6
Findings and Recommendations

In this report, the Stockpile Committee has reviewed the operations at DCD/TOCDF in terms of previous NRC recommendations. Table 6-1 summarizes these recommendations, indicates the chapter of this report where they are discussed, notes the committee's evaluation of the Army's response, and enumerates related new recommendations (presented below). If the committee found that a prior recommendation had been satisfied, the issue was considered closed. The new findings and recommendations in this chapter reflect the remaining and new issues that require further attention by the Army. Some of the new recommendations also have implications for future CSDP sites.

Finding 1. The committee considers the quantitative risk assessment (QRA) and the evolving risk management plan (RMP) as effective steps toward meeting the objective of minimizing public and worker risk.

Recommendation 1. The Stockpile Committee reiterates its earlier recommendation that the Chemical Stockpile Disposal Program should proceed expeditiously and should use technology that will minimize overall risk to the public and to the workers at each site.

Finding 2. The initial disposal campaigns at the Tooele Chemical Agent Disposal Facility (TOCDF) have destroyed a significant quantity of GB nerve agent, although the delay in the issuance of the Toxic Substances Control Act permit caused an interruption in the processing of GB M55 rockets. As a consequence, risk-reduction is well behind the original schedule. Although the Army seems confident that it can overcome this schedule slippage, a recent audit by the Arthur Andersen Company raises questions about the likelihood of meeting the disposal schedule. Extending the schedule will have adverse risk and cost implications.

Recommendation 2. The Army should process M55 GB rockets as soon as possible. The Army should also maintain a strong management commitment and close and effective working relationships with the relevant regulatory agencies to avoid future schedule slippages with their associated adverse risk and cost implications.

Finding 3. Several waste-handling aspects of TOCDF operations have not been resolved. These include performance in the brine reduction area (although the Army now plans to continue to treat brine off site), and plans to replace the dunnage furnace with an alternative method for the disposal of activated carbon. A micronizer and burner for activated-carbon disposal will be tested in the deactivation furnace system at the Johnston Atoll Chemical Agent Disposal System (JACADS) in 2001.

Recommendation 3. The Army should expedite the resolution of issues associated with the disposal of brine and dunnage in the interest of minimizing landfill disposal and minimizing overall waste as additional sites become operational.

Finding 4. The Army is pursuing a wise course in upgrading current automatic continuous air monitoring system (ACAMS) monitors while simultaneously funding the development of a faster, more reliable ACAMS. The Army has also significantly upgraded laboratory analysis tools for identifying species adsorbed on depot area air monitoring system (DAAMS) tubes that may trigger ACAMS false alarms. Infrared technology that may provide real-time detection of agent release is being investigated, and some progress has been made.

Recommendation 4. The Army should take the following steps to improve its monitoring systems:

  • continue its vigorous efforts to improve the response times, agent specificity, and overall reliability of the ACAMS alarms

  • continue to test and introduce improved laboratory instruments that can identify and quantify



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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations 6 Findings and Recommendations In this report, the Stockpile Committee has reviewed the operations at DCD/TOCDF in terms of previous NRC recommendations. Table 6-1 summarizes these recommendations, indicates the chapter of this report where they are discussed, notes the committee's evaluation of the Army's response, and enumerates related new recommendations (presented below). If the committee found that a prior recommendation had been satisfied, the issue was considered closed. The new findings and recommendations in this chapter reflect the remaining and new issues that require further attention by the Army. Some of the new recommendations also have implications for future CSDP sites. Finding 1. The committee considers the quantitative risk assessment (QRA) and the evolving risk management plan (RMP) as effective steps toward meeting the objective of minimizing public and worker risk. Recommendation 1. The Stockpile Committee reiterates its earlier recommendation that the Chemical Stockpile Disposal Program should proceed expeditiously and should use technology that will minimize overall risk to the public and to the workers at each site. Finding 2. The initial disposal campaigns at the Tooele Chemical Agent Disposal Facility (TOCDF) have destroyed a significant quantity of GB nerve agent, although the delay in the issuance of the Toxic Substances Control Act permit caused an interruption in the processing of GB M55 rockets. As a consequence, risk-reduction is well behind the original schedule. Although the Army seems confident that it can overcome this schedule slippage, a recent audit by the Arthur Andersen Company raises questions about the likelihood of meeting the disposal schedule. Extending the schedule will have adverse risk and cost implications. Recommendation 2. The Army should process M55 GB rockets as soon as possible. The Army should also maintain a strong management commitment and close and effective working relationships with the relevant regulatory agencies to avoid future schedule slippages with their associated adverse risk and cost implications. Finding 3. Several waste-handling aspects of TOCDF operations have not been resolved. These include performance in the brine reduction area (although the Army now plans to continue to treat brine off site), and plans to replace the dunnage furnace with an alternative method for the disposal of activated carbon. A micronizer and burner for activated-carbon disposal will be tested in the deactivation furnace system at the Johnston Atoll Chemical Agent Disposal System (JACADS) in 2001. Recommendation 3. The Army should expedite the resolution of issues associated with the disposal of brine and dunnage in the interest of minimizing landfill disposal and minimizing overall waste as additional sites become operational. Finding 4. The Army is pursuing a wise course in upgrading current automatic continuous air monitoring system (ACAMS) monitors while simultaneously funding the development of a faster, more reliable ACAMS. The Army has also significantly upgraded laboratory analysis tools for identifying species adsorbed on depot area air monitoring system (DAAMS) tubes that may trigger ACAMS false alarms. Infrared technology that may provide real-time detection of agent release is being investigated, and some progress has been made. Recommendation 4. The Army should take the following steps to improve its monitoring systems: continue its vigorous efforts to improve the response times, agent specificity, and overall reliability of the ACAMS alarms continue to test and introduce improved laboratory instruments that can identify and quantify

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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations TABLE 6-1 Summary of Prior and New NRC Recommendations Prior Recommendation Area(s) Addressed by Recommendation Chapter in Which Recommendation Is Discussed Response to Date New Recommendation RC-1 Program-wide risk reduction 2,3,4 Ongoing process 1 S-1 Implementation of a safety program 3,4 Ongoing process 1, 5, 6, 7, 9, 11 S-2 Incorporation of safety and environmental goals into award fees 4 Satisfied at the TOCDF and JACADS, but not program-wide 8 S-3 Completion of QRA and resolution of QRA safety-related issues 3 Good implementation at the TOCDF to date, but incomplete program-wide 5, 6, 7 S-4 Improved public interactions and communications 5 Ongoing process 10 S-5 Emergency-preparedness training 5 Satisfactory cooperative effort at the TOCDF, but ongoing concern about federal coordination at other sites 11 S-6 Completion and practice of emergency-preparedness plans 5 Satisfactory ongoing process 11 S-7 Completion of emergency-preparedness communications system for Tooele site 5 Significant progress and essentially complete   S-8 Completion of Army preoperational survey 2 Completed   S-9 Attainment of LIC 99.9999% DRE 2 Accomplished   S-10 Safety management 4 Progress, but continuing concerns 5, 6, 7, 9 S-11 Completion of RCRA and TSCA trial burns 2 Completed   S-12 BRA certification; dunnage disposal 2 Off-site disposal alternatives implemented; BRA certification on hold; DFS alternative to DUN to be investigated 3 S-13 LIC slag removal 2 Satisfactory performance of equipment   S-14 Completion of risk management plan (RMP) 3 Progress but not complete 7

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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations Prior Recommendation Area(s) Addressed by Recommendation Chapter in Which Recommendation Is Discussed Response to Date New Recommendation S-15 Risk assessment integration 3 Satisfied in principle   S-16 ''Near misses" tracking and safety 3 Progress but not complete 6 S-17 Improvements in monitoring 2 Progress but continuing effort required 4 R-1 Updating of QRA, HRA 3 Documentation of updating process pending 6 R-2 Development and review of program-wide site-specific QRAs and HRAs 3 Ongoing process 6 R-3 Update of QRA methodology manual 3 Still pending 7 R-4 Inclusion of "safety culture" in Guide 4 Progress but not complete 9 R-5 Definitions of risk management roles and responsibilities in Guide 4 Progress but not complete 7, 8, 9 R-6 Inclusion of public involvement in RMP 5 Further refinement necessary 10 R-7 Tracking of CMP performance 5 Disappointing performance to date on carbon-filter issue 10 R-8 Understanding of risk assessment by workers, etc. 3 Progress but not complete 5 R-9 Implementation and updating of RMP 3,4,5 Progress but not complete 5, 6, 7 PI-1 Commitment of CSDP to public involvement 5 Recent indications of improved strategy but commitment yet to be demonstrated 10 PI-2 Coordination of CSDP, CSEPP, public affairs, and RMP 3, 5 RMP not complete 7, 10 Code Legend: RC = Recommendations for the Disposal of Chemical Agents and Munitions report; S = Review of Systemization of the Tooele Chemical Agent Disposal Facility report; R = Risk Assessment and Management at Deseret Chemical Depot and the Tooele Chemical Agent Disposal Facility report; and PI = Public Involvement and the Army Chemical Stockpile Disposal Program report. See Appendix B for a complete list of reports by the NRC Stockpile Committee. interference species to minimize false positive ACAMS alarms continue to sponsor the development, testing, and potential deployment of new analytical instrumentation capable of providing real-time or near real-time (< 10 s) detection of significant levels of agent release and keep abreast of research in the area of rapid-response agent detection

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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations Finding 5. No comprehensive, integrated program for managing risks or communicating them to workers and nearby residents has been established or implemented. Recommendation 5. The Risk Management Program at stockpile storage and disposal facilities must be comprehensive and integrated to protect workers, the public, and the environment. The Army should incorporate current and planned risk management tools (quantitative risk assessments [QRAs]; health, safety, and environmental evaluations; health risk assessments [HRAs], etc.) into a comprehensive, integrated risk-reduction program to identify, prioritize, and reduce any (as yet undetermined) residual risks to workers and the public at Tooele and other disposal sites. The risk management program should be updated in response to experience and new information and should be a living, ongoing process that is integral to facility operations and adequately communicated. When used iteratively, it can help to identify and manage on-site and off-site risks. For example, lessons learned from Phase 2 QRAs can be incorporated into facility designs. Risk management decisions and HRA results should be used to determine if other mitigation measures are required. Finding 6. The Army has briefed the committee on how various issues related to the QRA have been resolved, but no formal process has been established for identifying and tracking QRA issues that must be resolved before the beginning of each campaign. The committee was briefed on the Programmatic Lessons Learned (PLL) program and concluded that two aspects of the program require additional work: (1) formal specification of the lessons-learned program, including site responsibilities in responding to lessons learned, and (2) the dissemination of lessons learned among the personnel at each site. Moreover, procedures for updating the QRA, and when necessary the HRA, based on new information (as identified in the PLL) have not been established, and the process for updating them when plant configuration or operational changes are planned has not yet been incorporated into the Guide. The committee notes that the Army has fallen significantly behind schedule in implementing major elements of the RMP at the TOCDF. Recommendation 6. As a formal process for each site, a list of outstanding issues related to the QRA for each campaign should be prepared and the resolution of each issue documented before the campaign begins. The Army should provide a formal specification for the lessons-learned programs, including individual responsibilities and definitions of how safety improvements at each site will be developed based on the lessons learned. The Guide to Risk Management Policy and Activities should be revised to include the process for updating the QRA and/or the HRA when significant new information is identified through the lessons-learned programs, or when significant plant, processing, or scheduling changes are planned. Based on its experience at the TOCDF, the Army should initiate Phase 2 QRAs for the chemical disposal facilities under development as soon as feasible, preferably while the risk information can still be used to improve the design and construction of the facility. Finding 7. The Army has successfully implemented an informal risk management process for DCD/TOCDF, but has not finalized a formal plan or institutionalized programmatic lessons learned for the risk management process or for other informal cross-site risk communication programs. The QRA methodology manual has not been revised to reflect recent improvements. Recommendation 7. The Army should formally and expeditiously implement risk management practices at site and programmatic levels into coordinated, well-documented plans and update them whenever necessary to ensure that they reflect current practices and lessons learned. The methodology manual for the quantitative risk assessment should be updated to reflect the significant improvements that have been made. Finding 8. At the start-up of operations, industrial safety performance was poor at both of the currently operating facilities (JACADS and the TOCDF). The committee believes this reflects a disproportionate focus on chemical agent and a failure of management to build a total safety culture prior to plant start-up. Sharing of lessons learned among sites will be critical for improving CSDP-wide safety performance. Recommendation 8. The Army should consider adding a Chemical Stockpile Disposal Program (CSDP)-wide factor for safety into the criteria for award fees at each site. This factor should be based on the safety performance at all CSDP sites. Operating sites should be required to demonstrate continued improvements in key safety metrics with "best of industry" standards, rather than "industry averages," as the target goal. The Army should insist that the safety performance of new

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Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations facilities be comparable to the best safety performance of operating facilities. Finding 9. After public allegations of safety deficiencies at the TOCDF by two employees, seven independent safety investigations at the site, and previous Stockpile Committee recommendations, TOCDF management implemented programs to improve safety performance and to lay the foundations of safety culture at the site. However, safety metrics do not yet indicate that performance has improved. Recommendation 9. The Army should continue the vigorous implementation of all elements of the Safety Culture Plan, with visible commitment and involvement by management. Finding 10. Recent efforts by the Army to improve public outreach are listed below: the reorganization of the Public Outreach and Information Office the development of the PMCD [Program Manager for Chemical Demilitarization] Overarching Public Involvement Strategy the publication of Public Involvement Strategy for the CSDP the publication of Umatilla Chemical Agent Disposal Facility Public Involvement Implementation Plan plans for a CSDP stakeholder survey the significant expansion of the capacity of the local Tooele public outreach office The Army has not, however, increased the opportunities for meaningful public input and review of CSDP activities and plans. Furthermore, a component of meaningful public involvement, which is recognized in the Umatilla Chemical Agent Disposal Facility Public Involvement Implementation Plan, is still missing at the TOCDF. Public involvement has not come at a point in time "when stakeholders believe that what they have said or contributed has been heard, understood, and incorporated into the decision-making process." The change management process will be a major step forward, but public involvement should not be limited to the CMP. Recommendation 10. The Army should continue to increase the involvement of local Citizens Advisory Commissions (CACs), stakeholder groups, and the public in the development of future CSDP planning, implementation, and public outreach activities (e.g., surveys). The public outreach activities should be integrated with other CSDP activities, and the committee again recommends that the public, CACs, and stakeholder groups play early and meaningful roles in the implementation of significant operational changes and in planning for the decontamination and decommissioning of disposal facilities. The integration of the Army's public outreach program and the CMP should be the first step in the development of a coordinated, efficient, effective, and meaningful public involvement program. Once the criteria are finalized for using the CMP and involving the public, the Army should actively expedite implementation of the process. Finding 11. Most of the committee's recommendations concerning emergency management and preparedness at the TOCDF have been addressed. First responders have been well trained in the use of personal protective equipment. Emergency preparedness plans for Tooele County for incidents involving chemical agent have been completed, and training exercises are continuing. Efforts are being made to coordinate responses by the Army with state and local emergency management agencies. Although these efforts are being hampered by the use of different software packages, significant improvements in preparedness and planning have been made. Significant improvements have also been made toward completing the communications system in Tooele County, and radios for using the National Weather Service as a notification system are being distributed. The committee is concerned that the current reorganization of the Chemical Stockpile Emergency Preparedness Program, under which FEMA now has responsibility for off-site plans and activities, may fragment authority and interfere with a well coordinated emergency management program. Recommendation 11. The Army and the Federal Emergency Management Agency should work together to ensure that preparedness and planning, warning, response, and mitigation activities of the emergency management program for the TOCDF are well coordinated. Informal relationships and agreements among state, local, and federal personnel should be formalized to ensure a permanent emergency preparedness capacity. Interfaces for emergency management software should be provided as soon as possible.