Defense Environment Alert 12/28/04

Defense Environment Alert

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

Vol. 12, No. 26--December 28, 2004

SOME NERVE AGENT SITES WILL MISS DEADLINE FOR EMISSION LIMITS

Some of the Army's chemical weapons storage and destruction facilities will fail to fully comply on time with new, more stringent airborne exposure limits taking effect Jan. 1, an Army Chemical Materials Agency (CMA) spokesman says. As a result, the Army headquarters environmental office will require weekly reporting on the compliance status of the facilities, the spokesman says.

Because of the challenges the Army faced with meeting the new standards, it was given more than a year between the time the final requirements were issued and their effective date. But the CMA spokesman is downplaying the lack of full compliance by the deadline, saying the Army is still monitoring at conservative levels even without full compliance.

The Centers for Disease Control & Prevention (CDC) finalized new airborne exposure limits (AELS) for nerve agents GB, GA and VX in 2003, making them effective Jan. 1, 2005. The CDC updated 1988 limits for both the general population and the worker population, relying on an updated EPA risk assessment methodology to lower these values by approximately threefold. While the limits have changed, the level at which chemical agent facilities "alarm" remains the same. The revised lower worker population limit (WPL) aims to protect workers from exposure to extremely low concentrations of agent. "WPL monitoring is intended to serve as a sentinel or early warning to ensure a safe work environment for workers who do not wear personal protective equipment," a CMA fact sheet says. "The revised, lower WPL serves as an added layer of protection, and is a level at which corrective action can be taken before levels reach the [alarm levels]," another fact sheet says.

The Army previously was concerned about its ability to detect to the new limits (Defense Environment Alert, Oct. 7, 2003, p 14). The Army is at the "southern limit" of its capabilities to monitor in near real-time so it plans to use additional depot area air monitoring system (DAAMS) tubes and add laboratory personnel to meet the new AEL requirements, according to the CMA spokesman. The Army already relies on DAAMS as a passive sampling system that draws air through adsorption tubes that are collected periodically for analysis. They are currently present inside chemical weapons disposal facilities and around the perimeter of depot property.

Citizen activists could not be reached for comment on the Army's compliance plans for meeting the new AELS. The Army's air monitoring program has long been a sticking point for citizens living near the remaining eight chemical weapons storage and disposal sites. Both citizen activists and Congress have called for use of better air monitoring technology at chemical weapons storage and destruction sites, with citizens recently urging lawmakers to support funding for new technology that could provide "real-time" analysis of airborne chemical agents.

The Army has established seven indicators to determine compliance with the new AELs, one of which has been fully met by all of the chemical weapons storage and destruction facilities. Under this indicator, the Army and DOD have provided guidance and documentation to the facilities to resolve multiple policy issues, according to a Dec. 13 Army assessment of compliance. Many of the facilities also have modified their permits to account for the lower AELs, it says.

But there are still issues at some sites that must be overcome, the CMA spokesman says. Under the indicator of "overall performance," Blue Grass Chemical Activity in Kentucky still has serious issues to address before being in compliance, while some facilities are in full compliance and others have done some work toward compliance, according to the assessment. Clarifying guidance from Army officials is needed on this, it says.

Umatilla Chemical Depot in Oregon is the only facility seriously lagging behind in modifying its systems contract to comply with the new AELs, the assessment indicates. And many of the sites have "developed detailed strategies to revise on-site documentation," it says, although Blue Grass Chemical Activity is far from compliant.

Blue Grass Chemical Activity is also behind in procuring and installing new equipment to meet the revised AELs, and in hiring and training new personnel, it says. "Most sites plan to purchase [two] additional Gas Chromatographs," it notes.