Defense Environment Alert

an exclusive biweekly report on defense policies for cleanup, compliance and pollution prevention

Vol. 18, No. 4

February 16, 2010

NAS Panel Suggests Meterics For Closing Chemical Agent Disposal Plants

A panel of the National Academy of Sciences (NAS) is advising the Army to use metrics such as setting performance standards for closure wastes and establishing facility end-state conditions to ensure the military's chemical weapons incineration plants are closed effectively once destruction operations cease.

The recommendation comes in a Jan. 7 interim letter report the NAS Board on Army Science and Technology wrote in response to a request from the director of the Chemical Materials Agency (CMA) to review and assess closure plans for the Tooele Chemical Agent Disposal Facility (TOCDF) and Chemical Agent Munitions Disposal System (CAMDS), and is in the early stages of planning for the facility's closure, while CAMDS, both in Utah. After operation for many years, TOCDF plans to finish its incineration operations toward the end of 2011, and in the early stages of planning for the facility's closure,  while CAMDS, a facility used to test chemical agent treatment methods, is no longer operationg except for an on-site lab. Final closure planning is not yet complete for CAMDS. Both facilities are expected to stay under Army control after closure as part of the nearby Tooele Army Depot the report says.

The panel considered closure experiences at three chemical agent disposal facilities previously closed and looked at closure planning so far for TOCDF and CAMDS. As a result, it developed a set of parameters "it believes are important in ensuring a consistently effective approach to the closures of the four currently operating CMA chemical agent disposal facilities," the letter report says. In addition to TOCDF, the three other CMA chemical agent disposal facilities - all using incineration - are located in Pine Bluff, AR; Hermiston, OR; and Anniston, AL. The parameters are key to these facilities' successful closure, the report says.

The report lists out 13 parameters to guide facility closures, along with numerous associated metrics. The parameters are: safety, health and security; communications for promoting safety culture; maintenance; training and development; communications with various stakeholders; quality criteria; cost criteria; operations and deconstruction; management; environmental regulatory compliance; monitoring plan compliance; analytical; and material management.

The NAS panel lists several environmental regulatory compliance metrics, including establishing facility end-state conditions and performance standards for closure wastes, modifying the Resource Conservation & Recovery Act (RCRA) permit to include detailed closure plans, modifying other applicable permits to include closure, and monitoring compliance with the RCRA permit, closure  plans and other permits.

To address the parameter on monitoring plan compliance, the Army should develop a waste analysis plan and waste characterization protocols, develop monitoring plans for air and the other media and monitor implementation of the waste analysis plan.

"Obtaining requlatory agreement to the closure plan in a timely manner is key to achieving efficient closure," the report notes, adding that delay will be minimized if continued monitoring is done for meeting permit requirements.

The report also outlines challenges facing the closure of TOCDF and CAMDS and makes suggestions specific to their eventual shutdown. One complication for TOCDF is that it has approximately 2  million pounds of legacy secondary waste in storage that the report says must be managed and disposed of during closure activities. And it says "[t]he main challenges associated with CAMDS closure stem from its age, its use as a pilot facility, and to the site having many interconnected building and common utility services whose closure requires careful staging."

Among the suggestions specific to these two facilities, the panel advises the Army to consider negotiating with Utah regulators over lowering the stringency of regulatory requirements that will govern closure operations, in light of the reduced risks at the facilities as compared to those present during incineration operations. The panel says this could make closure more efficient.

"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 report says. During closure, there will not be a significant amount of agent present, it says. It also notes that the regulatory standards were developed early in the disposal program when little was known about managing the risks of materials exposed to agent. But these requirements may be more than is needed for closure operations, it says.

"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," the report says.

The interim letter report will be followed by a comprehensive report that will use the parameters "to assess and intergrated approach to common closure requirements," and decide on applicable lessons learned from the closure of other plants for potential use during the shutdown of TOCDF and CAMDS, the interim report says.