IMPACT OF REVISED AIRBORNE EXPOSURE LIMITS ON NON-STOCKPILE CHEMICAL MATERIEL PROGRAM ACTIVITIES
THE NATIONAL ACADEMIES PRESS
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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance.
This study was supported by Contract/Grant No. W911NF-04-C-0045, between the National Academy of Sciences and the Department of the Army. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the views of the organizations that provided support for the project.
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COMMITTEE ON REVIEW AND ASSESSMENT OF THE ARMY NON-STOCKPILE CHEMICAL MATERIEL DEMILITARIZATION PROGRAM: WORKPLACE MONITORING
RICHARD J. AYEN, Chair,
Waste Management, Inc. (retired), Jamestown, Rhode Island
MARTIN GOLLIN,
St. Davids, Pennsylvania
GARY S. GROENEWOLD,
Idaho National Engineering and Environmental Laboratory, Idaho Falls
FREDERICK T. HARPER,
Sandia National Laboratories, Albuquerque, New Mexico
PAUL F. KAVANAUGH, BG,
U.S. Army (retired), Fairfax, Virginia
TODD A. KIMMELL,
Argonne National Laboratory, Washington, D.C.
LOREN D. KOLLER,
Oregon State University (retired), Corvallis
BRIAN LAMB,
Washington State University, Pullman
BENJAMIN Y.H. LIU,
University of Minnesota (retired), Shoreview
DOUGLAS M. MEDVILLE,
MITRE Corporation (retired), Reston, Virginia
BARBARA PALDUS,
Picarro, Inc., Sunnyvale, California
GEORGE W. PARSHALL,
DuPont Company (retired), Wilmington, Delaware
JAMES P. PASTORICK,
Geophex UXO, Ltd., Alexandria, Virginia
CHARLES F. REINHARDT,
DuPont Company (retired), Wilmington, Delaware
GARY D. SIDES,
Gas Technology Institute, Birmingham, Alabama
LEONARD M. SIEGEL,
Center for Public Environmental Oversight, Mountain View, California
ROBERT SNYDER,
Rutgers, the State University of New Jersey, Piscataway
BILLY R. THOMAS,
Integrated Environmental Management, Inc., Findlay, Ohio
WILLIAM J. WALSH,
Pepper Hamilton LLP, Washington, D.C.
Liaison
Board on Army Science and Technology
HENRY J. HATCH,
Army Chief of Engineers (retired), Oakton, Virginia
Staff
BRUCE A. BRAUN, Director,
Board on Army Science and Technology
NANCY T. SCHULTE, Study Director
HARRISON PANNELLA, Program Officer
JAMES MYSKA, Research Associate
TOMEKA N. GILBERT, Senior Program Assistant
BOARD ON ARMY SCIENCE AND TECHNOLOGY
JOHN E. MILLER, Chair,
Oracle Corporation, Reston, Virginia
GEORGE T. SINGLEY III, Vice Chair,
Science Applications International Corporation, McLean, Virginia
SETH BONDER,
The Bonder Group, Ann Arbor, Michigan
DAWN A. BONNELL,
University of Pennsylvania, Philadelphia
NORVAL L. BROOME,
MITRE Corporation (retired), Suffolk, Virginia
ROBERT L. CATTOI,
Rockwell International (retired), Dallas, Texas
DARRELL W. COLLIER,
U.S. Army Space and Missile Defense Command (retired), Leander, Texas
ALAN H. EPSTEIN,
Massachusetts Institute of Technology, Cambridge
ROBERT R. EVERETT,
MITRE Corporation (retired), New Seabury, Massachusetts
PATRICK F. FLYNN,
Cummins Engine Company, Inc. (retired), Columbus, Indiana
WILLIAM R. GRAHAM,
National Security Research, Inc., Arlington, Virginia
HENRY J. HATCH,
U.S. Army Corps of Engineers (retired), Oakton, Virginia
EDWARD J. HAUG,
University of Iowa, Iowa City
MIRIAM E. JOHN,
Sandia National Laboratories, Livermore, California
DONALD R. KEITH,*
Cypress International (retired), Alexandria, Virginia
CLARENCE W. KITCHENS,
Science Applications International Corporation, Vienna, Virginia
ROGER A. KRONE,
Boeing Integrated Defense Systems, Philadelphia, Pennsylvania
JOHN W. LYONS,
U.S. Army Research Laboratory (retired), Ellicott City, Maryland
JOHN H. MOXLEY,
Korn/Ferry International, Los Angeles, California
MALCOLM R. O’NEILL,
Lockheed Martin Corporation, Bethesda, Maryland
EDWARD K. REEDY,
Georgia Tech Research Institute (retired), Atlanta, Georgia
DENNIS J. REIMER,
National Memorial Institute for the Prevention of Terrorism, Oklahoma City
WALTER D. SINCOSKIE,
Telcordia Technologies, Inc., Morristown, New Jersey
WILLIAM R. SWARTOUT,
Institute for Creative Technologies, Marina del Rey, California
EDWIN L. THOMAS,
Massachusetts Institute of Technology, Cambridge
BARRY M. TROST,
Stanford University, Stanford, California
JOSEPH J. VERVIER,
ENSCO, Inc., Melbourne, Florida
Staff
BRUCE A. BRAUN, Director
WILLIAM E. CAMPBELL, Manager, Program Operations
CHRIS JONES, Financial Associate
DEANNA P. SPARGER, Administrative Coordinator
Preface
The Committee on Review and Assessment of the Army Non-Stockpile Chemical Materiel Demilitarization Program: Workplace Monitoring (see Appendix A for committee members’ biographies) was appointed by the National Research Council (NRC) to evaluate the impact of then newly promulgated or proposed airborne exposure limits (AELs) for nerve agents and mustard on the program of the U.S. Army Non-Stockpile Chemical Materiel Product (NSCMP).
The chemical demilitarization workforce and neighboring populations must be protected from the risk of exposure to hazardous materials during munition disposal operations and during facility closure. To accomplish this, a program must be in place to monitor hazardous materials in and near the workplace and to monitor workers’ activities and health. A previous NRC report examined the programs in place at two stockpile facilities, the Johnston Atoll Chemical Agent Disposal System and the Tooele Chemical Agent Disposal Facility, to monitor concentrations of airborne and condensed-phase chemical agents, agent breakdown products, and other substances of concern. The report concluded that the programs then in place were adequate and recommended the pursuit of improvements in agent monitoring technologies (NRC, 2001c).
Public Law 91-121 and Public Law 91-441 require the Department of Health and Human Services to review Department of Defense plans for disposing of lethal chemical munitions and to make recommendations to protect public health. In the process of meeting these requirements, the Centers for Disease Control and Prevention (CDC) recommended new AELs for nerve agents and published these recommendations in the Federal Register in October 2003 (Federal Register, 2003a). The AELs of the nerve agents were to be monitored starting January 1, 2005. New AELs for mustard were recommended and published in the Federal Register in May 2004 (Federal Register, 2004). Monitoring of mustard will start on July 1, 2005.
The statement of task for the committee was, on its face, limited:
The NRC will establish an ad hoc committee on workplace monitoring at non-stockpile chemical materiel disposal sites and former production facilities. The committee will:
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Review and understand the basis for the Centers for Disease Control and Prevention’s (CDC’s) newly promulgated airborne exposure limits (AELs) for GA (tabun), GB (sarin), and VX and proposed CDC AELs for mustard agent and assess the safety and process implications of these standards.
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Review and become familiar with facility designs and operational procedures:
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For destruction of the former production facility at Newport, Indiana, and
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For the use of the mobile explosive destruction system and the rapid response system.
-
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Assess monitoring technologies in use at the existing non-stockpile sites to determine if they are capable of measuring compliance with short- and long-term AELs and determine the degree to which these technologies can be incorporated into overall program monitoring strategies, particularly for the purposes of process verification and environmental permit compliance.
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If existing monitoring methods are not capable of determining compliance with short- and long-term AELs, evaluate the capability of other monitoring that may achieve the same goal.
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Make recommendations on
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Application of currently used monitoring methodologies to facilitate non-stockpile activities,
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Capability of currently used measurement technologies to meet future monitoring requirements,
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Assessing impacts of newly promulgated AELs on worker and public safety aspects,
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Alternative measures (e.g., increased personal protective equipment and worker safety training
-
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requirements) that may be required to compensate for inabilities to meet standards with existing equipment,
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Impact of relevant monitoring technologies (for new AELs) and effect on ability to implement in time to meet the CWC treaty deadline, and
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The critical path regulatory approval and public involvement issues that may arise in developing such a monitoring program.
In light of this specific charge, the committee accepted the new AELs from the CDC as a starting point for its review of the monitoring program. That is, the committee did not evaluate the process used or the end points selected by the CDC in revising the 1988 limits, nor did it take a position on the appropriateness of the 2003/2004 CDC-recommended AELs. Nevertheless, the committee expresses in Chapter 3 its belief that the new AELs will not achieve any risk benefit. This report contains a significant discussion of the 2003/2004 AELs and the differences between them and the 1988 limits, because understanding the degree of uncertainty in the new AELs was necessary to understand the role of monitoring in implementing them.
This study was conducted under the auspices of the NRC’s Board on Army Science and Technology (BAST). The chair acknowledges the continued superb support of the BAST director, Bruce A. Braun, and the study director, Nancy T. Schulte. Valuable assistance was provided by Harrison Pannella, Tomeka Gilbert, and James Myska of the NRC staff and by the committee members, who all worked diligently on a demanding schedule to produce this report.
Richard J. Ayen, Chair
Committee on Review and Assessment of the Army Non-Stockpile Chemical Materiel Demilitarization Program: Workplace Monitoring
Acknowledgment of Reviewers
This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report:
Barbara Callahan, University Research Engineers and Associates,
Richard A. Conway, Union Carbide Corporation (retired),
Gene Dyer, Bechtel Corporation (retired),
Eugene Kennedy, National Institute for Occupational Safety and Health,
David Mummert, Shaw Environmental, Inc.,
Hyla Napadensky, Napadensky Energetics, Inc. (retired),
Kenneth Shuster, U.S. Environmental Protection Agency,
William Tumas, Los Alamos National Laboratory, and
Calvin Willhite, State of California Department of Toxic Substances Control.
Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by Stephen Berry, University of Chicago. Appointed by the NRC, he was responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.
Figures, Tables, and Box
FIGURES
2-1 |
Former VX production facility at NECD, |
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2-2 |
Level B PPE, |
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2-3 |
Level C PPE, |
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2-4 |
Level D PPE, |
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2-5 |
Structure of VX and EA-2192, |
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2-6 |
Diagram of the EDS-1 vessel on its trailer, |
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2-7 |
Typical EDS deployment layout, |
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2-8 |
Side view of RRS operations trailer, |
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2-9 |
RRS exhaust air filtration system, |
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4-1 |
MINICAMS and DAAMS operating ranges for the 1988/1997 GB AELs and required ranges for the CDC’s 2003 GB AELs, |
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4-2 |
MINICAMS and DAAMS operating ranges for the 1988/1997 VX AELs and required ranges for the CDC’s 2003 VX AELs, |
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4-3 |
MINICAMS and DAAMS operating ranges for the 1988 HD AELs and required ranges for the CDC’s 2004 HD AELs, |
TABLES
ES-1 |
Types of Airborne Exposure Limits, |
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ES-2 |
1988 and 2003/2004 CDC-Recommended Airborne Exposure Limits for the Nerve Agents GA, GB, and VX (2003) and Sulfur Mustard (HD) (2004), |
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1-1 |
Types of Airborne Exposure Limits, |
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1-2 |
1988 and 2003/2004 CDC-Recommended Airborne Exposure Limits for the Nerve Agents GA, GB, and VX (2003) and Sulfur Mustard (HD) (2004), |
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1-3 |
Equivalent Unit Nomenclatures for AEL Concentrations, |
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2-1 |
Types of PPE Currently Employed at the NECD Former VX Production Facility, |
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2-2 |
VX Airborne Exposure Limits (Effective January 1, 2005), |
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2-3 |
Available PPE Approved for Use at the NECD Former Production Facility, |
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2-4 |
General EDS Explosive Containment Vessel Specifications, |
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2-5 |
Usage Data for the EDS, |
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2-6 |
Personal Protective Equipment Levels, |
3-1 |
1988 and 2003 CDC-Recommended AELs and 2003 Acute Exposure Guidelines (AEGLs) for GA, GB, and VX, |
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3-2 |
1988 and 2004 CDC-Recommended AELs and 2003 AEGLs for Sulfur Mustard (HD), |
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4-1 |
TWA Concentrations Reported by Two Different MINICAMS for 1.00-TWA Challenges Made During 4 Weeks of Operation (August 2004), |
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5-1 |
EDS and RRS Containment Features, |
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B-1 |
Inventory of Non-Stockpile Items at the Pine Bluff Arsenal, |
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B-2 |
Inventory of Non-Stockpile Items at Dugway Proving Ground (DPG) and Deseret Chemical Depot (DCD), Utah, |
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B-3 |
Inventory of Non-Stockpile Items at Aberdeen Proving Ground, Maryland, |
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B-4 |
Inventory of Non-Stockpile Items at Anniston Chemical Activity, Alabama, |
BOX
2-1 |
Formation of the G-Analog, |
Abbreviations
ACAMS
automatic continuous agent monitoring system(s)
A/DAM
Agilent/Dynatherm agent monitor
AEGL
acute exposure guideline
AEL
airborne exposure limit
CAIS
chemical agent identification set(s)
CAS
Chemical Abstract Service
CDC
Centers for Disease Control and Prevention
CFR
Code of Federal Regulations
CG
phosgene
CHPPM
(U.S. Army) Center for Health Promotion and Preventive Medicine
CK
cyanogen chloride
CMA
(U.S. Army) Chemical Materials Agency
CPT
chemical process trailer
CWC
Chemical Weapons Convention
CWM
chemical warfare materiel
DA
diphenylchloroarsine
DAAMS
depot area air monitoring system(s)
DCD
Deseret Chemical Depot (Utah)
DET
detonation chamber
DF
binary chemical agent precursor
DM
adamsite
DPE
demilitarization protective ensemble
EA-2192
product of VX hydrolysis
EDS
explosive destruction system(s)
EIS
environmental impact statement
FPD
flame photometric detector
GA
tabun (a nerve agent)
GB
sarin (a nerve agent)
GC
gas chromatograph
GD
soman (a nerve agent)
GDL
gross detection level
GPL
general population limit
GS
diethyl malonate
GTR
German Traktor rocket
H
sulfur mustard
HD
sulfur mustard (distilled)
HN
nitrogen mustard
HT
sulfur mustard, T-mustard combination
HVAC
heating, ventilation, and air conditioning
IDLH
immediately dangerous to life and health
L
lewisite
LAMS
large area maintenance shelter
LOAEL
lowest observed adverse effect level
MASP
mobile analytical support platform
MCE
maximum credible event
MDU
metal decontamination unit(s)
MEA
monoethanolamine
mg
milligram
MINICAMS
low-level, near-real-time air monitor(s)
mm
millimeter
MMD
munitions management device
MPL
maximum permissible limit
MSD
mass spectrometry detector
NaOH
sodium hydroxide
NECD
Newport Chemical Depot
NIOSH
National Institute for Occupational Safety and Health
NOAEL
no observed adverse effect level
NRC
National Research Council
NRT
near real time
NSCM
non-stockpile chemical materiel
NSCMP
Non-Stockpile Chemical Materiel Product
NSCWCC
Non-Stockpile Chemical Weapons Citizens’ Coalition
O,S-DMP
O,S-diethyl methylphosphonothiolate, a by-product in the manufacture of VX
OSHA
Occupational Safety and Health Administration
P&A
precision and accuracy
PD
phenyldichloroarsine
PFPD
pulsed flame photometric detector
PIG
container for shipping CAIS
PINS
portable isotopic neutron spectroscopy
PMNSCM
Product Manager for Non-Stockpile Chemical Materiel
PPE
personal protective equipment
PS
chloropicrin
psig
pounds per square inch gauge
PWS
projectile washout system
QA/QC
quality assurance/quality control
QL
binary chemical agent precursor
RAP
regulatory approval and permitting
RCRA
Resource Conservation and Recovery Act
RCWM
recovered chemical weapons materiel
RD&D
research, development, and demonstration
RRS
rapid response system
SCANS
single CAIS access and neutralization system
SCBA
self-contained breathing apparatus
SDS
spent decontamination solution
STEL
short-term exposure limit
TAP
toxicological agent protective
TP
triphosgene
TPA
triphenylarsine
TRO
diethyl methylphosphonate, an oxidation product of a VX precursor
TSDF
treatment, storage, and disposal facility
TWA
time-weighted average
U.S.C.
United States Code
VCS
vapor containment structure
VX
a nerve agent
WPL
worker population limit
XSD
halogen-selective detector
3X
level of agent decontamination (suitable for transport for further processing)
5X
level of agent decontamination (suitable for commercial release)