I. GENERAL COMMENTS
The Kentucky Chemical Demilitarization Citizens Advisory
Commission (CAC) expresses its support for the approach being taken by the
Assembled Chemical Weapons Alternatives program (ACWA), the Blue Grass Army
Depot, (BGAD) and Bechtel Parsons Blue Grass (BPBG), in seeking a Research,
Development and Demonstration Permit for the destruction of the chemical weapons
stored in the Commonwealth.
The CAC also expresses it support for the issuance
of such a permit by the Kentucky Environmental and Public Protection Cabinet’s
Division of Waste Management (Cabinet) and its concurrence with the reasons
listed on page 2 of the “Fact Sheet” accompanying the Draft.
The CAC also wishes to acknowledge the Cabinet’s diligence
in preparation of the current draft.
The CAC wishes to emphasize the unique circumstances
associated with endorsing this action and to state unequivocally that this
should not be viewed as a precedent in regards to any other hazardous waste
treatment permit applications within the Commonwealth in the future.
The Chemical Weapons stored in Madison County are
not only unique insofar as they are weapons of mass destruction, separating
them from any and all other types of hazardous waste, but additionally, the
United States is under obligation to destroy these materials in compliance
with the international Chemical Weapons Convention (CWC), signed in April
1997.
The CAC also supports the modification of the current
hazardous waste permit held by BGAD to include the storage of chemical munitions
and related hazardous waste, based on the understanding that the storage period
is finite as required in the CWC and other federal laws which specifically
prohibit the importation of any additional chemical munitions and/or agents,
as defined within the CWC, into the Commonwealth.
The CAC believes that the incorporation of the Compliance
Schedule as a means to facilitate the expeditious execution of disposal of
these materials is an appropriate and responsible approach.
Finally, the CAC recognizes and appreciates the efforts
put forward by the Cabinet and the Permittee(s) in regards to public involvement
in the process, the transparency and information sharing that has occurred
thus far and the extra time and effort taken to inform and gather input from
the CAC, the Chemical Destruction Citizens Advisory Board (CDCAB) and the
general public.
II. SPECIFIC COMMENTS
A. Part I
The CAC concurs with all sections
in Part I of the Draft.
Part II
Condition No. T-8 Waste Streams: Secondary Waste.
COMMENT: As noted on page 3 of the accompanying
Fact Sheet, secondary waste codes N001, N002, and N003 are chemical agents
GB, VX and Mustard (H) respectively. It is stated in the Fact Sheet
that the identified wastes, including N001, N002, and N003 will be “disposed
of off-site.” Condition T-8 also identifies these wastes by the same
codes.
The CAC is concerned that the permit will therefore
allow off-site shipment of secondary waste, which may include detectible levels
of these agents, and opposes any such shipment.
The CAC is concerned about the treatment of liquid
effluent from the SCWO process that may contain heavy metals. The CAC
urges, in the strongest terms possible, that any liquid effluent containing
heavy metals be dried on-site and the end product shipped to a permitted TSDF.
Under no circumstances should any effluent containing
heavy metals be processed in a wastewater treatment facility either on or
off-site. The CAC notes this is the position stated in § 11.3 of the
permit application.
Condition No. T-10 Thermal Treatment:
COMMENT: The CAC understands that the HDC has
been deleted from the plant (Design Change # 2) based on the possibility of
M-55 rocket separation, prior to disposal operations (Design Change # 43
A). Clarification on the HDC is sought, specifically in regards to PCB-contaminated
components of the M-55 rockets.
If PCB-contaminated material is going to be processed
in with the HDC or the MPT, the CAC notes the requirement of a TSCA permit.
Condition No. T-11 Stack Emission Limits:
COMMENT: § (1) In regards to the conditions
use of the terms “confirmed” and “detectable” regarding agent emissions, the
CAC is concerned with both the process used by the Army in designating any
release as “confirmed” and requests the Cabinet to investigate and make an
independent determination as to the adequacy of the confirmation process as
part of its duties to protect the public.
In regards to the levels currently “detectable” the
CAC is concerned with the state of the monitoring equipment currently used,
and planning to be used, in the BGAD CLA and at the BGCAPP. A more detailed
explanation of these concerns are contained in section III “Other Comments
– Monitoring Equipment and Capability” below.
§ (2) The CAC notes the reference to “Monitoring
Plan” being listed in the Compliance Schedule, Appendix B. However there
is no such Monitoring Plan section contained the Compliance Schedule, Appendix
B. The CAC requests this requirement be added to the Compliance Schedule.
The CAC also seeks a copy of the Monitoring Plan referenced
in this section once it is submitted to the Cabinet. The CAC is concerned
with the state of the monitoring equipment currently used, and planning to
be used, in the BGAD CLA and at the BGCAPP.
Condition No. T-13 Community Emergency Preparedness:
COMMENT: The CAC notes that KRS 224.50-130 (3)
(c) provides for, in addition to “the capability of removing individuals from
the largest area at risk from a worst-case release,” the option of “[o]r otherwise
mitigating exposure for all individuals that might be exposed to releases
from the facility.”
The CAC would recommend this language be inserted
in condition T-13 to provide consistency between the permit condition and
the KRS.
Condition No. T-16 Waste Analysis Plan:
COMMENT: The CAC questions why the Waste Analysis
Plan, required via the Compliance Plan, Appendix B, states that the “analytical
procedures, including QA/QC” would direct such a plan “not to include the
target release levels.”
The CAC believes such procedures should include target
release levels. The CAC wishes to be provided the Waste Analysis Plan upon
its being submitted to the Cabinet.
Condition No. T-22 Job Description and Training:
COMMENT: § (b] The CAC requests the following
be added to § (b), “and only those individuals demonstrating the proper
qualifications, or being able to receive the proper training to be qualified
in time to assume their responsibilities as identified in the job description,
be assigned to each position.”
Condition No. T-24 General Requirements
for Ignitable, Reactive, or Incompatible Wastes.
COMMENT: The CAC questions the ability of the
Rocket Shear Machine (RSM) (Appendix A #18) to meet this condition, given
the recent events at UMCDF and PBCDF.
The CAC recommends consideration of an alternative
method for accessing various components of the M-55 rocket for disposal.
This comment assumes Design Change 43(b) is not executed against.
Condition No. T-37 Contingency Plan and Emergency
Response: Evaluating Release.
COMMENT: The CAC believes that the current monitoring
equipment is incapable of meeting this permit condition. The CAC is
concerned with the state of the monitoring equipment currently used, and planning
to be used, in the BGAD CLA and at the BGCAPP.
A more detailed explanation of these concerns are
contained in section III “Other Comments – Monitoring Equipment and Capability”
below.
Condition No. T-39 Contingency Plan and Emergency
Response: Notify Off-Post Emergency Responders.
COMMENT: § (1) The CAC believes that the
current monitoring equipment is incapable of meeting this permit condition
and that the Emergency Coordinator will not be able to “determine that the
facility has had a release” at levels “which could threaten human health or
the environment outside the facility” depending on such monitors.
The CAC is concerned with the state of the monitoring
equipment currently used, and planning to be used, in the BGAD CLA and at
the BGCAPP.
A more detailed explanation of these concerns are
contained in section III “Other Comments – Monitoring Equipment and Capability”
below.
Condition No. T-47 Manifest System: General Requirements.
COMMENT: The CAC recommends that the following
be inserted into T-47.
§ (2) Any facility identified as permitted and
contracted to receive and handle the waste described in the manifest shall
be made known to the public.
§ (3) any alternative facility designated on
the manifest shall be identified to the public.
§ (4) The Permittee shall not have the authority
to “designate another facility” to receive hazardous waste from BGCAPP that
is not on the original manifest.
Condition No. T-51 Record-keeping and Reporting:
Operating Record.
COMMENT: The CAC recommends that as part of
the permit conditions all BGCAPP operating records as identified in T-51
be posted on the ACWA web site in a timely fashion (i.e., within 24 hours).
Additionally, the CAC requests that additional information,
as identified in section III “Other Matters – Information Sharing” be posted
on the ACWA web site in the time frames identified.
Condition No. T-53 Record-keeping and Reporting:
Annual Report.
COMMENT: The CAC recommends that as part of the permit
conditions the Hazardous Waste Annual Report be provided to the CAC at the
same time it is provided to the Cabinet. The Annual Report should also be
placed in the appropriate repositories throughout the Commonwealth (i.e. Public
Libraries).
Condition No. T-55 Record keeping and Reporting:
Additional Reports.
COMMENT: The CAC recommends that as part of
the permit conditions the Additional Reports, identified in this section,
be provided to the CAC at the same time they are provided to the Cabinet.
The Additional Reports should also be posted on the ACWA web site in a timely
manner after submission to the Cabinet (i.e., within 24 hours).
Condition No. T-64 Management of Hazardous Waste
in Containers: Capacity.
COMMENT: The CAC seeks an explanation as to the volume
noted in Appendix C, #16 (3,210,000 gallons) for the storage of Hydrolysate
at the BGCAPP.
The CAC notes that the Newport, Indiana disposal plant
contains 1,269 tons of chemical agents slated for neutralization, with a predicted
on-site storage or off-site shipment of approximately 4,000,000 gallons of
Hydrolysate.
The BGCAPP will treat approximately 523 tons of agents,
which by ratio would produce approximately 1,665,605 gallons of hydrolysate.
The capacity noted in Appendix C is almost double for BGCAPP than that at
Newport. What is the basis for arriving at this capacity?
B. Part III
Condition No. T- 106 Definitions: “Facility.”
COMMENT: The CAC notes this condition may be modified
in connection with Design Change #25, and supports this proposed change.
Condition No. T- 113 Duties and Requirements: Duty
to Reapply
COMMENT: The CAC requests clarification in regards
to the reapplication process for the RD&D permit. Regarding the Storage
permit, it is clear its expiration date is 30 September 2104. However,
the RD&D permit is “only for nerve agent GB.”
Subsequent to the end of the GB campaign (180 days
prior, according to T-113 (2)) the Permittee shall submit a renewal application.
Please address the following questions in the response
to comments:
1) Can the Permittee submit a series of renewal applications
for additional time within the initial RD&D permit for the VX and H campaigns?
2) If not, will a separate RD&D permit be required
for each campaign? Or;
3) Will the Cabinet require a Part B RCRA permit for
the VX and H campaigns?
Condition No. T- 118 Duties and Requirements: Duty
to Allow Entry and Inspection.
COMMENT: The CAC understands that at other chemical
disposal facilities, the state regulatory authority has a constant presence
during agent operations. The CAC recommends the Cabinet to adopt this
posture in regards to oversight at the BGCAPP.
Condition No. T- 125 Duties and Requirements: Immediate
Notification
COMMENT: § (2) (b) The CAC believes that
the current monitoring equipment is incapable of meeting this permit condition.
The CAC is concerned with the state of the monitoring equipment currently
used, and planning to be used, in the BGAD CLA and at the BGCAPP.
A more detailed explanation of these concerns are
contained in section III “Other Comments – Monitoring Equipment and Capability”
below.
Condition No. T- 128 Duties and Requirements: Duty
to Report Non-Compliance Not Previously Reported.
COMMENT: The CAC recommends a specific time
frame for reporting such Non-Compliances from the time of their discovery
by the Permittee be incorporated in this condition. Any such reports should
also be posted on the ACWA web site within 24 hours of submission to the
Cabinet.
C. Appendix A “Hazardous Waste Management
Units”
COMMENT: The CAC recognizes that the ongoing
Design Change Process has, and may continue to, modify the Units listed in
Appendix A (i.e.: #’s 21 and 28). Updated lists of Hazardous Waste Management
Units should be provided in a timely fashion following such changes.
D. Appendix B “Compliance Schedule”
COMMENT: The CAC, with the few exceptions noted
above (i.e.: Monitoring Plan omission), endorses and supports the items and
timeframes noted in the Compliance Schedule and feels the Cabinet did a through
job in ensuring proper oversight of the BGCAPP path forward.
III. OTHER COMMENTS
A. Agent Monitoring
COMMENT: The CAC notes the long and thus far unproductive
discussion between the government and the public regarding the need within
the chemical weapons disposal program for deployment of upgraded and advanced
agent monitoring systems.
In that regard, the CAC has attached several documents
associated with this need from citizens groups, the United States Congress
and the National Research Council. (Appendix A)
The CAC urges, in the strongest terms possible, the
Cabinet to include within its Storage and RD&D permit, specific requirements
for advanced monitoring capabilities as a condition of issuance of such permits.
The CAC believes this requirement can be reasonably included in the Compliance
Schedule and urges a time frame of deployment of not more than one year from
the date of issuance for such action to be taken.
B. Off Site Treatment of Hydrolysate
COMMENT: The CAC wishes to differentiate between its
prior concurrence with Design Change # 35, Off-site Shipment of Wood Dunnage
and other secondary wastes, and its strong opposition to Design Change # 34,
Off-site Shipment of Hydrolysate. Any inference drawn from the comments contained
herein and the CAC’s endorsement of off site shipment of hydrolysate is in
error. The CAC unequivocally opposes such action.
Additionally, the CAC recommends all brines be dried
on-site to reduce the amount of liquid waste leaving BGAD.
C. Public Information Access
COMMENT: The CAC believes that continued information
sharing with the public is critical to timely and safe execution of the disposal
mission. In that regard, the CAC has attached a list of specific information
it believes should be provided to the public and the time frames within which
it should be provided. (Appendix B)
Recognizing that every aspect of the BGCAPP will be
recorded on computer, the CAC does not believe including such information
sharing by the Permittee's creates an undue burden. Thus, the CAC recommends
the Cabinet include such conditions in the RD&D permit.
D. Workers Rights
COMMENT: The CAC appreciates the significant difference
in the way ACWA and the BPBG team has dealt with the disposal program at BGAD
and other management styles at other de-mil sites.
Nevertheless, there has been an unmistakable atmosphere
of apprehension on behalf of the work force at other disposal facilities regarding
their willingness to report safety and compliance matters to their superiors
and/or the public.
In order to assist in preventing such a situation
from emerging at the BGCAPP, the CAC recommends the Cabinet incorporate specific
language in the Storage and RD&D permit(s) that will increase the confidence
of the work force that such actions will not only be tolerated, but also expected.
Apprehension on the part of the work force due to threats of termination,
demotion or any form or retaliation is unacceptable.
In that regard, the CAC has attached information it
believes should provide guidance to the Cabinet in formulating specific conditions
to be incorporated into both permits (Appendix C).
The CAC would like an opportunity to review and comment
on such conditions prior to their being incorporated into the permits.
IV. RECOMMENDATIONS
The CAC, with consideration given to the above comments,
supports the Cabinet in its issuance of the BGAD Storage and RD&D Permit.
V. Signature Page
Submitted August 30, 2005 by
The Kentucky Chemical Demilitarization Citizens Advisory
Board
--------------------
___________________________________________
Douglas Hindman, Chair
105 Fifth Street
Richmond, KY 40475
Douglas.Hindman@eku.edu
Appendix A
I) NRC Recommendations for deploying
advanced monitoring technologies
(A) The Army’s Chemical Agent Monitoring Program
& the National Research Council (NRC)
1. Review of Monitoring Activities
Within the Army Chemical Stockpile Disposal Program, 1994.
“General Recommendations,” p. 3
The major finding of the committee
is that the monitoring system currently in use at JACADS should be improved
prior to employment at sites in the continental United States.
“General Recommendations,” p. 4
1. The Army should initiate a substantial
program to upgrade the monitoring systems for continental U.S. sites.
3. The Army should undertake
whatever instrument development is necessary to ensure that improved instrumentation
is available to the chemical disposal program is suitably rugged and operational
forms.
4. The Army should test and use
new monitoring instrumentation at JACADS before such instrumentation is employed
at Tooele.
“Executive Summary,” p. 5 • Reduce the time required
for confirmation of false positives.
Retrieval and laboratory analysis
of DAAMS sample tubes are required to confirm ACAMS alarms. Manual transport
and analysis time lead to delays of 15 to 20 minutes. The response
time of present ACAMS instrumentation is longer when operated at increasing
levels of sensitivity.
“The Importance of Monitoring” p.12
The public is justifiably concerned
with demilitarization operations like those at JACADS, A disposal facility,
if operated close to a civilian population area, will likely require more
stringent monitoring standards to ensure acceptance by, and protection of,
the public.
“Agent Monitoring,” p. 24
The ACAMS and DAAMS are able to
detect agents at the levels required by regulations, but that alone does not
ensure safety.
“ACAMS Experience,” p. 25 • Response Time
The relatively slow response of
the ACAMS means that, in the event of a sudden release of agent, plant workers
and the local population might be exposed to a concentration of agent above
acceptable levels.
“DAAMS Experience,” p. 27 • Response Time
The sampling of the DAAMS range
from one hour when detecting in the exhaust stacks, to eight hours when monitoring
plant work areas, and twelve hours at the site perimeter. These times
do not include analysis time. The response time of DAAMS confirmation
of ACAMS alarms requires about 15 to 20 minutes for sample tube collection,
transportation to the laboratory, and analysis.
(1)
“Opportunities for Improvements...,” p. 30
State- of- the- art analytical
methods are available that are more sensitive (by a factor of 1,000 or more)
than the Automated Chemical Agent Monitoring System (ACAMS) and the Depot
Area Air Monitoring System (DAAMS) at the Johnson Atoll Chemical Agent Disposal
System (JACADS).
“Opportunities for Improvements...,” p. 31
Remote sensing or point source
sampling, employing infrared spectroscopy techniques, could be used to provide
more rapid agent detection in plant work areas. The instruments could
operate continuously and have a response time on the order of 10 seconds
or less.
“Opportunities for Improvements...,” p. 32
Research being performed at the
U.S. Army Edgewood Research, Development and Engineering Center, Aberdeen
Proving Ground, Maryland, has addressed the use of Fourier Transform Infrared
Spectroscopy sensing for detection of chemical agents on battlefields and
for detecting leaks from the stockpiles.
“Findings and Recommendations,” p. 39
Alternative monitoring technologies should be explored.
Long-path optical measurements of vapor concentrations in air allow large
volumes to be probed continuously with rapid response (seconds rather than
several minutes for ACAMS). The benefits of such remote sensing ...are
that it provides earlier warning and broader area coverage.
2. Recommendations for the Disposal of Chemical
Agents and Munitions. 1994
“Agent Monitoring Systems,” p. 93
The ACAMS generates frequent false
alarms because it cannot adequately differentiate agent from other commonly
encountered organic contaminants.... Further, when an alarm sounds, the retrieval
and laboratory analysis of the DAAMS collection tubes to verify conditions
typically require half an hour or more.
3. Evaluation of the JACADS OVT: Part II,
1994.
“Findings and Recommendations,” p. 64
The current ACAMS...are able to detect only one agent
at a time and, for major releases, may have a sampling time that is longer
than required for timely response. Additional and alternative instrumentation
appears to have the potential to minimize these problems.
“Findings and Recommendations,” p. 67
The Tooele systemization program...should
be used to conduct the following activities: 1. Develop and demonstrate
an improved agent monitoring and identification system.
4. Review of Systemization of TOCDF, 1996
“General Recommendations for Agent/Nonagent Monitoring,”
p. 22
...[A]dditional research and development
either by the Army’s laboratory programs or by
(2)
Outside contractors, has not been
initiated yet so that additional technologies that might provide longer term
upgrades in monitoring capabilities can be tested and promoted...a significant
reduction of the time required to confirm ACAMS alarms would require development
and deployment of a rapid, species-specific alarm system alongside each ACAMS.
At present, the Army has not yet identified monitoring technology to fulfill
this function.
“Specific Recommendations for Agent/Nonagent
Monitoring,” p. 23
A more species-specific alarm to
complement the current ACAMS system needs to be developed for both general
plant and stack monitoring.
“Specific Recommendations for Agent/Nonagent Monitoring,”
p. 24
Both the Stockpile Committee and
the Army recognize that new monitoring technology will be required to reduce
the desired response times to a few seconds, rather than the few minutes possible
with staggered ACAMS. The Army has contracted for the development and
demonstration of a Fourier Transform Infrared (FTIR) multipass absorption
technique, which should be capable of real-time (> 1 second) detection
of high agent release levels.
“Responses to Monitoring Report Recommendations,”
p. 73
The Stockpile committee continues
to believe that the Army should investigate new monitoring technologies with
the intent of continual improvement.
Reduce the time for confirmation
of false positives. Current Status: This requirement has not been
met. ACAMS alarms still require the laboratory analysis of DAAMS samples
to confirm false positives. A single false positive requires the shutdown
of agent operations, but does not by itself initiate the response appropriate
for a major agent release. False positive signals result in plant disruptions
and the potential for increased human error and equipment degradation.
5. Occupational Health and Workplace Monitoring
at Chemical Agent Disposal Facilities, 2001
“Executive Summary,” p. 2
[R]ecent advances in monitoring
technology could reduce false alarm rates and decrease response times.
Therefore the committee recommends that the Army continue to evaluate potential
improvements. The committee also identifies weaknesses in the monitoring
of EA-2192, an agent breakdown product, and in the rapid quantification of
contamination by agent and agent breakdown products on surfaces and in liquid
and solid materials.
“Findings and Recommendations,” p. 29
Finding 2a. Current workplace
monitoring systems for chemical agents are generally adequate for normal operations
but may have serious deficiencies during accidents or departures from nominal
operating conditions. Potential employee exposures as a result of process
upsets and/or accidents can be detected by existing monitoring systems, but
not in real time.
Finding 2c. Advances in monitoring
technology could reduce response times and/or false positive alarm rates....This
could reduce the risk of worker exposure during both disposal and closure
operations.
Recommendation 2a. The Army
should continue to pursue improvements in airborne agent monitoring, including
improved ACAMS technology (for multi-agent monitoring and lower false alarm rates), and in methods for identifying
interferents that cause false alarms. It should also pursue new analytical
techniques that could lead to real-time agent detection.
6. Evaluation of Chemical Events at Army
Chemical Agent Disposal Facilities 2002
“Findings and Recommendations,” p. 52
Finding 6a. Relatively frequent
false positive ACAMS alarms for airborne agent and the lack of true real-time
(<10 s) monitoring for airborne agent have long been a concern of [NRC]
committees assessing and examining the chemical demilitarization program.
Improvements in the sensitivity, specificity, and time response of the ACAMS
system and the development of an additional airborne-agent monitoring technology
robust at the parts-per-trillion level have previously been recommended...Although
[PMCD] has made some efforts to develop better agent-monitoring technology,
results to date have been disappointing.
Recommendation 6a. To reduce
the rate of false positive alarms for both airborne and condensed-materials
agent contamination, [PMCD] and the relevant [DoD] research and development
agencies...should invigorate and coordinate efforts to develop chemical agent
monitors with improved sensitivity, specificity, and time response.
7. Monitoring at Chemical Agent Disposal
Facilities 2005
“Findings and Recommendations,” p.123
Finding 5-1. Conversely, FT-IR
spectrometry may play an important role in monitoring accidental releases
of chemical agents in locations very close to where the agents are stored
or incinerated and where the concentration may exceed 0.05 mg m –3.
Detecting a catastrophic release within a minute of the event would allow
suitable action to be taken.
Finding 5-5. Chemical sensors
have the potential to be useful for making rapid measurements at IDLH levels
and above, such as for events including spills and leaks.
Compiled by the Chemical Weapons
Working Group - May 20, 2003
Amended August 30, 2005
For additional information contact: 859-986-7565
A) Asserting the Need for Improved
Airborne Chemical Agent
Monitoring Systems at U.S. Chemical Weapons Stockpile
Sites
Compiled by:
Chemical Weapons Working Group
PO Box 467 Berea, KY 40403
Phone: (859) 986-7565
Fax: (859) 986-2695
Web: http://www.cwwg.org
April 2004
Introduction
Hundreds of thousands of U.S. citizens live within
harmful range of old stockpiles of chemical weapons, stored or being destroyed
on eight military bases in Utah, Oregon, Colorado, Kentucky, Alabama, Arkansas,
Indiana and Maryland. The chemical weapons are filled with lethal nerve
agents VX and GB, and mustard, or blistering, agents.
As the weapons are destroyed -- whether by incineration
or non-incineration methods -- one of the basic means of ensuring the well-being
of citizens living nearby these stockpiles is to monitor for the release of
chemical agents as completely, accurately and quickly as possible.
However the Army’s current monitoring system is woefully
inadequate, particularly at its incinerator sites, where chemical agent can
be released along with tons of daily gaseous emissions through smokestacks.
Chemical agents can also be released from places other than incinerator smokestacks,
including ash bins; from rooms that are not sealed; and during movement of
weapons from storage igloos to the disposal facility.
This primer will clarify the inadequacies of existing
monitoring systems, and the benefits that additional airborne chemical agent
monitors offer.
I. Existing chemical agent monitoring systems
The Army relies primarily on two monitoring systems
at its chemical weapons stockpile sites to sample the air for mustard and
nerve agents: Agent Continuous Air Monitoring Systems (ACAMS) and Depot
Area Air Monitoring Systems (DAAMS). A third set of monitors called
the MINICAMS (Mini Chemical Agent Monitoring Systems) are not typically used
around chemical weapons disposal facilities.
Both ACAMS and DAAMS monitors are positioned throughout
chemical weapons disposal facilities, including in the smokestacks of incinerators.
ACAMS are very sensitive and can detect even trace levels of chemical agents.
ACAMS are connected to an alarm system, which sounds as soon as chemical agent
is detected. DAAMS are not connected to alarm systems. Rather,
DAAMS tubes collect air samples and are used to confirm readings from ACAMS.
DAAMS stations are also positioned outside of the
facilities, on depot property.
Though the sensitivity of the ACAMS is definitely
a plus, there are frequent “false positive” readings. That is, when
an ACAMS alarm sounds, it may be because of chemical agent but it may also
have resulted from some other industrial chemical or interferent. In
fact, the Army has said it is common to have as many as 5000 such alarms
every month. Such a high number of false readings can lead to a “cry
wolf” situation in which workers begin to disregard ACAMS alarms.
Since ACAMS can only be calibrated to monitor one
type of chemical agent at a time, they do not fully identify chemical emissions.
For example, an incident on March 30, 1998 at the Tooele, Utah incinerator
resulted in the release of some unidentified compounds at a very high concentration.
The Army has insisted that the release was not chemical agent, however they
cannot say what it was, or what the environmental or health impacts of the
release may have been.
The effectiveness of DAAMS tubes outside chemical
weapons disposal facilities is extremely limited. The sporadic placement
of DAAMS stations means that a plume of chemical agent could be missed.
There are no alarms associated with these monitors,
and DAAMS tubes outside of the facilities are collected every 8 - 12 hours.
In February 2004 in Anniston, Alabama, a routine pull of DAAMS air sampling
tubes revealed a reading for VX nerve agent. No ACAMS alarm ever sounded,
and there is no way to know exactly when the detection occurred during the
12 hours prior to their being collected. The Army used all three DAAMS
tube samples to run the same confirmation test, leaving no other sample with
which a more detailed test could be conducted. All three tubes confirmed
VX agent. However, source and concentrations of the confirmed agent readings
remain a mystery.
The Army does not monitor for toxic compounds such
as PCBs, dioxins or heavy metals except for a limited time during the trial
burn phase. The concentrations of these kinds of toxic emissions during
routine incinerator operations are unknown.
II. Workers at chemical weapons facilities have
testified on the limitations of the Army’s existing monitoring systems, and
the failure of the Army to fix the problems
Over the years, in state and federal court hearings
in Utah and Oregon, Army experts from chemical weapons incinerators have testified
as to the limitations of the ACAMS and DAAMS monitoring systems. Following
is a summary of issues raised by workers in Oregon district court in 2003:
- Chemical agent could be passing through incinerator
smokestacks undetected. This would explain how chemical agent monitors
at an Army facility nearby the Tooele, Utah chemical weapons incinerator repeatedly
alarmed for the presence of chemical agent at times when the incinerator next
door was burning weapons; but ceased to alarm when the incinerator was shut
down.
- Chemical agent monitor verification tests done
after the Utah incinerator released chemical agent through the smokestack
in May 2000, revealed only a 40% and 75% confirmation rate.
- Processes for analyzing monitor readings are
not accurate, and prone to mistakes.
- Worker suggestions on how to improve monitoring
systems (such as the ways in which monitor samples are taken, and how monitor
probes are used, and how the systems are maintained) have been chronically
ignored by both the Army and its contractors.
It is important to note that workers who raised
these issues internally and publicly have been harassed, even by the Army’s
attorney, right in the courtroom! On August 13, 2003, under cross examination
by Army attorney Robert Foster, Mr. Tom Cramer, testifying to the inadequate
monitoring systems, was told that if he testified, his “head would be on the
chopping block.” This shows the Army’s willingness to quash those
who challenge the effectiveness of its monitors.
III. By adding advanced chemical agent
monitoring systems to existing monitors, a much-needed layer of protection
would be provided to depot workers and community members
A. What do we mean by improved or advanced
chemical agent monitoring systems?
One such advanced monitoring system, recommended
by the National Research Council, is an infrared monitoring system called
the Open-Path Fourier Transform Infrared (FTIR) Spectrometer. There
are numerous companies producing infrared technology and the CWWG does not
endorse any one provider.
B. How does the technology work?
FTIR technology uses an infrared light beam,
shot horizontally from an instrument that looks like a telescope, to monitor
the air for pollutants. The system can be used to simultaneously monitor
more than 50 chemicals and pollutants, including chemical warfare agents.
The CWWG proposes that FTIR be deployed in the open air surrounding the chemical
weapons storage and disposal facilities.
Infrared technology can “fingerprint”
airborne gases generated by chemical weapons incinerators, meaning it can
monitor the emissions, and accurately identify and measure the concentration
of the chemicals it identifies. It is a computer driven
system, which means complete information on chemical readings are available
immediately on a computer screen. This information can be downloaded,
saved, and even used as a means to track changes in air quality.
The technology can work effectively when infrared
beams are configured in a set of concentric grids surrounding the source of
air pollutants (be it an oil refinery, landfill, incinerator, etc.).
For a chemical weapons facility, this would mean having two grids of infrared
beams surrounding the facility, within the depot. Any chemical agent
that crosses that space would be identified in near real-time.
C. What are the advantages of using this
technology in addition to ACAMS and DAAMS?
For use at chemical weapons facilities, infrared
technology would fill a void by providing prompt, accurate detection of chemical
agents outside the facility, between the facility and the perimeter DAAMS
chemical agent collection tubes. The benefits are huge:
- Airborne chemicals can be completely identified.
Think of the construction workers at the Umatilla, Oregon incinerator who
in 1999 were overcome by a chemical plume that has yet to be identified.
This type of system would take the guess work out of chemical identification,
and help predict where a chemical plume may be headed -- on the grounds of
the depot or over the perimeter and into our communities. That is an
important layer of protection for workers and community members.
- Infrared technology can provide continuous “real-time”
monitoring, meaning there is little or no delay in obtaining information about
the emissions in the area.
- Chemical agents migrating outside of storage
and disposal facilities can be quantified in “real-time” (around 15 seconds),
thereby providing better emergency response capabilities.
- Workers at the facilities could respond to incidents
much more safely and effectively if they know exactly what chemicals were
released and when. They would not have to wait hours for results from
DAAMS.
- Community members and agencies could view monitoring
results from computer terminals in public spaces. That means we don’t
have to wait for the Army or regulators to tell us what is going on at the
facility, or wait too long to find out about a problem.
IV. The National Research Council has for 10
years advised the Army to use improved monitoring systems (See Section (A)
above.
V. Adding advanced chemical agent monitoring
systems is cost effective and can be accomplished quickly without impacting
the chemical weapons disposal schedule
Infrared monitoring systems like FTIR are “off the
shelf” technology, meaning they are already being used widely by the military
and in the private sector. Examples of their use include:
Deployment
Location
Date
Sponsor
Iraq
Iraq
May 96
UNSCOM
Fenceline Monitoring
Aberdeen, MD
Aug 96
U.S. Army
Iraq
Iraq
Nov 96
UNSCOM
Iraq
Iraq
March 97 UNSCOM
Iraq
Iraq
Aug 97
UNSCOM
Iraq
Iraq
Sept 97
UNSCOM
Process Monitoring
Hill AFB, Utah
Dec. 98
U.S. Air Force
Chem Weapons Remediation Louisiana
July
99
U.S. Corps of Engineers
Chem Weapons Remediation Memphis
April
00
U.S. Corps of Engineers
Chem Weapons Remediation Ogden,
UT
Sept. 00
U.S. Corps of Engineers
Chem Weapons Remediation Anniston,
AL May 01
U.S. Corps of Engineers
Chem Weapons Remediation Spring
Valley, MD June 01
U.S. Corps of Engineers
ChemWeapons Remediation Anniston,
AL Apr
02
U.S. Corps of Engineers
(Gamiles)
As noted in the chart above, the U.S. Army Corps of
Engineers uses Op-FTIR air monitors at remediation sites where buried chemical
weapons are being un-earthed. The system is used to warn workers, and
nearby residents in the event of a release. Releases have been accurately
detected and reported. It should be noted that Op-FTIR air monitoring
was used during the remediation of Pelham Range, at Fort McClellan, Alabama
during the Spring of 2002. As part of routine operation, intrusive work
does not commence unless the Op-FTIR air monitoring system is operational.
This is standard practice for all of the sites operated by the U.S. Army Corps
of Engineers when open-path air monitors are used.
The U.S. Army Soldier Biological and Chemical Command
(SBCCOM) has published a fact sheet on Op-FTIR monitors, which states
FTIR is used to perform air quality studies of industrial
sites, residential communities, landfills, and more. The technology
can identify all compounds present in a cloud of smoke emitted from an industrial
plant, and it can predict how a cloud of smoke will disperse due to wind speed.
This may be helpful as an emergency evacuation monitor to protect public
health. Open-path FTIR technology can also be used to determine air
quality conditions in a neighborhood setting; determine source-specific fenceline
fugitive and stack pollutant emission concentrations from selected industries;
identify compounds emitted from factories as they change processes, batches,
or shifts; study impurities from vehicles in traffic; perform perimeter monitoring
around remediation sites; determine ambient air quality pollutants in a Community
Bases Environmental protection area; and determine the effectiveness of a
water spray curtain on cloud concentrations.
and, “As required, FTIR would be an ideal tool for
use by refineries, environmental agencies, citizen groups, and state and local
governments.”
Vendors for these systems estimate that the total
cost of deploying infrared monitoring systems at all chemical weapons disposal
facilities could be in the range of $16 million. That is a proverbial
‘drop in the bucket’ for the chemical weapons program, projected to cost over
$25 billion, and considering the safety benefits gained by facility managers,
depot workers and nearby community members.
Vendors also believe this technology could be deployed
at chemical weapons sites within months after funding is secured. Deploying
these systems does not require the facilities to shut down, so the chemical
weapons destruction schedule would not be impacted.
Work Cited
Chemical Materials Agency, Anniston Chemical Activity
Press release. “Monitoring station detects VX at perimeter of Pelham Range;
no emergency involved.” March 3, 2004.
Mr. Mario Fiori, Assistant Secretary of the Army,
Installations and Environment (former). Personal correspondence, December
2001.
Dr. Don Gamiles. Affidavit from CWWG et al.
vs. U.S. Army et al. US District Court, District of Columbia, August 6, 2003.
Case No. 1:03CV00645
National Research Council. Review of Monitoring
Activities Within the Army Chemical Stockpile Disposal Program. National
Academies Press, 1994.
National Research Council. Recommendations for
the Disposal of Chemical Agents and Munitions. National Academies Press,
1994.
National Research Council. Review of Systemization
of TOCDF. National Academies Press, 1996.
National Research Council. Occupational Health
and Workplace Monitoring at Chemical Agent Disposal Facilities. National
Academies Press, 2001.
National Research Council. Evaluation of Chemical
Events at Army Chemical Agent Disposal Facilities. National Academies
Press, 2002.
Testimony from CWWG et al. vs. U.S. Department of
the Army et al., US District Court District of Utah, June 1999. Case
No. 2:96-CV-425(TC)
Testimony from GASP et al. vs. Oregon Environmental
Quality Commission et al., US Circuit Court, State of Oregon, County of Multnomah,
August 2003. Case No. 0009-09349.
US Army SBCCOM. “Open Path Fourier Transform
Infrared Spectrometer” fact sheet. 2002. <http://www.sbccom.apgea.army.mil/RDA/ecbc/pdfs/ftir.pdf>
US Army SBCCOM. “Monitoring at Chemical Agent
Disposal Facilities” fact sheet. 2003.
C) Congress Supports Advanced Agent Monitoring
House Rpt.108-354 - NATIONAL DEFENSE AUTHORIZATION
ACT FOR FISCAL YEAR 2004
------------------------------------------------------------------------
SUBTITLE F--OTHER MATTERS
Sense of Congress on deployment of airborne chemical
agent monitoring systems at chemical stockpile disposal sites in the United
States (sec. 1056)
The Senate amendment contained a provision (sec. 1042)
that would express the sense of the Senate that the Secretary of the Army
should develop and deploy a program to upgrade the airborne chemical agent
monitoring systems at all chemical stockpile disposal sites across the United
States in order to achieve the broadest possible protection of the general
public, personnel involved in the chemical demilitarization program, and the
environment.
The House bill contained no similar provision.
The House recedes with an amendment that would express
the sense of Congress that the Secretary of the Army, in coordination with
relevant Department of Defense research and development agencies, should invigorate
and coordinate efforts to develop and deploy chemical agent monitors with
improved sensitivity, specificity, and response time.
The conferees note that the National Research Council
(NRC) has completed six reports since 1994 that include assessments of the
capabilities of airborne chemical agent monitoring systems installed at the
chemical agent and munitions stockpile and destruction sites. In these reports,
the NRC has consistently cited several problems with the airborne chemical
agent sensors. While the NRC has determined that monitoring levels used at
the demilitarization facilities are very conservative and are highly protective
of workers and public health and safety, the conservative monitoring levels
used are a contributing factor in a high incidence of false positive alarms.
The NRC has urged the Project Manager for Chemical Demilitarization to improve
both the reliability and response time of its airborne agent monitoring systems
and recommended that the Army develop a real-time system for airborne-agent
monitoring. The NRC has also noted the lack of robust techniques for rapidly
measuring agent and agent breakdown products present in liquid waste streams
and associated solid materials. The NRC acknowledges the progress made by
the Army over the last decade in developing better agent monitoring technology,
but concludes that the results to date have been disappointing.
The conferees note that the Army's Chemical Material
Agency (CMA) conducts an active program for evaluating new equipment and methods
for improving both near-real time monitoring and historical long-term monitoring
and continues to improve technologies and equipment to increase specificity,
lower detection limits and response times, and minimize false alarms. The
conferees believe that these efforts should be coordinated with, and take
advantage of, the increased level of interest in and increased resources available
for developing chemical agent detectors for homeland defense. The committee
strongly supports these actions of the CMA that promote the maximum protection
of the general public, personnel involved in the chemical demilitarization
program, and the environment.
June 22nd, 2004
BUNNING SECURES $2 MILLION FOR BLUE GRASS ARMY
DEPOT
WASHINGTON - U.S. Senator Jim Bunning today applauded
the Senate Appropriations Committee for approving the FY-05 Defense Appropriations
Bill and sending it to the full Senate. The Senate Appropriations Committee
allocated Bunning’s request for $2 million for an improved chemical warfare
agent monitoring system at the Blue Grass Army Depot in Richmond, Kentucky.
In April, Bunning made it his top priority to get these important funds into
the final bill.
“Last year I secured language in the FY04 Defense
authorization act to have the Army provide improved chemical monitoring devices
at Bluegrass Army Depot. These appropriated funds will make sure the Army
does not lag behind to meet this very important requirement.”
###
Appendix B
Public Information Access
SPECIFICS
Daily Public Information Check List (published on
accessible web site):
I) Operational Availability of the facility during
the 24-hour period:
A) If less that 24 hours availability:
1) Reason(s)
for Unavailability
a) Routine Maintenance - Activity Performed
b) Unscheduled Maintenance - Activity Performed
c) Chemical Event/Incident - Incident Summary
II) Number and types of munitions transported to the
disposal facilities during the 24 hour period;
IV) Number of Munitions processed during the 24-hour
period
V) Type(s) of Munitions processed during the 24-hour
period
1) Note any "gelled"* munitions"
separately (* less than 95% drain)
VI) Amount of agent processed during the 24-hour period:
VII) Percentage of agent drained per munition during
the 24 hour period (not averaged - but by munition)
1) Note any "gelled"* munitions"
separately (* Less than 95% drain)
VIII) Number of ACAMS Alarms during the 24-hour period:
1) Location of each Alarm
2) Alarm Reading in Time Weighted
Average (TWA)
3) Number Confirmed -
4) Number False Positive - Identification
of Cause of the Alarm(s)
5) Number False Negative
IX) Prevailing Wind Patterns during the 24-hour period
by percentage.
X) Potential Worker Exposures during the 24-hour period:
1) Cause(s) of potential exposure
during the 24-hour period
2) Number of Blood Draws during
the 24-hour period
XI) Worker Accidents during the 24-hour period
1) Type of Accident: Agent Related
or Industrial
2) Location of Accident
3) Number of Workers Involved
4) Status of Injuries, if any
Monthly Public Information Check List (published on
accessible web site):
I. Number of RCRA Permit Non-Compliances during the
4-week period
A. Specific Non-Compliance(s)
II. Amount of Residual Hazardous Waste Produced during
the 4-week period
A. Type(s) of waste produced from
operations
B. Amounts of each Type of
waste produced from operations
1. Spent Decon
2. Brine
3. Lab Waste
4. Dunnage Non-Metals
5. Dunnage Metals
6. Other
C. Location for disposition of
wastes
D. Type of disposal for wastes
1. Incineration
2. Landfill
3. Deep-Well
Injection
4. Fuel Blending
5. Bio-treatment
6. Other
Quarterly Public Information Check List (published
on accessible web site):
I. Conformance with latest published Schedule
A. Scheduling Adjustment
B. Basis for Adjustment
II. Contract Changes Implemented
A. Cost of Contract Modifications
B. Basis for Contract Modifications
C. Schedule Impact of Contract
Modifications
III. Contractor Award Fees Granted (if Quarterly -
if semi-annually, then post semi-annually).
Annually: All RCRA Non-Compliance Reports Distributed
to the Public
Appendix C
Worker Rights
I. Court Ruling: On July 26 2004, the Oregon Circuit Court issued a Ruling
regarding a citizens action against the chemical weapons incinerator located
at Umatilla.
That ruling stated in part, “Without the addition
of the whistleblower functions, the permitted activity endangers human health
and the environment and can only be regulated to acceptable levels by modification
of the permit by adding whistleblower protections. Meaningfully encouraging
workers to report good faith concerns for safety, hazards, and related noncompliance
with permit conditions would represent a substantial function. The mere existence
of a federal whistleblower statute has not been sufficient to ensure full
participation of workers in protecting health, safety and the environment.”
(Oregon Circuit Court: GASP vs EQC; Case number 0009-09349)
II. Existing Worker Protections:
Employee Workplace Rights: OSHA 3021-08R
Excerpts From: Worker Rights Under the OSH Act
Whistleblower protections
Employees have a right to seek safety and health on
the job without fear of punishment.
That right is spelled out in Section 11(c) of the
OSH Act. The law forbids the employer from punishing or discriminating against
employees for exercising such rights as
• Complaining to the employer, union, OSHA, or any
other government agency about job safety and health hazards; and
• Participating in OSHA inspections, conferences,
hearings, or other OSHA-related activities.
States administering their own occupational safety
and health programs must have provisions at least as effective as those in
the OSH Act to protect employees from discharge or discrimination.
III. Suggested Permit Conditions
Specific provisions that should be conditions of the
BGCAPP permit including protection of workers from any of the following
based on their efforts to ensure safety and compliance:
- Firing or lay offs
- Assigning to undesirable shifts
- Blacklisting
- Demoting
- Denying overtime or promotion
- Disciplining
- Denial of benefits
- Failure to hire or rehire
- Intimidation
- Transferring
- Reassigning work
- Reducing pay or hours
END