Defense Environmental Alert
May 21, 2002

REGULATORS CITE LABORATORY VIOLATIONS AT ANNISTON INCINERATOR

State regulators last month issued a warning letter to the Army for violations of operating procedures at a laboratory that is part of the military's chemical weapons incinerator in Anniston, AL. The state says it sent the informal warning letter, rather than taking a more severe enforcement action, because the incinerator has not yet begun destroying chemical agent. But if similar violations are found when the incinerator is operational, the state may take enforcement actions that include monetary penalties, the letter says. The letter is available on InsideEPA. coin. See page 2 for details.

An Army spokesman says the military is in the process of fixing the problems and is completing a top-to-bottom review of operating procedures at the laboratory. The spokesman says the trust of the Anniston community is paramount and that before agent operations begin, everything will be in place to ensure the health and safety of the community.

In an April 29 letter to the Army, the Alabama Department of Environmental Management (ADEM) writes, "Many of the observations and discrepancies that have been documented, when taken individually, appear to be relatively insignificant. However, when considered in total, along with those that may have a direct effect on the over-all quality of data, the performance of the lab is disturbing."

"These reports reflect a general attitude of lax management, and offer at least a hint of collusion between the laboratory branches (Analytical, Monitoring, and Quality Control) to prevent major discrepancies from seeing the light of day." As an example, ADEM says incorrect weights were used in sensitivity challenges and instruments were not manually calibrated as required, yet there was no indication that these situations were adequately addressed. Additionally, agent concentrations were incorrectly labeled on a vial, but the correct concentration mysteriously appeared on a form, ADEM says.

ADEM's letter cites three specific violations and several additional observations that raise questions about laboratory practices. The violations include: an open container collecting hazardous waste, when state law requires hazardous waste holding containers to be closed except when adding or removing waste; hazardous waste containers that either were not labeled as being hazardous waste or lacked a description of the contents; and the failure to take corrective action when operating procedures were not followed.

Other problems include leakage of sampling tubes that render the results useless, the failure to test "blind" unknown samples for analysis as an additional quality control check, and several inconsistencies in following quality control checklists.

One of the discrepancies ADEM lists is from an air monitoring tube surveillance checklist dated Jan. 17. Rather than responding yes or no to the question: "Heat trace line on and warm to touch," the checklist just says it is not applicable. The explanation given is "can't reach." ADEM asks. "Is this a legitimate reason for not performing a required [quality control] check?"

Another problem comes from a March 12 logbook for analytical balancing. "Some operators seem to be having a problem selecting the proper weight for sensitivity challenges. It is possible they are not attentive since they often enter unacceptable results and continue without corrective action," ADEM quotes from the logbook. The state says the logbook indicates errors as high as 40 percent and says, "This seems to be a significant observation." But when the checklist asks, "Any Deficiency and/or Observation Reports created?" the logbook says, "No."

The Army will not rush in correcting the problems and the laboratory may have to readjust its priorities as it prepares for agent operations, but these actions should not affect the timeline to begin destroying chemical weapons in the fall, the Army spokesman says. These types of problems are not unusual when laboratories are being set up, he says.