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


Vol. 12, No. 7--April 6, 2004


ARMY WARNS TOOELE CONTRACTOR OF SLIPPING SAFETY PERFORMANCE

The Army recently warned the chemical demilitarization contractor at its Tooele, UT, facility that its environment and safety performance is worsening, despite a major overhaul of its safety program after a July 2002 chemical agent incident. In response, EG&G concedes the problems and says it needs to reinvigorate its "continuous improvement program" at the site.

The Army Field Support Command in Utah writes of the downward trend in a March 15 letter to EG&G Defense Materials Inc., which runs the Tooele chemical agent incineration plant. "As of the January and February assessments, performance is regressing" toward the operational discipline the plant had used before a July 2002 incident where workers were exposed to nerve agent, the letter says.

That incident shut down the plant for eight months and sparked investigations that resulted in a multitude of recommended corrective actions (Defense Environment Alert, Oct. 22, 2002, p.l0, and April 8, 2003, p.l2). DOD's inspector general, in investigating the incident, found the facility lacked a documented process for reporting safety concerns and had communication failures between employees and supervisors, among other things, while the Army's own investigation found failures in procedure and recommended 97 corrective actions.

The problems being raised now are "almost exclusively associated with operational performance and work execution, the responsibility of line management," the Army Contracting Officer's Technical Representative Dale Ormond says in the letter to EG&G obtained by the citizen coalition Chemical Weapons Working Group (CWWG).

He goes on to list 11 of the most significant events, including "[n]early 100 gallons of agent pumped from a ton container to a sump following improper execution of a maintenance activity" and a 30-gallon spill of agent after a strainer was improperly restored. And "shift management approved work for an inappropriate level of [personal protective equipment] based on the hazards, resulting in a near miss for agent exposure (an event remarkably similar to the July 15, 2002 exposure incident)," among other, sometimes repeated, incidents.  Relevant documents are available on InsideEPA. com. See page 2 for details.

Ormond questions how these incidents have been allowed to occur, given the level of scrutiny the plant supposedly receives. Before the plant began its campaign to destroy VX agent, EG&G "made a strong commitment to critique events, develop corrective actions, and implement those actions within the scope of a continuous improvement program," he says.

"While some of the more recent critiques have demonstrated an improvement in the process, it is difficult to understand how the combination of management critiques to capture issues, the implementation of lessons learned, and the focused commitment to continuous improvement could allow the performance of disciplined operations to degrade to its current state."

In particular, he questions whether the Operations Department completely comprehends its safety responsibilities and "is fully committed to implementing the work planning and execution standards and processes that have been painstakingly developed over the last 18 months." He wonders whether communications are broken between high- level managers and plant shift managers, and says "it is unclear how line management is holding itself accountable for this trend in performance."

While some action has been taken by EG&G, the proposed "path forward" seems to be inadequate, Ormond says. He asks EG&G by April 5 to develop a comprehensive plan "to fully understand the scope of the problem, a schedule of near-TERM and long-term activities to improve performance, and a description of the metrics that the [contractor] will use to track progress as the plan is implemented."

Stephen L. Frankiewicz, a high-level EG&G official replies to the charges in a March 22 letter, saying the company "shares" the concern about the "less than adequate operational performance and work execution" over the past several months. This indicates that the facility's continuous improvement program started by senior management "has reached a plateau and needs to be reinvigorated" to reach EG&G and the Army's expectations.

He also says EG&G management in recent months refocused on the destruction through-put, which meant less emphasis "on strict adherence to standards and continuous improvements. The series of unexpected undesired results has caused EG&G management to recognize that we had overestimated the success of the 'cultural change' we had attempted and that the maturity of the organization was not such that it had adequately institutionalized the processes we had changed."

Frankiewicz lists what EG&G senior management believes are the root causes of these events and recommends an independent assessment be done to validate the accuracy of these alleged causes and the appropriateness of EG&G's proposed corrective actions, some of which are already being undertaken. These root causes include a lack of understanding of work scope, failure to fully document work completed, lack of attention to detail in managing the plant, and unaccountability for substandard performance. It has also implemented compensatory measures in response to the problems, he says.

But a CWWG spokesman says that with the repeated warnings and problems occurring at Tooele, which has been running for eight years, those in charge should "take a serious look" at whether the Army can continue the contract. The source believes these documents "show a thorough disconnect" between those on the ground running the plants and the hierarchy in the chemical demilitarization program or a misrepresentation by the program's higher-ups to Congress, in which officials are reporting no problems. Either way, it is not acceptable, the source says. The source says that these documents represent just the struggle at one plant, noting that next year, the Army hopes to have up and running six chemical demilitarization plants. That is "not a confidence builder," the source says.

And while the contract was modified after the 2002 incident to give more weight to compliance, safety and procedural adherence when making award fee determinations, the source says that maintaining the destruction schedule still appears to override any other drivers.