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

Recommendation 1. Safety program development and implementation at the TOCDF must be given high priority.

Recommendation 2. Safety and environmental performance goals should be given at least equal weight with production goals in establishing award fee criteria.

Recommendation 3. Applicable portions of the accident quantitative risk assessments must be completed and all safety-related concerns resolved before the start of specific agent-destruction campaigns.

Recommendation 4. A substantial effort should be made by the Army to enhance interactive communications with the host community and the Utah State Citizens Advisory Commission on issues of mutual concern (e.g., various elements of the Chemical Stockpile Emergency Preparedness Program [CSEPP], decontamination and decommissioning, future use of the facility, and risk reduction).

Recommendation 5. The Army should increase efforts to work with the Utah Division of Comprehensive Emergency Management to ensure that first-responders have been adequately trained to use the personal protective equipment approved by the Occupational Safety and Health Administration. Tooele County must ensure their capability for responding to an emergency incident, especially because this condition relates to state requirements for the start of agent operations.

Recommendation 6. The Army, and where appropriate the Federal Emergency Management Agency (FEMA), should ensure that local and state Chemical Stockpile Emergency Preparedness Program (CSEPP) plans for responding to potential chemical events are complete and well exercised as soon as possible.

Recommendation 7. The Army/FEMA should provide the necessary resources for completing the communications system planned by the Tooele County Department of Emergency Management.

Recommendation 8. All mandatory requirements of the Army's Pre-Operational Survey must be satisfied.

Recommendation 9. The liquid incinerator and deactivation furnace system must have demonstrated a destruction removal efficiency of 99.9999 percent (6-nines) during surrogate trial burns.

Recommendation 10. High-quality, adequately staffed safety management systems must be completely implemented (including procedures for testing

critical equipment; all necessary operating, maintenance, and emergency procedures; management of change procedures; training and cross-training programs; programmatic lessons-learned activities; subject area reviews; and other safety oversight activities).

Recommendation 11. The liquid incinerator must pass all required Resource Conservation and Recovery Act (RCRA) trial burns; and the deactivation furnace system must pass required Toxic Substances Control Act trial burns.

Recommendation 12. Testing and certification of the brine reduction area and the dunnage incinerator should be completed at the TOCDF, or a satisfactory disposal alternative must be implemented.

Recommendation 13. Performance of the slag removal system for the liquid incinerators should be demonstrated when sufficient slag has accumulated.

Recommendation 14. The Risk Management Plan must be fully implemented.

Recommendation 15. A comprehensive, integrated, and clear TOCDF risk assessment study, including a full description of all significant acute and latent agent and nonagent risks associated with disposal operations, as well as with the continued maintenance of the Tooele chemical stockpile, should be completed. A full explanation of the uncertainties associated with the various estimates should be included.

Recommendation 16. A system for documenting and tracking unexpected upsets, errors, failures, and other sources of problems that lead to ''near misses" during operation of the facility should be developed as soon as possible. A program for integrating this information into a plan for continual safety improvements at the TOCDF should be implemented.

Recommendation 17. An active program for continual improvement of monitoring instrumentation, including techniques for more rapid recognition of significant levels of agent release, should be pursued.

Recommendation 1. The Army and the Chemical Stockpile Disposal Program management at all levels must make an increased commitment to public involvement throughout the entire program.

• The Program Manager for Chemical Demilitarization should establish and develop mechanisms and processes that allow direct input by affected citizens into the decision-making process for destruction of the stockpile.

• The Program Manager for Chemical Demilitarization should develop and implement a detailed public involvement plan that identifies program elements where the public and affected parties can make significant contributions to program decisions. The plan should be developed with input from the public, citizens advisory commissions, and other affected parties. The plan should define the goal of public involvement, a process for identifying opportunities for public input and review, mechanisms for interaction between the public and the parties responsible for implementing the disposal program, and individual and collective roles and accountability on the part of the Army, citizens advisory commissions, and others. Senior management of the Chemical Stockpile Disposal Program and management at each chemical stockpile site should be active and visible participants in the public involvement process.

• The Program Manager for Chemical Demilitarization should institute policies and procedures to ensure feedback to the communities detailing the Army's response to and use of input from the public and other parties in the decision-making process and program oversight.

• The Program Manager for Chemical Demilitarization is encouraged to provide independent technical assistance to the citizens advisory commissions as requested. This assistance should come from individuals or organizations that are without bias and have no conflicts of interest concerning the Chemical Stockpile Disposal Program.

Recommendation 2. The public affairs programs for the Chemical Stockpile Disposal Program, the Chemical Stockpile Emergency Preparedness Program, and other Army activities at stockpile locations should be

closely coordinated to avoid adversely affecting public perceptions of the Chemical Stockpile Disposal Program and delaying implementation of stockpile destruction. In addition, the public affairs program for the Chemical Stockpile Disposal Program should be coordinated with the risk management plan at each stockpile site.

Recommendation 1. The Army should update both the QRA and HRA at the TOCDF whenever changes to system design or operations occur that could affect QRA or HRA calculations to ensure that estimates of risk are current and reflect changes in operating conditions and experience, assumptions, and program status (current Established Configuration). The process for updating the QRA and HRA should be included in the Guide.

Recommendation 2. The Army should continue the site-specific QRA and HRA processes at all PMCD sites. The development of assessments for sites other than the DCD will be greatly simplified because much of the methodology has already been established. The Army should continue to obtain interactive, independent expert reviews of all site-specific QRAs. The Army should heed the lessons learned from development of the TOCDF QRA and should incorporate the changes recommended by the Expert Panel.

Recommendation 3. The QRA methodology manual should be updated to reflect the significant improvements that have been made.

Recommendation 4. The Army should expand its draft report on risk management policy, A Guide to Risk Management Policy and Activities, to encourage the establishment of a "safety culture" within the PMCD and its field offices and among contractors and other government agencies. The Guide should elucidate the Army's policy on industrial safety, including the responsibilities of individuals and managers in the field and the definitions of acceptable performance.

Recommendation 5. The Army should develop a management plan (and include it in the Guide) that defines the integration of management roles, responsibilities, and communications across activities by risk management functions (e.g., operations, safety, environmental protection, emergency preparedness, and public outreach).

Recommendation 6. The Army should review and expand the current draft risk management plan to include public involvement in appropriate areas beyond the management of change process.

Recommendation 7. The Army should institutionalize the management of change process developed in the Guide. The Army should track performance of the change and document public involvement and public responses to decisions. The Army should use this experience to improve the change process.

Recommendation 8. The Army should expand implementation of the risk management program to ensure that workers understand the results of the risk assessments and risk management decisions. The Army should also ensure that CSEPP and other emergency preparedness officials understand the QRA and how their activities might affect risk. CSEPP activities should be tracked by the Army as part of their risk management program.

Recommendation 9. The Army should implement their risk management plans and update them whenever necessary to ensure that they reflect current practices and lessons learned.

NRC (National Research Council). 1996a. Review of Systemization of the Tooele Chemical Agent Disposal Facility. Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Board on Army Science and Technology. Washington, D.C.: National Academy Press.

NRC. 1996b. Public Involvement and the Army Chemical Stockpile Disposal Program. Committee on Review and Evaluation of the

Army Chemical Stockpile Disposal Program, Board on Army Science and Technology. Washington, D.C.: National Academy Press.

NRC. 1997. Risk Assessment and Management at Deseret Chemical Depot and the Tooele Chemical Agent Disposal Facility. Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Board on Army Science and Technology. Washington, D.C.: National Academy Press.