Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations (1999)

The Stockpile Committee has made several recommendations related to both public involvement in the CSDP and emergency management and preparedness. In the Systemization report (NRC, 1996a), the recommendations dealt explicitly with activities at the TOCDF. In the Risk Assessment and Management report (NRC 1997), the recommendations were addressed to the overall disposal program as it relates to risk management and the involvement of the public in risk management decisions. The Public Involvement report (NRC, 1996b), a letter report issued subsequent to the Systemization report, focused on institutionalizing public involvement within the CSDP.

On the subject of public and community interactions for the duration of TOCDF operations, the Stockpile Committee recommended that the Army make a substantial effort to increase and improve communications with the host community and the Utah State Citizens Advisory Commission (CAC) on issues of mutual concern (e.g., the CSEPP, decommissioning of the facility, its future use, and risk reduction) [S-4]. The committee also recommended that the Army review and expand its draft RMP (risk management plan) to include public involvement in more areas than the CMP [R-6].

The Stockpile Committee recommended that at the start of agent operations the Army increase its efforts to work with the Utah Division of Comprehensive Emergency Management to ensure that: (1) first responders are properly trained and well equipped [S-5]; (2) local and state CSEPP plans are complete and have been practiced [S-6]; and (3) resources are provided in coordination with the Federal Emergency Management Agency (FEMA) to complete the emergency communications system for the Tooele County Department of Emergency Management [S-7]. The committee also recommended that the Army ensure that CSEPP and other emergency preparedness officials understand the QRA and its implications for emergency management and that the Army track CSEPP activities as part of its RMP [R-8].

The Stockpile Committee has repeatedly recommended that the Army and CSDP management at all levels make a strong commitment to public involvement throughout the entire program [PI-1]. Also, public affairs programs for all Army activities at stockpile locations and the CSEPP (now managed by FEMA), should be closely coordinated, which should be reflected in the RMP at each site [PI-2].

This chapter reviews the Army's responses to these recommendations, which are all concerned with emergency management or preparedness, public involvement, and the intersection of the CMP and public involvement. The following discussion is based on direct observations by committee members, briefings by the Army, and telephone interviews with key community personnel, local officials, county personnel, and CAC members. Either the full committee or a subgroup has visited the TOCDF and the Tooele community six times since the Systemization report was issued. In addition, members of the committee have been briefed by local officials on a regular basis on measures undertaken in Tooele County related to CSEPP. The following discussion focuses on: (1) public involvement, (2) surveys of public opinion, (3) emergency management and preparedness, and (4) the CMP.

The PMCD's past attempts at developing a national public outreach (i.e., public involvement) plan, as well as some site-specific plans, have not been successful. The Stockpile Committee has repeatedly emphasized the importance of "community involvement in decisions regarding the technology selection process, oversight of operations, and plans for decommissioning the facilities" [RC-6] (NRC, 1994a). Meaningful public involvement was also the subject of the Public Involvement letter report and a topic in the Risk Assessment and Management report.

The committee strongly believes that meaningful public involvement would enable the Army to respond

to the concerns of local communities, thereby building trust and minimizing impediments to the timely disposal of the stockpile. The committee also addressed the importance of public involvement in a recommendation in the Systemization report:

The committee has monitored the development of the Army's public outreach programs through briefings by the Army, meetings with the Utah CAC, and public meetings. Since 1996, important changes have been made in the PMCD's management of the CSDP, specifically in the Public Outreach and Information Office (POIO) (U.S. Army, 1998a).

The PMCD's overarching strategy has shifted the POIO's mission from an "operational emphasis providing site-specific support to providing public involvement support on the program level" (U.S. Army, 1998d). Since 1998, the director of the POIO has been responsible for providing staff liaisons and some staffing for outreach activities at specific sites and other related programs. Two contractors were hired to help the Army: SAIC assisted in establishing public involvement (storefront) offices in major towns and communities near each site; Booz-Allen & Hamilton assisted the Army in developing both the PMCD Overarching Public Involvement Strategy (U.S. Army, 1998b) and the Public Involvement Strategy for the CSDP (U.S. Army 1998c). The POIO office now has the following responsibilities:

• public outreach at the baseline incineration sites at Tooele, Utah; Umatilla, Oregon; Anniston, Alabama; Pine Bluff, Arkansas; and Johnston Atoll (U.S. Army, 1998b)

• public outreach and public involvement in the selection and implementation of alternative disposal technologies for the bulk storage sites at Aberdeen, Maryland, and Newport, Indiana¹

• public outreach in the non-stockpile program (i.e., the disposal of buried chemical warfare materials and binary chemical weapons, the cleanup of former production sites, etc.)

• outreach in the Army's cooperative threat-reduction program for assisting the Russian Federation with its disposal program (U.S. Army, 1998b).

The POIO will also provide legislative support, media relations, training, and crisis communication to the CSDP. Perhaps more importantly, the POIO now has a clearly stated mission (to provide "a public involvement program that supports meaningful public participation and dialogue") and a clearly stated vision ("to gain public acceptance of the need for the safe expeditious disposal of chemical material") (U.S. Army, 1998b). The PMCD Overarching Public Involvement Strategy is the first document that clearly indicates the direction of PMCD's public outreach.

Booz-Allen & Hamilton also helped the Army develop a public-involvement strategy document for the CSDP, the Public Involvement Strategy for the CSDP (U.S. Army, 1998c). This document outlines the "objectives, key messages, and operational framework" for the CSDP's public information and public involvement program. The document is designed to be continually updated and provides specific guidelines for public involvement programs at storage and disposal sites. The updated (September 1998) Umatilla Chemical Agent Disposal Facility Public Involvement Implementation Plan was reviewed by the committee for this report (U.S. Army, 1998d). Implementation plans for Anniston, Pine Bluff, Tooele, Aberdeen, and Newport, which are in various stages of development, will also be constantly updated as circumstances and resources change.

It is still too early to assess the impact of the reorganization and realignment of the POIO. Nevertheless, both the PMCD Overarching Public Involvement Strategy document and the Umatilla Chemical Agent Disposal Facility Public Involvement Implementation Plan represent significant improvements over previous efforts. Moreover, the new strategy seems to have encouraged the site outreach offices, which are closest to the local communities, to take the initiative in developing their

own strategies within the context of the mission, vision, and programs of the POIO. All elements of the program organization are now united by a common mission and appear to have received strong leadership from the POIO (Campbell, 1998).

If the other site-implementation plans are of the same high quality as the plan prepared for the Umatilla site, then significant improvements have been made. For example, the Umatilla plan attempts to relate future activities to both past efforts at public involvement by the Army and present sentiments in the community, which were expressed in surveys (see below) (U.S. Army, 1998d). Perhaps even more important is the description of opportunities for public involvement, which reflects a substantial step in the right direction.

Since the start of operations at the TOCDF, public outreach has been less than successful. First, involvement of the public and the CAC in several important developments could have improved communications and meaningful public involvement by the local community. For example, the committee learned that the Tooele public outreach office did not involve the public or the CAC in the development of its draft public-involvement implementation plan. A few CAC members were involved informally, but the Army made no formal attempt to obtain input from the CAC or the public. In the future, the Army should obtain public input before any plan (or substantive modification) is finalized.

Second, a public meeting sponsored by the Army on July 14, 1997, to discuss the proposed CMP (change management process) was not successful. Neither the personnel of the local outreach office nor the public had been involved in the development of the draft CMP prior to the meeting (Campbell, 1998). As a result, only a few members of the public and the CAC were present at the meeting, along with about 30 personnel associated with the Army and the TOCDF. This lack of public interest reflects both the past lack of communication between the community and the Army and the fact that the public has little interest in changes to the established technology. Based on this experience, the committee concluded that at sites where the technology is already established, the Army should expand the CMP to include other topics of interest to the public, such as plans for decommissioning the facilities.

Although reorganization of the POIO and the development of strategies for obtaining public involvement are important, neither is a substitute for an organizational culture that proactively seeks the involvement of not only the public, but also personnel of the local outreach office, who are best informed about local interests and issues.

In the 1996 Systemization report, the committee noted that the Army had missed an excellent opportunity by not making a concerted effort to involve the public in the development of the risk assessments for the TOCDF. The drafting of the CMP appears to be another lost opportunity, and as the committee notes in the recent report, Carbon Filtration for Reducing Emissions from Chemical Agent Incineration, the CMP has yet to be linked to issues that could arouse public interest (NRC, 1999).

In 1997, the Tooele outreach office had 575 visitors, participated in 35 speaking engagements attended by 2,800 people, and conducted 380 tours of the facility (U.S. Army, 1998e). The local outreach office at Tooele has since improved its tracking capability and expanded its staff and office space to three times its original size. The CAC meeting at the opening of this new office on April 16, 1998, was attended by more than 50 people involved in emergency management operations (Campbell, 1998; Sagers, 1998a). The office is now staffed by four Booz-Allen & Hamilton employees. In addition, it now maintains its own mailing lists. All of these changes are consistent with the new expanded mission for local offices and should provide local citizens with better information and more accessibility to the CSDP.

Nevertheless, despite these improved outreach capabilities at the local level and the reorganization of the POIO, this site has a long way to go to reach the level of public involvement in the decision-making process the committee recommended in the Systemization report [S-4] and again in the Public Involvement letter report [PI-1]. The sooner the public becomes meaningfully involved, the more widely accepted program decisions will be.

In the past, the Stockpile Committee has been critical of the POIO's efforts to ascertain public views and

attitudes, as well as to provide relevant information about the disposal program (NRC, 1996b). In June 1998, and again in December 1998, the POIO provided the committee with an overview of its preparations for conducting a stakeholder survey and incorporating the survey results into a database and tracking system (Williams, 1998; U.S. Army, 1998f). The survey plan indicates that local outreach offices will be involved in developing the surveys, and as of mid-April 1998, the Tooele County outreach office had already convened a meeting of various stakeholders to identify issues to be included in the survey (Campbell, 1998). One of the first decisions made by this local group was to invite some of the leaders or representatives of groups interested in the TOCDF, or incineration generally, to participate (Campbell, 1998). A consultant has informed the committee that similar stakeholder meetings have been held at the other sites and that additional efforts are under way to ensure the participation of a broad spectrum of stakeholders, including opponents of the baseline incineration system (Williams, 1998).

The committee is encouraged that the Delphi survey technique is being used to identify important issues that should be included in the survey. The extremely ambitious survey plan raises concerns, however, that the large number of responses necessary at each site to produce generalizable results may not be received. Therefore, the Army must seek the cooperation of all stakeholder groups at each site. The committee urges the Army and its contractor to build on this excellent beginning and take the necessary steps to obtain the cooperation from these groups.

In the 1996 Systemization report, the Stockpile Committee made three recommendations concerning the coordination of emergency management, response, and preparedness with the start of agent operations. These recommendations are discussed below. In addition to these recommendations, part of another recommendation [S-4] called upon the Army to enhance its interactive communications with the host community on issues involving the CSEPP.

Since this recommendation was made, the CSEPP has been reorganized. The Army has retained control of on-site emergency preparedness, but all off-site responsibilities, including budgeting, have now been assigned to FEMA. Consequently, off-site emergency preparedness is no longer within the scope of the Stockpile Committee's oversight. Nevertheless, the committee has made several observations based on its oversight experience.

The General Accounting Office has prepared at least seven reports citing problems in the CSEPP (GAO 1993, 1994, 1995a, 1995b, 1995c, 1996, 1997). The committee is also concerned about the CSEPP and about the horizontal fragmentation of responsibility at the federal level. Previous briefings by directors (both Army and FEMA) of the CSEPP, as well as discussions with directors of state emergency management agencies, have all stressed the importance of a well coordinated response-management capability with the technical capacity to respond effectively to a chemical event. The recent reorganization will require excellent coordination and communication to overcome the barriers of separate organizational responsibilities. In fact, the committee is not convinced that the reorganization will improve the capacity for responding to an emergency.

The committee strongly recommended that the Tooele County Emergency Management Plan be completed and that the Army ensure that training exercises be carried out. Two issues underlie this recommendation. First, the committee's initial review in 1996 of the Tooele County Emergency Operations Plan and the functional appendices on chemical hazard/agent response revealed that several components of the plan and appendices were still in draft form. Second, the committee determined that, because of the disagreements over issues pertaining to the procurement of personal protective equipment, Utah County had not participated in the latest training exercise at that time. Moreover, for some time, both Salt Lake and Utah counties participated only minimally in these exercises. Both Army and FEMA guidelines state that all plans must be completed and that personnel must be trained to carry them out in order to ensure a comprehensive emergency-response capability to a chemical event (FEMA and Department of the Army, 1994).

In mid-1998, committee members were able to review the completed and updated Tooele County Emergency

Operations Plan (and the functional appendices pertaining to a chemical agent event). The Tooele County director of the Department of Emergency Management informed the committee that DCD, county, and state personnel had participated in a successful exercise of the Emergency Operations Plan (Sagers, 1998a). In September 1998, another exercise was held in which both Salt Lake and Utah counties participated. Observers from several FEMA regions, as well as FEMA headquarters personnel, also attended. In fact, more than 300 evaluators or observers were present (Sagers, 1998b). The increased interest in the September exercise was partly due to the Army's Integrated Process Teams' attempts to develop better exercises for CSEPP (Sagers, 1998b). At the time of this report, there were no negative findings on the exercise, and the basic response activities were positive (Sagers, 1998b). Thus, it appears that the committee's concerns in this area have been adequately addressed.

The committee recommended that the Army provide OSHA-approved personal protective equipment to local first-responders and train them in its use. In interviews with the director of the Tooele County Department of Emergency Management, the committee was assured that the equipment had been provided and that 250 local first-responders had been trained (Sagers, 1997, 1998a).

The committee had also been concerned about the delegation of responsibility for determining when an area was safe for reentry and whether adequate decontamination equipment was available for local emergency medical personnel. The committee has learned that three mobile decontamination units (to decontaminate patients prior to treatment) have been deployed in Tooele County, one of them stationed at the Tooele Valley Regional Medical Center. The adequacy of the decontamination capacity in Rush Valley is still being assessed by Tooele County (Sagers, 1998b). The reentry issue has been resolved through cooperation between local officials and DCD personnel. Emergency preparedness exercises have been planned and implemented for both decontamination and evacuation scenarios (Sagers, 1997, 1998a).

Two different emergency-management software packages are being used in Utah: FEMIS and EMIS. The Tooele County Department of Emergency Management now has the capacity to interface between the two so that it can work with the Army, which uses EMIS, and the state, which uses FEMIS. The committee commends the cooperative efforts of Army, state, and county emergency-management personnel. However, the committee notes that the use of different software packages is evidence of the lack of cooperative planning.

In 1994, the committee found that both the Army and FEMA recognized the importance of a highly reliable, highly redundant communications system that would serve the following functions (FEMA and the Department of the Army, 1994):

• issue notifications and warnings

• serve as incident command center

• function as emergency operations center

• establish and maintain links to state, county, and Army emergency operations centers

• maintain communications with local officials

• maintain links to all first responders, as well as various sheltering, medical, and decontamination sites

As of early 1996, however, Tooele County had still not completed its communication system.

Interviews in 1997 and 1998 with the Utah Department of Emergency Management showed that the communication system was almost completed. The Tooele County Department of Emergency Management's Communication Plan has been revised, and the system is now both highly reliable and highly redundant. Virtually the entire county is now covered by some type of communication band (microwave, 400 MHz, 800 MHz, or 900 MHz) (Sagers, 1998a). Although there are still some dead spots in Rush Valley, three critical links in the system have now been funded and are being phased into place. The communications system thus appears to be adequate to handle an incident. Most of Tooele County is covered by an 800-MHz band, except for police, fire, and emergency medical agencies (Sagers,

Figure 5-1 PMCD's organizational elements directly related to risk management (p. 63 in the Guide). Source: U.S. Army, 1997a.

1998c). However, the county can interface with all relevant response agencies.

The communications system can now notify and warn residents. Originally, Tooele County had planned to use tone-alert radios (indoor alert notification system 990-MHz radios), which had been funded but had not been distributed when the Systemization report was issued. The current notification system relies on National Weather Service radios (through an agreement concluded in 1994–1995). These radios have been widely distributed and can be activated in the event of an incident by either the National Weather Service or the operations center of the Department of Emergency Management (Sagers, 1998a). A small part of Rush Valley is without these radios because of difficulties with distribution or resident preferences. The Department of Emergency Management, in cooperation with other Tooele County departments and the local Army POIO outreach office, has devised and implemented a plan for distributing radios to new residents. (Warning sirens are included in the plan but were not evaluated for this report.) It is clear that substantial progress has been made in the critical area of communications and that the system is almost complete.

The Risk Assessment and Management report included several recommendations ([R-5] through [R-8])

concerning the integration of the public-involvement and emergency-management functions (CSEPP) into the Army's draft Guide and RMP (risk management plan):

These recommendations clearly reflect the committee's conviction of the importance of integrating both the public-outreach and the emergency-preparedness programs into the Army's draft Guide, as well as the CMP (which was planned as the last chapter of the Guide). The committee was convinced that the development of a CMP and its inclusion in the Guide would break new ground. The CMP would be "a process for managing changes that may affect the risk associated with PMCD activities" (NRC, 1997, p. 41), would distinguish matters of risk assessment (the science) from matters of risk management (policy and value judgments), and would establish an approach for integrating them that involved the public. In addition, the Guide would define and integrate management functions as they relate to risk management (Holmes, 1998c). The committee concluded that the development of an institutionalized CMP would be critical to comprehensive risk management. At the same time, the committee noted with concern that public involvement, as reflected in the draft Guide's organizational components, was not being integrated with risk management (see Figure 5-1). Nevertheless, the committee encouraged the completion of the draft Guide, especially Chapter 7, which focused on public involvement, so that the Guide could become policy.

Since the Risk Assessment and Management report was issued, the committee has monitored the Army's efforts to complete the draft Guide, especially the CMP and the public involvement components, and has documented its disappointment with the slow development of the CMP. (The lack of implementation of the CMP in the carbon filtration issue is discussed in the recent Carbon Filtration for Reducing Emissions from Chemical Agent Incineration [NRC, 1999]). The committee continues to be concerned that the results of both the QRA and HRA may still not be well understood by CSEPP and other emergency-management personnel, or by the public. The absence of a CMP that includes meaningful public and stakeholder involvement in the Army's risk management decisions is a notable lapse in the program. The Army has failed to use the CMP as a way of initiating two way communication and providing a mechanism for the public to participate in decision making.