and comprehensive public information program in Tooele County. Considering the list of activities either planned or under way in this program, it is clear that insufficient attention may have been given to the importance of soliciting citizen input into programmatic decisions as outlined in Committee Recommendation 6 (REC-6) in the Recommendations report (NRC, 1994c). For example, the committee found no evidence that the Army has considered the role of the public in decisions related to decommissioning the facility or monitoring disposal operations. It is understandable that the Army's program is oriented toward producing and disseminating information to the public, but it is essential that the outreach also proactively develop mechanisms and an approach for "engaging the public and addressing its concerns in the program" (NRC, 1994c) (Hance et al., 1988). Public concern about emergency management in the program is likely to increase as the TOCDF starts agent operations. Efforts should be made by the Army to include the public in CSEPP issues and to integrate public outreach more fully with elements of the CSEPP program.