THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
Board on Army Science and Technology
Mailing Address: 500 Fifth Street, NW Washington, DC 20001 www.nationalacademies.org
January 7, 2010
Mr. Conrad F. Whyne
Chemical Materials Agency
5183 Blackhawk Road Edgewood Area Aberdeen Proving Ground, MD 21010-5424
RE: Letter Report on Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System
Dear Mr. Whyne:
The Chemical Materials Agency (CMA), under your direction, requested the National Academies’ Board on Army Science and Technology to examine the current state of closure activities for the Tooele Chemical Agent Disposal Facility (TOCDF) and the Chemical Agent Munitions Disposal System (CAMDS). In this brief interim report, the Committee on Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System addresses some of the issues pertaining to closure at the TOCDF and CAMDS facilities. It also provides insights into what the committee believes are important parameters to ensure the success of the CMA’s closure program for these and CMA facilities at other locations. As indicated in the statement of task for the committee (see Attachment A), this interim report is to be followed by another report, referred to hereinafter as “the full report,” which will use these parameters to conduct a comprehensive assessment of closure activities and issues.
For this interim report, the committee examined the current status of closure plans for both the TOCDF and CAMDS based on presentations by key members of your staff and the systems contractor. It then developed a set of parameters based on this high-level evaluation that it believes are important in ensuring a consistently effective approach to the closures of the four currently operating CMA chemical agent disposal facilities. The committee also assessed regulatory requirements imposed by the state of Utah, where TOCDF and CAMDS are located.
TOCDF and CAMDS are totally different facilities with different missions and different life cycles. They are located at Deseret Chemical Depot (DCD) near Tooele, Utah, and share the same systems contractor for closure. Likewise, both are under the jurisdiction of the same Utah state regulatory authorities and share many of the same regulatory challenges. They are often viewed by the public as one facility. At present, it is
anticipated that both facilities will stay under Army control after closure as part of the nearby Tooele Army Depot.
TOCDF is a large, active facility where disposal operations for mustard agent munitions and ton containers will continue until well into 2011. In addition to the baseline facility, a small skid-mounted liquid combustion unit, complete with a pollution abatement system, is being designed and will be constructed in the adjacent munitions storage area known as Area 10 to dispose of small quantities of the nerve agent tabun (GA) and lewisite. It is further anticipated that an explosive destruction technology chamber will be brought on-site to handle mustard agent munitions referred to as “rejects,” which present problems for processing through the TOCDF disassembly and destruction processes. A further complication affecting the closure of TOCDF is the approximately 2 million pounds of legacy secondary wastes in storage that must be managed and disposed of during closure operations.
Closure planning for TOCDF, including the disposal of legacy wastes and the planning for the new units noted above, is presently at an early stage. While a general closure plan was initially submitted as part of the initial permit application for TOCDF, a more detailed closure plan is expected to be submitted to the state for TOCDF in June 2010. This and other information on the use of specific processes and analyses will be the subject of the full NRC report, to be prepared. Discussions with the state of Utah Department of Environmental Quality (UDEQ) are already under way to identify challenges that will eventually be addressed in the more detailed closure plan.
The closure of CAMDS is at an entirely different stage, and except for the laboratories (discussed below), CAMDS is no longer operational. It was the pilot facility for the U.S. Army’s chemical demilitarization activities and operated between 1979 and 2005. The CAMDS site encompasses 61 hazardous waste management units, a ventilation system, and a number of buildings, some of which were used in testing equipment for chemical agent destruction processes. Initial closure activities were carried out by personnel affiliated with the Tennessee Valley Authority, who have recently been replaced by the TOCDF systems contractor, the EG&G Division of URS Corporation. Closure has progressed, with some equipment already removed from the buildings. More detailed closure plans are being written for CAMDS, and their approval is being requested on a unit-by-unit basis from the UDEQ. Final closure is expected to be completed by the first quarter of 2012. The main challenges associated with CAMDS closure stem from its age, its use as a pilot facility, and to the site having many interconnected buildings and common utility services whose closure requires careful staging.
Laboratory capabilities at CAMDS are being upgraded and will be used throughout the remaining disposal operations at DCD and the closure campaigns for CAMDS and TOCDF. It is anticipated that the laboratory closure will take place in 2015.
The committee is not aware of any current detailed closure plans for the laboratory. The committee spoke with the chair of the Citizens Advisory Commission (CAC), who indicated that the CAC fully understands that the closures of the TOCDF and CAMDS facilities are a separate issue from the disposition of other solid waste management units (SWMUs) on the site that will require remediation. The CAC chair further indicated that at this time closure has not yet become an important issue except
for concern about loss of jobs. The Army and community have not so far developed a plan for community involvement during closure.
The committee also spoke with members of the UDEQ that oversee compliance with state hazardous waste laws and requirements. In its exercise of regulatory jurisdiction over the TOCDF and CAMDS, the state of Utah developed some unique regulatory requirements.1 Authority to regulate hazardous waste facilities and closure under the Resource Conservation and Recovery Act (RCRA) was delegated to the state by the federal Environmental Protection Agency (EPA). Utah requirements generally adhere to all the EPA RCRA regulations, but in addition to these, waste listings specific to chemical agent operations have been added to the regulations. That is, “Nerve, Military and Chemical Agents” is a class of materials listed as acute P999 hazardous waste. “Residues from Treatment and Testing of Nerve Military and Chemical Agents” are a class of materials listed as F999 hazardous waste. In addition, all wastes that have been potentially exposed to agent liquid or vapor are considered a P999 or F999 “listed waste.” Any hazardous waste that meets the waste control limits (WCL) for agent by chemical analysis is an F999 waste that, on a case-by-case basis, can be considered for shipment off-site for additional treatment if necessary and subsequently sent to a hazardous waste landfill. Used (spent) activated carbon poses a particular challenge in this regard because Utah considers any activated carbon from chemical agent disposal operations, whether or not it was actually exposed to one or more chemical agents, to be a P999 waste that must be treated on-site. Utah’s practices for chemical agent wastes and residues are atypical within Utah; commercial hazardous wastes within the state are not so regulated. That is, these practices are considered more restrictive and may impede the efficient disposition of wastes and the closure of the TOCDF and CAMDS sites.
In this interim study, the committee also considered prior closure experiences for three other chemical agent disposal facilities: the prototype baseline Johnston Atoll Chemical Agent Disposal System on Johnston Island in the Pacific Ocean and the hydrolysis-based facilities in Aberdeen, Maryland, and Newport, Indiana, where, respectively, bulk mustard agent and VX nerve agent were destroyed. In doing so, the committee remained mindful of the differentiating characteristics of these facilities in relation to TOCDF and CAMDS. After evaluating these earlier closures and the closure planning to date for TOCDF and CAMDS, the committee identified parameters that are key to the successful closure of the still-operating CMA facilities. These are discussed in more detail in Table 1 of the main body of this interim report, which follows the committee’s findings and recommendations.
FINDINGS AND RECOMMENDATIONS
Finding 1. The Tooele Chemical Agent Disposal Facility operates with a strong safety culture, but this admirable approach to safety as an overriding parameter was not
sufficiently emphasized in either the briefings the committee received or the Programmatic Closure Planning document.
Recommendation 1. The management of the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System should consider safety the primary value in all of its decisions and work activities, and it should make its commitment to a safe operation highly visible to all workforce personnel and site visitors.
Finding 2. Parameters and metrics provide important guidance for planning, organizing, and implementing efficient closure of chemical demilitarization sites.
Recommendation 2.The Army should consider the parameters and metrics presented in Table 1 (in the main body of this report) as it plans for the closure of the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System.
Finding 3. As deconstruction activities proceed over the course of closure operations at the Chemical Agent Munitions Disposal System and the Tooele Chemical Agent Disposal Facility, a separate workforce will be on-site specifically to conduct demolition. This situation raises the possibility that safety performance could degrade because the new demolition workforce may be unfamiliar with the dangers of agent and agent degradation products and unfamiliar with the background circumstances regarding any demolition work done before its arrival.
Recommendation 3. The Tooele Chemical Agent Disposal Facility/Chemical Agent Munitions Disposal System management should establish a cross-training and hazards familiarization program to ensure continued strong safety performance and effective utilization of personnel.
Finding 4. The Utah Department of Environmental Quality (UDEQ) and the Army and contractor continue to have good relations. Some UDEQ regulatory practices differ from those in force for commercial hazardous waste management facilities in Utah and, in some cases, in other states that host chemical demilitarization facilities. All wastes from agent operations are considered listed wastes even if there is only a potential for exposure to vapor, and they often require treatment on-site to meet waste control limits before they are transported off-site and ultimately disposed of in a hazardous waste landfill.
Recommendation 4. The Army should negotiate risk-based criteria based on attainable waste control limits with Utah Department of Environmental Quality to establish the reuse, recycling, on-site treatment, off-site treatment (if necessary), and off-site disposal for all major waste streams—especially metal, activated carbon, and concrete.
Finding 5a. The Army and its contractor have been planning for the Tooele Chemical Agent Disposal Facility closure for some time. Plans are to submit a request for a Resource Conservation and Recovery Act (RCRA) permit modification that will establish details for meeting relevant regulatory requirements applicable to the closure plan by June 2010. Although some early closure activities have been initiated as approved partial
closure authorizations under RCRA, formal closure operations of the munitions demilitarization building are expected to begin in September 2011, with closure of the metal parts furnace and liquid incinerators later on (mid-2013) to allow their availability for continued waste processing, including closure waste processing. The committee finds this schedule optimistic.
Finding 5b. Based on the information provided in the basic closure plan of the current permit, which will be combined into a single permit covering both the Chemical Agent Munitions Disposal System and the Tooele Chemical Agent Disposal Facility, there appears to be sufficient time to meet the Army’s indicated milestones for closure of the Chemical Agent Munitions Disposal System.
Recommendation 5. The Army should confirm with the regulators their willingness to consider partial closure with attendant more detailed closure plans and permit modifications. It should establish a realistic accelerated schedule for submitting its Tooele Chemical Agent Disposal Facility Resource Conservation and Recovery Act Closure Plan to ensure that closure operations are not delayed.
Finding 6. At the time of this report, it is anticipated that the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System sites will be closed to an industrial use specification and have an end use that involves becoming part of the Tooele Army Depot. Still, a risk-based closure performance standard that would reflect an industrial end use, in the form of specific concentrations of specific constituents in the various waste types and media, has not been negotiated. It is also unclear whether analytical methods have been approved in Utah that are capable of measuring the analytes at the selected performance standard.
Recommendation 6. The end use for the Tooele Chemical Agent Disposal Facility and Chemical Agent Munitions Disposal System sites should remain as defined at the start of closure planning to avoid extensive delays. The Army should expedite its discussions with Utah Department of Environmental Quality on specific risk-based closure performance standards that must be achieved. Further, if necessary, the Army should expedite its effort to gain approval of analytical methods.
Finding 7. The risk of exposure to chemical agents during closure operations is expected to be significantly lower than what potentially could be encountered during agent disposal operations. The regulatory standards and practices used by the state of Utah for controlling agent-contaminated materials were developed early in the program when there was little experience with managing the risks of materials exposed to agent. These practices and regulations may be more restrictive than necessary considering the nature of the closure operations.
Recommendation 7. The Army should evaluate the reduced risk of exposure to chemical agents and their degradation products from closure operations and waste materials in view of Utah’s restrictive regulatory practices and consider negotiating with the Utah
regulatory community to obtain less restrictive, but safe, regulatory practices that allow for more efficient closure operations.
Finding 8. Through the Citizens Advisory Commission, Outreach Office, and other forums, the Army has created a successful public participation program. The Army and community have not developed a plan for community involvement during closure.
Recommendation 8. The Army should discuss with the Citizens Advisory Commission ways to establish a continuing, constructive public involvement between the end of demilitarization and formal closure.
Finding 9. A comprehensive Lessons Learned program for operations has been implemented by Tooele Chemical Agent Disposal Facility (TOCDF) management, and is also being applied to the TOCDF and the Chemical Agent Munitions Disposal System closure. For example, a comprehensive worker retention program for use during closure operations is in place.
Peter B. Lederman, Ph.D.,
Committee on Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System