Evaluation of Chemical Events at Army Chemical Agent Disposal Facilities (2002)

CALHOUN COUNTY COMMISSION

1702 NOBLE STREET, SUITE 103

ANNISTON, ALABAMA 36201

TELEPHONE (256) 241-2800

FAX (256) 231-1744

COMMISSIONERS

JAMES A. DUNN

District 1

ROSERT W. DOWNING

District 2

JAMES ELI HENDERSON

District 3

RANDY WOOD

District 4

LEA FITE

District 5

KENNETH L. JOINER

Administrator/Treasurer

THOMAS M. SOWA

County Attorney

The Calhoun County Commission respectfully requests that the Committee examine and report on the following issues:

I PROCESS TECHNOLOGY

(A) Modified Baseline: The Commission requests that the Committee assess the validity of deploying the "Modified Baseline" technology, as proposed in Pueblo, Colorado, to the Anniston facility as well as the Tooele, Pine Bluff and Umatilla sites, as referenced in Attachment 1 of the Operations Schedule Task Force 2000 – Final Report (October 20, 2000 §’s 1, 2, 7, 10 and 13).

In the case of "Modified Baseline," it is our understanding that projectiles, with the explosives removed, will be processed and that this will result in significantly larger quantities of agent being treated than the "baseline" technology was designed to accommodate. We understand that little information is available on the impact to the downstream pollution abatement system's capability to handle the larger volumes of offgases, temperature spikes, as well as residence times for agent destruction. Also, it is our understanding this approach creates significantly greater quantities of agent within the system than is contemplated within the "baseline" design, leading to the potential for higher amounts of agent to be released during upset conditions, operational malfunctions, and raising serious questions surrounding steady state operational capabilities, given the delicate air flow balance required between the HVAC and combustion systems. To the

best of the Commission’s knowledge, none of these factors has been addressed in a Safety or Hazard Analysis or in the Health Risk Assessments for ANCDF.

(B) Gelled Rockets: The Commission requests that the Committee assess the validity of the Permit Modification currently under consideration for ANCDF which would allow trial burn processing rates of between 30 to 34 M-55 gelled rockets per hour with no agent draining or explosive reconfiguration prior to processing (i.e.: fully agent loaded, explosive and propellant contained chopped rockets fed to the deactivation furnace.) Under this approach the “unknowns” appear to be even greater in number and potentially more severe from a safety perspective than the “Modified Baseline” concept. In a 1991 report on the Cryofracture method of destruction, the National Research Council state, “Unsteady, very rapid burning of explosives and propellant elements would lead to a variable residence times for agents in downstream components, thus making complete combustion difficult to achieve. The combustion of so many different types of components simultaneously, with the potential for generating undesirable complex gases or solids in the process, plus the strong corrosive nature of the chemical agents make the use of a common kiln a most questionable procedure from the standpoint of both efficiency and safety.” (emphasis added). Demilitarization of Chemical Weapons by Cryofracture: A Technical Assessment; National Research Council; 1991. The modifications being proposed for ANCDF create the exact set of circumstances which were of such deep concern in the NRC Cryofracture report; A single kiln would be processing agent, explosives, propellant and metal parts simultaneously.

These are examples of the types of issues under the “Process Technology” portion of the SOT the Commission requests be addressed by the Committee. A more extensive list may be provided within the two month period of time allotted by the Committee.

II. DESIGN CHANGES:

(A) Isolation Valves (Knife Gates): The Commission would like the Committee to include a recommendation on whether the inclusion of isolation valves at ANCDF is an appropriate modification of the incinerator from a safety and operational perspective. Subsequent to the release of agent GB at Tooele on May 8 and May 9, 2000, PMCD implemented the incorporation of a Control Room operated isolation and air (bleed) intake valve in the ducting between the DFS kiln and the Afterburner (AFB) to prevent unburned agent from escaping to the Pollution Abatement System and then out the common stack. (Approval for Restart of the Deactivation Furnace Letter from Utah DEQ to Commander, Deseret Chemical Depot; Item EG&G #12/Army #5; page 3; September 18, 2000). According to the above referenced document, “the valve has been function tested and is operational.”

A similar design modification has been incorporated into the ANCDF. The Commission requests the Committee to consider the process flow implications of this modification of the incinerator in regard to the potential backpressure which could occur should the valve have to be deployed; as well as the characterization, route and final disposition of the air that would be released through the “air bleed” action and other

associated impacts on process flow as a result of this design change. Specifically, the Commission would like to know the answer to the following questions: What kind of backpressure will be created when the operator drops the gate? What happens? It would appear to the Commission that the air has to go somewhere.

(B) Safety or Hazard Analysis: The Commission also would like to know if a Safety or Hazard Analysis has been done for this isolation valve design change and whether there are any Health Risk Assessment implications concerning this particular modification.

These are two examples of the types of issues under the “Design Change” portion of the SOT the Commission requests be addressed by the Commission. A more extensive list of additional design change issues may be provided within the two month period of time provided by the Committee.

III MANAGEMENT

(A) The Commission requests the Committee include within its management review the issues raised and conclusions reached in the following reports: all GAO Reports between 1990 – 2000; Overarching Issue Assessment Annual Report for FY 1998 (December 7, 1998); Array I.G. Report – “Command and Control Structure at Current and Future Army Chemical Storage and Demilitarization Sites (March 23, 1998); Report submitted to Congress by Undersecretary of Defense Gansler on behalf of Secretary of Defense Cohen (Report of the Secretary of Defense to the Congressional Defense Committees on the Management of the Chemical Demilitarization Program, April 2000).

These are examples of the types of documents and the issues under the “Management” portion of the SOT the Commission requests be considered by the Committee. A more extensive list may be provided within the two month period of time provided by the Committee.

IV TOXICITY RISK MANAGEMENT AND SAFETY PROGRAMS

(A) Acute Agent Toxicity: The Commission requests the Committee include within its Risk Management and Safety Review the latest information available on acute agent toxicity available from all of the NRC Committees which have examined this issue. In particular the Commission requests the Committee to focus on the acute agent toxicity information included in the NRC report, “Review of Acute Human-Toxicity Estimates for Selected Chemical-Warfare Agents” (National Academy Press; 1997) and the Anny’s CDEPAT Report, “Review of Existing Toxicity Data and Human Estimates for Selected Chemical Agents and Recommended Human Toxicity Estimates for Selected Chemical Agents and Recommended Human Toxicity Estimates Appropriate for Defending the Soldier” (1994). Additionally, the Commission asks the Committee to incorporate into this section a Review and Finding on the Chemical Warfare Agent sections of EPA’s proposed “Acute Exposure Guideline Levels for Hazardous Substances; Proposed AEGL

Values” (Federal Register/Vol.66, No.85/Wednesday, May 2, 2001; pages 21940 – 21964).

(B) Low Level Exposure of Agents: The Commission also requests the Committee include within its Risk Management and Safety Review the incorporation of the latest information available on the impact of low-level exposure of agents. The Commission requests this review include, but not be limited to, the issues raised in “DoD Strategy to Address Low-Level Exposures to Chemical Warfare Agents” (May 1999).

(C) Hazardous Waste Combustion: The Commission requests the Committee include a review of the 1999 National Research Council report, Waste Incineration and Public Health, which made an assessment of the relationship between hazardous waste combustion and human health; the design, citing and operating conditions of combustion facilities; an overview of human exposure to pollutants the risk assessments and other methodologies used to measure potential exposures. The report notes that “Some of the available assessments may now be considered inadequate for a complete characterization of risk, for example, due to their failure to account for changes in emissions during process upsets, or because of gaps in and limitations of the data or techniques of risk assessment available at the time.”

(D) Hazardous Waste Emissions: The Commission requests the Committee include a review of EPA’s June 1998 document, Development of a Hazardous Waste Incinerator Target Analyte List of Products of Incomplete Combustion, which concluded that current sampling methods for characterizing hazardous waste incinerator emissions “provide an incomplete picture of the emission profile,” and that a large number of products of incomplete combustion (PICs) remain unidentified; therefore the health effects of these compounds are unknown.

These are examples of the types of documents and the issues under the “Risk Management and Safety Review” portion of the SOT the Commission requests be considered by the Committee. A more extensive list may be provided within the two month period of time provided by the Committee.

V IMPROVEMENTS TO OPERATIONAL ACTIVITIES

(A) ACAMS/DAAMS: The Commission requests the Committee investigate the inadequacies of the ACAMS/DAAMS monitoring system with a particular emphasis on the DAAMS analysis agent confirmation methodology deployed by PMCD.

(B) Real Time Monitoring: The Commission requests the Committee consider the fact that Continuous Emissions Monitoring System (CEMS technology) exists in the method known as “EPA Method TO-16: Long-Path Open-Path Fourier Transform Infrared Monitoring of Atmospheric Gases” and other advanced real-time monitoring systems. (i.e., real time online MS/MS systems). This technology is a critical component of a proper safety regimen, and we request that you review and made a recommendation on the applicability of this technology for ANCA.

These are examples of the types of issues under the “Improvements to Operational Activities” portion of the SOT the Commission requests be considered by the Committee. A more extensive list may be provided within the two month period of time provided by the Committee.

VI INPUT BY CITIZEN GROUPS

(A) Chemical Events:

1. Identifying Events to be Reviewed: There is a high degree of skepticism in communities where chemical stockpiles are located that many “incidents” are not being disclosed to the public and that the decision by PMCD on whether or not to have these incidents formally characterized as “chemical events” is often based on the potential negative impact on the program’s image rather than the actual circumstances surrounding the incidences. The Commission therefore requests that the Committee insure the lists of “incidents” that have complied by these citizen groups be compared with the list of “Chemical Events” provided to the Committee by PMCD.

2. Agent Releases: In addition to the broader definition of a “Chemical Event” (wherein agent escapes “engineering controls”) the Commission also requests an in-depth review of actual releases from JACADS and TOCDF that have been documented by citizens groups, as well as those identified as potential releases or potential releases by citizens groups but denied by PMCD. A few examples of these potential releases:

   1. August 26, 1996: TOCDF initiated operations and the facility was shut down within 24 hours due to what citizens believe was an agent release from the HVAC filter area;

   2. October/November 1997: Information concerning major computer problems at TOCDF and related incidents was communicated to citizen groups. No incident reports were released to the public although numerous common stack alarms were said to have gone off during the period.

   3. March 30, 1998 Incident: On July 23, 1999 the NRC Stockpile Committee was supplied with more than 1000 pages of data on the March 30, 1998 incident at TOCDF with the assurance that this incident would be investigated and reported on. To date no such investigation or report has been made public.

   4. June 4, 1999 Incident: A global power outage occurred at TOCDF. The automatic back-up power system failed and was not brought on line until 25 minutes after power outage. Documents indicate negative pressure capability during power loss can only be maintained for approximately 10-12 minutes; however, TOCDF was without power for 25 minutes. A memo in response to a Senate inquiry of the incident states that power was restored in 12 minutes, but the internal PMCD document

written immediately after the incident states the facility was without power for 25 minutes.

5. December 9, 2000: A HVAC filter bank experienced agent breakthrough at TOCDF. The ACAMS reading was 3.01 TWA.

6. 2001: Public information on TOCDF operations has decreased noticeably since the September 2000 House Armed Services Procurement Subcommittee Hearings on the May 8^th, 2000, agent release at TOCDF. Information from sources at TOCDF indicate continued DFS feed gate problems, several slag fires in the LIC and other possible incidents of potential agent releases. The Commission requests that the Committee review actual logs and CON operations reports and not rely strictly on incident lists provided by PMCD in determining whether or not there is any validity to these allegations.

(B) Exposure and Medical Treatment for Workers: Citizen groups remain concerned about the impacts of low-level and other levels of exposure to workers at the CDF’s, although the PMCD continues to publicly state that “no worker has ever been exposed to agent.” The Commission shares the concerns of these citizen groups.

A few examples of the low level and other levels of exposure to workers at the CDF’s which the Commission respectfully requests the Committee examine and report on are:

1. November 1996: A NREMT/Health Technician at TOCDF has alleged to have been harassed by plant supervisors for suggesting suspected organophosphate poisoning of TOCDF workers based on the technician having observed increased numbers of bradycardias (slow heart rates) and atrioventricular blocks (delays or block in cardiac electrical conduction) amongst these TOCDF workers.

2. April 1997: Two workers at TOCDF apparently were exposed to agent while in the TMA. After being decontaminated and stripped down to their underwear, ACAMS alarms still rang off above non-zero levels. Exact ACAMS levels remain unknown.

3. April 1997: A JACADS Clinical Lab Technician sent a letter to the U.S. Senate alleging worker safeguards at the facility were being ignored and covered up by contractors.

4. May 26, 1999: TOCDF – Occurrence Report No: 99-05-26-A1: After repeated decontamination and stripping down to bare skin of four workers ACAMS alarms continued to ring off in the “B” airlock.

5. April 11, 2000: A RDC Investigation Report prepared April 18, 2000 stated that, during an emergency exercise, medical personnel on JACADS were

potentially exposed to agent but were not decontaminated and, according to affidavits, told not to report the incident.

The Commission requests these incidents be closely examined and investigated because recent scientific evidence indicates low-level non-acute exposures to nerve agents can cause long term health problems. There is also evidence which strongly suggests that blood sampling (the method used by PMCD to determine worker exposure), may not be an inadequate method for confirming whether or not workers have been exposed to agent.

(C) Army Audit Agency (AAA) Report: The Commission requests the Committee review the more than 3000 design changes noted in the AAA Report with particular attention to the lack of assessment of the effect of these design changes on operations. Modifying components within the overall design of the plants without consideration of their impacts on up or down stream functional capability would appear to contradict sound management policy and could be potentially dangerous from an operational standpoint.

According to the “Production Milestones” section of the SOT, a “Report Outline” is already done and a “Concept Draft” is due in just 14 days. The Committee has assured Congressman Riley and his staff that Alabama citizens will be involved in the front and back ends of the Committee’s efforts, as in inputting into the scope and issues they would like the Committee to investigate. How is it that the Outline is already done and the Draft will be completed in 2 weeks, particularly in light of this meeting being the first opportunity for the Commission and local citizens to present matters to the Committee?