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


Vol. 12, No. 8--April 20, 2004


ARMY SAYS PERMIT VIOLATIONS AT ANNISTON ARE PRIMARILY ADMINISTRATIVE

Army officials are downplaying the significance of 17 permit violations at the Army's Anniston, AL, chemical weapons incinerator, saying they are "primarily administrative in nature" and "do not pose a risk to the public, the work force, or the environment." The Alabama Department of Environmental Management (ADEM) noted the violations in an April 9 letter, asking for an explanation and corrections within 30 days.

While most of the violations are administrative, some are substantive. The violations include instances where copies of standard operation procedures (SOPs) were outdated or not used correctly, deficiencies noted by quality assurance inspectors were not documented or reported as required to ADEM, wrong dates were recorded for inspection of the plant's fire protection system, low-level alarms on sumps went off for up to three days, and rocket processing occurred without having safety equipment on line.

Specifically, on Oct. 27, 2003, rockets were processed without the high pressure gate wash on line as required by the plant's SOP, and on Jan. 8, tools used to break up ash in the deactivation furnace kiln were not spark proof and tests of the ash had indicated the presence of explosives, ADEM says.

Similarly, failure to follow SOPs at the Army's Tooele, UT, facility in 2000 led to the accidental release of agent. Investigations of that accident by Utah regulators, the Army and the contractor at Tooele cited the need for a comprehensive and detailed SOP to deal with both contingency and normal operations, and said the facility needed to clamp down on adherence to procedural requirements under all circumstances.

In Alabama, ADEM says it is baffled by new quality assurance/quality (QA/QC) control problems at Anniston because two years ago the facility corrected other QA/QC deficiencies in its laboratory, including the failure to initiate deficiency reports (Defense Environment Alert, May 21, 2002, p 12). As a result of a warning from ADEM, the laboratory changed its QA/QC program, producing "an effective, well-documented program," ADEM says. "It is puzzling why very similar problems have now arisen in another area of [the incinerator's] QA/QC program," ADEM says. Relevant documents are available on InsideEPA.com. See page 2 for details.

Under the ADEM enforcement action, the Army has 30 days to correct the violations and explain how some of them occurred. Timothy Garrett, the Anniston site project manager, said in an April 13 statement that the notice of violation is the result of ADEM's full-time presence at Anniston. The incinerator's management team "welcome[s] ADEM's oversight and the opportunity that their scrutiny will provide for the continuous improvement of our compliance posture," Garrett said. He added that the management team agrees that the cited items need attention and follow-on actions, and added the facility's managers have "vowed to thoroughly review internal processes and procedures with the intent of making improvements. Additionally, more work force training may be implemented if required."

The violations at Anniston also come on the heels of fines levied against similar incinerators in Oregon and Arkansas. The contractor at all three sites is the Washington Demilitarization Co. Late last month, the Oregon Department of Environmental Quality (DEQ) issued fines totaling $33,600 for four violations at the Umatilla chemical weapons incinerator. The Army appealed the fines April 6, according to a DEQ online database.

The cited violations involved feeding hazardous waste into a liquid incinerator on four separate days during a shakedown testing period while required monitoring instrumentation was disabled, DEQ says. The disabled instruments would have monitored the feed rates of the hazardous waste into the incinerator, and that monitoring is necessary for proper operation of the automatic waste feed cut-off systems. For safety reasons, proper operation of the instrumentation and the automatic waste feed cut-off are required by the facility's permit during shakedowns, trial burns and post-trial burns, DEQ says.

systems for the incinerator were disabled, and improper calibration of carbon dioxide monitors. The Army usesAnd earlier this year, the Arkansas Department of Environmental Quality fined the Army and its contractor $22,389 for permit violations at the Pine Bluff incinerator, with an option to reduce the fine by $7,836.15 through a supplemental environmental project. The violations included a leak of sodium hydroxide, instances where the the automatic waste feed cut-off sodium hydroxide in its pollution abatement system, and Arkansas regulators say that a leak released between 835 to 982 gallons of the chemical into water that drains into a nearby creek. The state cites instances where the automatic waste feed cut-off systems for both the liquid incinerator and the deactivation furnace system were disabled. And the miscalibration of the carbon dioxide monitors were due to a lack of proper employee training, the state says.

Neither the Umatilla nor Pine Bluff incinerators have begun processing chemical agent.