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THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine National Academy of Sciences National Academy of Engineering Institute of Medicine National Research Council Board on Army Science and Technology Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program May 4, 2000 Dr. Gloria Patton Deputy Assistant Secretary of the Army for Chemical Demilitarization Office of the Assistant Secretary of the Army for Acquisition, Logistics and Technology SARD-ZC 2511 Jefferson Davis Highway, Suite 11300 Arlington, VA 22202 Re: Obstacles to Closure of the Johnston Atoll Chemical Agent Disposal System Dear Dr. Patton: This letter identifies urgent issues pertaining to the completion of chemical agent disposal operations and subsequent closure of the Johnston Atoll Chemical Agent Disposal System (JACADS). It appears that direction at the executive level will be required to clarify these issues. The National Academies National Research Council Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) has provided scientific and technical advice and counsel to the Army on its Chemical Stockpile Disposal Program for the past 12 years. When the committee recently began a study of the closure planning process for JACADS, it became apparent that timely and economical completion of plans for closure of the facility and the eventual transition to closure operations are in jeopardy because the final end use and end state of the atoll have not been established. In less than a year, the United States is scheduled to reach an important milestone in complying with the Chemical Weapons Convention of 1997. The first of nine U.S. chemical agent disposal facilities, JACADS, will have completed the destruction of its portion of the nation ’s chemical agent and munitions stockpile using high-temperature combustion technology. The Army’s Program Manager for Chemical Demilitarization has begun planning and preparations to close JACADS and turn over that segment of Johnston Island to the current host management agency, the Department of the Air Force, by September 2003. Responsibility for the overall atoll is based on Executive Orders dating back to 1926 and current Department of Defense assignments, which do not take into account the involvement of multiple agencies in the cleanup of the atoll. Because other federal agencies have an interest in the atoll’s use after the Army and Air Force complete their missions, it may not be possible to establish the final use of the Johnston Atoll in time to meet the September 2003 schedule established by the Army. Some of the key issues that may present obstacles to timely and effective closure are beyond the purview of the Army: (1) the lack of high-level coordination of all involved agencies to determine the end 2101 Constitution Avenue, NW, Washington, DC 20418 Telephone (202) 334 2577 Fax (202) 334 2620 email firstname.lastname@example.org www4.nationalacademies.org/cets/dmst.nsf
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use and end state1 of the entire Johnston Atoll and associated cleanup criteria; and (2) the lack of plans for the remediation of Johnston Atoll as a whole, with all waste processed in a way that minimizes hazards on the atoll and takes into account the costs to taxpayers. Chemical agent and munitions storage and disposal operations currently occupy about 130 acres of the 625-acre Johnston Island, the main island of Johnston Atoll. Johnston Island is approximately 7 percent natural; the remaining 93 percent was created by dredging of the surrounding coral reef to build a military runway. A protective seawall surrounding the island requires periodic maintenance to keep most of the island from being reclaimed by nature. Other parts of Johnston Island will require remediation (not necessarily by the Army) to address contamination by non-JACADS wastes, including Agent Orange, dioxins, PCBs, plutonium, and other potentially hazardous compounds known to be present outside the JACADS area. Although the organic wastes (including organic-contaminated soil) might be effectively treated by JACADS high-temperature combustion technology, the JACADS RCRA permit currently does not provide for the treatment of any of these “outside” wastes. Therefore, they are likely to be excavated, packaged, and shipped to the mainland for treatment and disposal. The Stockpile Committee believes that the destruction and disposal of these wastes at JACADS should be considered as a way to reduce total taxpayer costs and to reduce potential accidents during transport. Once the destruction of the chemical stockpile at JACADS has been completed, the Army plans to leave the island. To complete the closure of JACADS, the Army must demonstrate to the U.S. Environmental Protection Agency (EPA) that its portion of the island is acceptable for future use. The definition of “acceptable,” however, will depend on the final use of the atoll as a whole and will be based on risk assessments prepared accordingly. These risk assessments, which will describe risks under various exposure and receptor scenarios, will be the technical basis for EPA’s sign off on the end state and cleanup criteria for the entire atoll. The risk assessments cannot be completed, however, until the final end use and end state have been defined. Potential contaminants in the JACADS area that may require remediation include chemical agents, organic chemicals, and heavy metals. The definition of the end state will determine the required level of remediation and the probable cost of closure of JACADS. In other words, EPA will require a definition of the end use of the atoll agreed to by all involved agencies before the nature and extent of the cleanup, including cleanup for JACADS, can be approved. Whichever agency is the final steward of the atoll will have a major voice in that agreement. A decision on the end state of Johnston Atoll will require the participation of at least four federal departments (Commerce, Defense, Interior, and Transportation) and EPA. In the Department of Defense, the Departments of the Army (as the major tenant) and Air Force (current steward) will play lead roles in various aspects of the closure. The Air Force, as the current steward of Johnston Island, will probably not be the agency ultimately responsible for the overall atoll and, therefore, is not in a position to make the final determination of end use. The Defense Threat Reduction Agency (Defense) is responsible for the plutonium on the island. The Federal Aviation Administration (Transportation) operates the runway. The U.S. Fish and Wildlife Service (USFWS) (Interior), which operates the wildlife refuge, may be the final steward of the atoll. 1 NRC (National Research Council). 1998. A Review of Decontamination and Decommissioning Technology Development Programs at the U. S. Department of Energy. Washington, D.C.: National Academy Press.
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Recently, the involved agencies have begun negotiations to turn the atoll over to the USFWS for an expansion of the current wildlife refuge, which has coexisted successfully with the Army’s storage facility for chemical agents and munitions since long before destruction operations began in 1990. Participants in the negotiations have included the National Oceanic and Atmospheric Administration (Commerce), which is concerned about aquatic life in the lagoon, and the U.S. Coast Guard and other agencies, which may have interests in the ultimate use of the atoll. If the atoll is designated surplus property, the General Services Administration will also become involved. If Johnston Island and the surrounding atoll are returned to their natural state, natural processes might be allowed to return the island to a natural ecosystem. The end-state criteria for the Army’s portion of Johnston Island will depend on the end-state criteria for the entire atoll. However, neither the Army nor any other agency seems to have the authority to make the final decision about the long-term use of Johnston Atoll. Nevertheless, the Army will incur costly schedule extensions until the decision is made. If JACADS closure activities are compromised and surveillance and maintenance operations must be continued past the expected closure date, delays will become increasingly expensive. To avoid these costs, the Army could clean the JACADS area to an interim standard agreed to by EPA. However, if further cleanup is required in response to changes in land use after the facility has been vacated, the costs could be very high. The committee believes that unless negotiations with the EPA on cleanup criteria for JACADS are concluded immediately, the Army will not be able to complete closure of JACADS to a final standard. The committee strongly recommends that the Army pursue every option to resolve these issues, including seeking direction at the executive level to coordinate overall closure activities. Respectfully yours, David S. Kosson, Chair Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee)
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