Chemical Weapons Disposal: Plans for Nonstockpile Chemical Warfare
Materiel Can Be Improved (Letter Report, 12/20/94, GAO/NSIAD-95-55).
The Army's plans for destroying nonstockpile chemical warfare materiel
are not final and, as a result, its $17.7-billion cost estimate is
uncertain and cannot be used for budget purposes. This uncertainty is
largely because the amount of materiel to be disposed of has not been
fully identified and the disposal methods cannot be selected until the
Army is further along in the environmental assessment and permitting
process. Although the Army has good information about some categories
of nonstockpile materiel, the amount and condition of other materiel are
unknown. For example, the Army knows little about the agents inside
recovered chemical weapons or the nature of contaminated materiel at
former production plants. Also, the Army has little information on the
nature and extent of buried chemical agents, which are estimated to be
located at 215 sites in 33 states, the U.S. Virgin Islands, and
Washington, D.C. The Army will need to comply with federal, state, and
local laws; obtain the necessary environmental approvals and permits;
and address the strong public opposition to chemical weapons
incineration. On the basis of difficulties experienced in the stockpile
disposal program, GAO believes that the Army's estimated cost of the
nonstockpile program is likely to increase and its proposed schedule to
slip.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-95-55
TITLE: Chemical Weapons Disposal: Plans for Nonstockpile Chemical
Warfare Materiel Can Be Improved
DATE: 12/20/94
SUBJECT: Chemical warfare
Hazardous substances
Property disposal
Munitions
Cost analysis
Environmental impact statements
Army supplies
Federal/state relations
Future budget projections
Military materiel
IDENTIFIER: Army Chemical Munitions Stockpile Disposal Program
Army Chemical Munitions Nonstockpile Disposal Program
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Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Environment, Energy, and
Natural Resources, Committee on Government Operations, House of
Representatives
December 1994
CHEMICAL WEAPONS DISPOSAL - PLANS
FOR NONSTOCKPILE CHEMICAL WARFARE
MATERIEL CAN BE IMPROVED
GAO/NSIAD-95-55
Army's Nonstockpile Chemical Weapons
Abbreviations
=============================================================== ABBREV
abc - x
DOD - Department of Defense
Letter
=============================================================== LETTER
B-253645
December 20, 1994
The Honorable Mike Synar
Chairman, Subcommittee on Environment,
Energy, and Natural Resources
Committee on Government Operations
House of Representatives
Dear Mr. Chairman:
This report responds to your request that we review the Department of
the Army's disposal program for chemical munitions, materiel, and
facilities that are not specifically included in the U.S. stockpile
of unitary chemical weapons.\1 These items are referred to as
nonstockpile chemical warfare materiel and consist of binary chemical
weapons, miscellaneous chemical warfare materiel, recovered chemical
weapons, former chemical weapon production facilities, and buried
chemical warfare materiel. As requested, we collected and analyzed
information on (1) the status of the Army's planning process for the
nonstockpile disposal program, (2) the Army's estimated disposal cost
and schedule, and (3) lessons learned from the Army's ongoing
stockpile disposal program that may also apply to the proposed
nonstockpile program. Our scope and methodology are described in
appendix I.
--------------------
\1 A unitary chemical weapon is a munition containing a single lethal
chemical agent.
BACKGROUND
------------------------------------------------------------ Letter :1
In November 1985, the Congress directed the Army to destroy the
Department of Defense's (DOD) stockpile of unitary chemical weapons.
The stockpile is stored at eight Army installations in the
continental United States and one installation on the Johnston Atoll
in the Pacific Ocean. It consists of various lethal weapons, such as
rockets, bombs, and projectiles, and bulk containers that contain
nerve and mustard agents. Exposure to the agents can result in
death.
In 1993, the United States signed the U.N.-sponsored Convention on
the Prohibition of the Development, Production, Stockpiling and the
Use of Chemical Weapons and on Their Destruction, commonly referred
to as the Chemical Weapons Convention. The United States agreed to
dispose of (1) binary chemical weapons, recovered chemical weapons,
and former chemical weapon production facilities within 10 years and
(2) miscellaneous chemical warfare materiel within 5 years of the
date the convention becomes effective. If ratified by the U.S.
Senate, the convention becomes effective 180 days after the 65th
nation ratifies the treaty, but not sooner than January 13, 1995.
Under the terms of the convention, chemical weapons buried prior to
1977 are exempt from disposal as long as they remain buried. In the
United States, burial was a common disposal method for chemical
warfare materiel until the late 1950s. Should the United States
choose to excavate the sites and remove the chemical weapons, the
provisions of the convention would apply. DOD officials estimate
that the convention will enter into force in fiscal year 1996.
In the fiscal year 1993 National Defense Authorization Act (P.L.
102-484), the Congress directed the Army to report on its plans for
disposing of all nonstockpile chemical warfare materiel within the
United States. In 1993, the Army issued a report describing the
nonstockpile chemical materiel, potential disposal methods,
transportation alternatives, and disposal cost and schedule
estimates.\2 The report concluded that it would cost the Army $1.1
billion ($930 million in direct project disposal costs and $170
million in programmatic costs) to destroy, primarily by incineration,
demolition, and neutralization,\3 the nonstockpile chemical materiel
required by the convention within the required time frames.
Programmatic costs are associated with more than one disposal project
or program category. For example, the portion of management and
personnel costs that support more than one project is considered
programmatic costs. Also, estimated costs to procure and test
equipment to be used at more than one site are included in the
programmatic cost estimate. The Army also reported that it would
cost $16.6 billion ($12.04 billion in direct disposal costs and $4.56
billion in programmatic costs) to recover and destroy, primarily by
incineration and neutralization, buried chemical materiel within 40
years. These estimates are considered rough order of magnitude
estimates, typically used when a program is not fully developed.
According to program officials, the Army plans to issue a supplement
to its 1993 survey and analysis report, which will include revised
cost and schedule estimates, in mid-1995. Appendix II describes the
Army's nonstockpile chemical warfare materiel.
The Army Chemical Demilitarization and Remediation Activity, formerly
named the Army Chemical Materiel Destruction Agency, is responsible
for storing, transporting, and disposing of nonstockpile chemical
warfare materiel. The extent to which other federal and state
agencies will be involved in the program depends on the location and
particulars of the nonstockpile chemical materiel. Appendix III
describes federal and state agencies' roles and responsibilities for
the nonstockpile disposal program.
--------------------
\2 Survey and Analysis Report: Non-Stockpile Chemical Materiel
Program, U.S. Army Chemical Materiel Destruction Agency (Nov.
1993).
\3 The neutralization process involves altering the chemical,
physical, and toxicological properties of the chemical agent to
render it ineffective for use as intended. The process may be
followed by incineration of the remaining materiel.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :2
The Army's plans for destroying nonstockpile chemical warfare
materiel are not final and, as a result, its $17.7-billion cost
estimate is uncertain and cannot be used for budget purposes. This
uncertainty is largely because the amount of materiel to be disposed
of has not been fully identified and the disposal methods cannot be
selected until the Army is further along in the environmental
assessment and permitting process. Although the Army has good
information about some categories of nonstockpile materiel, the
amount and condition of other materiel are unknown. For example, the
Army knows little about the agents inside recovered chemical weapons
or the nature of contaminated materiel at former production
facilities. Also, the Army has limited and often imprecise
information about the nature and extent of buried chemical warfare
materiel, which are estimated to be located at 215 sites in 33
states, the U.S. Virgin Islands, and Washington, D.C. Although the
Army has determined that 30 of the 215 burial sites warrant no
further remediation activity, the nature and extent of buried
chemical warfare materiel at the other sites will remain unknown
prior to excavation, and additional burial sites may be identified.
The Army's cost and schedule estimates, and its ability to complete
the nonstockpile chemical disposal program, are likely to be affected
by issues similar to those experienced in the stockpile disposal
program. These include actions necessary to comply with federal,
state, and local laws and requirements; obtain the necessary
environmental approvals and permits; and address the strong public
opposition to chemical weapons incineration.\4 In addition, the Army
has limited experience destroying nonstockpile chemical materiel and
is unfamiliar with what types of environmental and technical problems
to expect. Based on the difficulties experienced in the stockpile
disposal program, the Army's estimated cost of the nonstockpile
disposal program is likely to increase and its proposed schedule to
slip.
--------------------
\4 The baseline incineration process involves a disassembly procedure
that breaks down munitions into their component parts. Once
disassembled, the chemical agent and components are burned separately
in high temperature furnaces.
THE ARMY'S PLANNING PROCESS AND
COST AND DISPOSAL ESTIMATES ARE
AFFECTED BY UNCERTAINTIES
------------------------------------------------------------ Letter :3
As of November 1994, the Army had not issued a comprehensive
implementation plan to dispose of nonstockpile chemical warfare
materiel. Moreover, based on the Army's experience with the
stockpile disposal program, it is likely to be several years before
the Army can develop a disposal plan that includes reliable cost and
schedule estimates.\5 The Army's 1993 report provides an initial
scoping of the magnitude of effort required to safely destroy all
nonstockpile chemical materiel in the United States if so directed.
However, because of uncertainties about the nature and magnitude of
the materiel or the disposal methods to be used, the Army recognizes
that its $17.7-billion cost estimate for the nonstockpile disposal
program cannot be relied on for budget purposes. Appendix IV lists
the disposal methods used by the Army to develop its program cost and
schedule estimates.
Whenever possible, the Army plans to dispose of nonstockpile chemical
materiel on-site. However, there may be occasions when it is not
feasible or practical for the Army to do so, and transportation to
another disposal location may be required. Factors the Army intends
to consider are population proximity and density, chemical weapon
type, condition of the munitions, and public safety and environmental
policy. In addition, the opinions and concerns of the affected
states, local governments, and the public will affect the Army's
decisions. For example, there is strong public opposition to
incineration and transportation of chemical weapons across state
boundaries.
The Army's level of knowledge and stage of planning by category of
nonstockpile materiel are summarized in table 1.
Table 1
Summary of the Army's Level of Knowledge
and Stage of Planning, Including
Disposal Cost and Schedule Estimates
(Dollars in billions)
Disposa
Number l cost Time
of estimat frame
Category Characteristic sites e (years)
------------------------ --------------------------- ------- ------- -------
Binary chemical weapons The locations and 4 $0.19 10
quantities are well-
documented. The nature of
the chemical elements and
the components are
understood by the Army.
Miscellaneous chemical The locations and 10 0.21 5
warfare materiel quantities are well-
documented, and most
materiel are not
contaminated with a
chemical agent.
Recovered chemical The locations and 6 0.11 10
weapons quantities are well-
documented, but the
inventory will change as
additional weapons are
recovered. The chemical
fill of 25 percent of the
weapons is unknown, and
the weapons are likely to
be in deteriorated
condition.
Former chemical weapon The facilities that are to 4 0.42 10
production facilities be destroyed have been
identified. However, the
levels of contamination
and deterioration are
unknown.
Buried chemical warfare The actual amount, chemical 215 12.04 40
materiel agent, condition, and type
of materiel are unknown,
and the number and
locations of potential
burial sites are
uncertain. The Army has
limited experience in
disposing of buried
chemical materiel.
Programmatic costs The estimated programmatic a 4.73 a
costs are based on little
actual experience, limited
data, and key uncertain
assumptions.
================================================================================
Total cost $17.70
--------------------------------------------------------------------------------
\a Not applicable.
Source: Based on the Army's 1993 Survey and Analysis Report.
--------------------
\5 In November 1985, the Congress directed the Army to destroy the
DOD stockpile of unitary chemical weapons. Nine years later, the
stockpile disposal program continues to experience cost growth and
schedule slippages.
BINARY CHEMICAL WEAPONS
---------------------------------------------------------- Letter :3.1
The locations and quantities of binary chemical weapons are
well-documented and understood by the Army. Binary weapon systems
principally involve an artillery projectile and components of the
bigeye bomb. The projectile is composed of chemical elements, a
metal casing, and explosive components. Although the bigeye bomb was
never produced or stockpiled, some associated chemical elements must
be destroyed.
Although the method for destroying binary chemical weapons has not
been determined, the Army estimates that, subject to the availability
of funds, it can destroy the binary weapons within 10 years for $190
million. According to Army officials, the chemical elements in
binary weapons are not lethal agents until they are combined during
flight to a target; therefore, handling and disposing of the chemical
elements and components should not pose any major problems. Some of
the disposal options being considered for binary weapon components
are incineration, landfill, crushing, and smelting. The actual
disposal method will be selected by the Army after a comprehensive
environmental review.
MISCELLANEOUS CHEMICAL
WARFARE MATERIEL
---------------------------------------------------------- Letter :3.2
The Army has a good understanding of miscellaneous chemical warfare
materiel to be destroyed and has documented them by location,
configuration, quantity, and type. However, changes are likely to
occur as materiel is added or deleted as a result of the Chemical
Weapons Convention verification process. The materiel is
predominantly metal containers and munitions components. Some of the
components contain explosive charges that may need to be extracted
before disposal.
Despite an uncertainty about the disposal method, the Army estimates
that, subject to the availability of funds, it can destroy the
miscellaneous chemical warfare materiel within 5 years for $210
million. According to Army officials, disposal options are numerous
since most of the materiel is not contaminated with a chemical agent.
The options include incineration, smelting, and crushing. However,
the decision on disposal methods will be based on (1) the location,
configuration, and type of materiel, (2) results of the required
environmental analyses and studies, and (3) input from the affected
states, local governments, and the general public.
RECOVERED CHEMICAL WEAPONS
---------------------------------------------------------- Letter :3.3
The Army has some information on the recovered chemical weapons that
it must dispose of, but the inventory will change as additional
weapons are recovered. According to Army documents, chemical weapons
have been recovered from range-clearing operations, chemical burial
sites, and research and development test areas. As of November 1993,
there were 7,056 recovered chemical items in the Army's inventory,
consisting of mortar cartridges, projectiles, bombs, German rockets,
chemical agent identification sets, and bulk containers.
With appropriate funding, the Army estimates that the destruction of
recovered chemical items can be completed within 10 years, at a cost
of $110 million. The Army believes that handling and disposing of
recovered chemical weapons will be difficult as (1) they are more
likely to have deteriorated than other nonstockpile materiel and (2)
the identity of the agent is unknown in 25 percent of the weapons.
The Army is studying several destruction options, including
transportable incineration and neutralization systems. However, the
actual method for destroying the recovered chemical weapons cannot be
selected until after the Army completes the required technical and
environmental studies.
FORMER CHEMICAL WEAPON
PRODUCTION FACILITIES
---------------------------------------------------------- Letter :3.4
The Army has identified former chemical weapon production facilities
that need to be cleaned up. They consist of buildings and equipment
for producing, loading, storing, and assembling chemical munitions
and agents. These facilities are located in four states and are in
various degrees of contamination and deterioration.
The Army estimates that it will take 10 years and $420 million to
dispose of former chemical weapon production facilities. However,
the Army has no experience in destroying former production facilities
in compliance with the Chemical Weapons Convention. It is still in
the process of determining the levels of contamination, identifying
potential problems in the demolition process, and determining how to
safely dispose of the buildings and their components. Some of the
disposal options being considered are incineration of contaminated
materiel and demolition of uncontaminated facilities and equipment.
The final disposal decision will not be made until comprehensive
environmental studies are completed with the participation of the
affected states, local governments, and the public.
BURIED CHEMICAL WARFARE
MATERIEL
---------------------------------------------------------- Letter :3.5
The Army has limited and often imprecise information about the nature
and extent of buried chemical materiel. However, it has begun to
develop site characterization, excavation, removal, and treatment
procedures for the burial sites. Since burial was considered to be
the final disposal act, little record-keeping was done for burial
activities and additional sites are likely to be identified.
Available records indicate that some burial sites may still contain
active chemical agents and explosives; therefore, they pose a threat
to human health and the environment.
According to Army officials, the lack of knowledge about buried
chemical warfare materiel has created considerable difficulty in
selecting appropriate disposal methods. The Army has conducted
various analyses, including comprehensive documentation surveys, site
visits, and interviews, to identify potential burial sites. Even at
well-documented sites, the actual amount, chemical agent, condition,
and type of buried materiel will remain relatively unknown prior to
excavation and visual identification. Based on preliminary analyses,
the Army has identified potential chemical warfare materiel at 215
burial sites in 33 states, the U.S. Virgin Islands, and Washington,
D.C. (See fig. 1.) The Army has determined that 30 of the 215
potential burial sites warrant no further remediation activity. This
determination is based on the Army's site assessment, prior completed
remedial work, or the restricted accessibility of the site.
Figure 1: Potential Chemical
Warfare Materiel Burial Sites
(See figure in printed
edition.)
Note: According to Army
officials, the potential burial
sites in Kansas, New York,
Virginia, and Washington do not
require additional remediation
activities. The remaining 29
states contain one or more
potential burial sites that
require further analyses and
appropriate actions.
(See figure in printed
edition.)
The Army is studying (1) several different on-site disposal
technologies, (2) the plausibility of leaving the materiel in the
ground while controlling access to the site and containing potential
contamination, and (3) transportation of the materiel to an Army
facility capable of storage and destruction. Prior to excavation,
the Army will conduct soil samples and metal detection surveys as
well as install monitoring wells to estimate the nature and extent of
contamination and develop remedial alternatives. The Army could
excavate by hand, which has been frequently used in the past. It is
also studying the use of robotics in excavating buried materiel,
although acceptable technology is not readily available. According
to Army officials, mechanical means are more likely to cause a
chemical release or detonation. The actual excavation method for
recovering buried chemical warfare materiel cannot be selected until
the Army completes further technical and environmental studies and
the public has been involved in the Army's selection.
The Army estimates that it will cost $12.04 billion, plus $4.56
billion in programmatic costs, and take 40 years to recover and
dispose of the buried chemical materiel. It included the estimated
costs (1) of fixed incinerators for three of the four large burial
sites, (2) for capping the remaining large site, and (3) of
transportable incineration and neutralization systems for small
sites. The transportable incineration and neutralization systems,
when developed, will comply with safety and environmental
requirements and be capable of moving or being moved from one
disposal site to another. The Army expects the systems will use a
batch-style process to treat relatively small quantities of chemical
warfare materiel.
Appendix V contains our case study of the Army's investigation and
disposal activities at the Spring Valley chemical burial site in
Washington, D.C. Remediation of the Spring Valley site took 2 years
and cost $20.22 million. The recovered chemical warfare materiel has
not yet been destroyed.
LESSONS FROM THE STOCKPILE
DISPOSAL PROGRAM SHOULD BE
APPLIED TO THE NONSTOCKPILE
PLANNING PROCESS AND COST AND
SCHEDULE ESTIMATES
------------------------------------------------------------ Letter :4
Because both chemical disposal programs involve similar environmental
requirements and potentially similar disposal methods, many of the
lessons learned from the stockpile disposal program may apply to the
nonstockpile program. In the 1990s, we reported that the Army did
not adequately anticipate and plan for (1) the time needed to obtain
the necessary environmental approvals and permits for the stockpile
disposal program and (2) the strong public opposition to the chemical
weapons incineration process.\6 Further, we reported that the
stockpile program had been delayed by design, equipment, and
construction problems at the new disposal facility at Johnston Atoll.
As a result of these factors, the estimated cost of the stockpile
disposal program increased and the Army's destruction schedule
slipped.
According to Army officials, they have applied some lessons learned,
such as the Army's experience with environmental compliance
procedures and research of alternative disposal methods from the
stockpile program, to the nonstockpile disposal program. However,
lessons learned were not discussed in the Army's 1993 survey and
analysis report on the nonstockpile program. In addition, because
the Army based its disposal program and estimates on numerous
assumptions as well as generic cost categories and work statements,
we could not determine the effects of the lessons on the Army's
nonstockpile planning process and estimates.
--------------------
\6 Chemical Weapons: Obstacles to the Army's Plan to Destroy
Obsolete U.S. Stockpile (GAO/NSIAD-90-155, May 24, 1990); Chemical
Weapons: Stockpile Destruction Cost Growth and Schedule Slippages
Are Likely to Continue (GAO/NSIAD-92-18, Nov. 20, 1991); Chemical
Weapons Destruction: Issues Affecting Program Cost, Schedule, and
Performance (GAO/NSIAD-93-50, Jan. 21, 1993); and Chemical Weapons
Destruction: Advantages and Disadvantages of Alternatives to
Incineration (GAO/NSIAD-94-123, Mar. 18, 1994).
OBTAINING ENVIRONMENTAL
APPROVALS AND PERMITS MAY
TAKE LONGER THAN ANTICIPATED
---------------------------------------------------------- Letter :4.1
Prior to recovering, storing, moving, or destroying nonstockpile
chemical warfare materiel, the Army must comply with federal and
state environmental laws and regulations. These laws and regulations
differ from state to state and change frequently. In its 1993
report, the Army reported that changes to environmental regulations
could significantly affect its estimated disposal cost and schedule
for the nonstockpile disposal program. Even when state regulatory
agencies grant the Army permission to recover, move, or dispose of
nonstockpile materiel, the Army is not insulated from legal actions
by concerned citizens and groups. Previously, we reported that
because of the Army's difficulty in anticipating the time needed to
comply with environmental requirements and to obtain environmental
approvals and permits, the chemical stockpile disposal program cost
more and took longer than planned.
Army facilities must have environmental permits for the storage and
disposal of the nonstockpile chemical materiel, and the methods for
transporting and disposing of the materiel must adhere to appropriate
environmental regulations and be based on comprehensive studies. In
general, state governments are authorized, under federal
environmental statutes, to adopt federal concepts and to promulgate
and implement additional rules and regulations, which in some
instances, are more stringent than federal standards. For example:
The Resource Conservation and Recovery Act, as amended, is likely to
apply to most aspects, including transportation and storage, of the
nonstockpile disposal program. Under the act, the Environmental
Protection Agency may authorize individual states to administer and
enforce hazardous waste programs in lieu of the federal program. The
act also allows states to establish requirements more stringent than
federal standards. For example, the states of Kentucky and Indiana
enacted legislation that require the Army to demonstrate the absence
of any acute or chronic health or environmental effects from
incineration of chemical weapons before an environmental permit will
be granted. There are miscellaneous chemical warfare materiel,
former chemical weapon production facilities, and five potential
burial sites located in these states.
The Comprehensive Environmental Response, Compensation, and Liability
Act provides overall cleanup procedures for nonstockpile sites and
incorporates the standards of other federal and state statutes if
they are applicable or relevant and appropriate to the cleanup
process. A specific sequence of activities, guaranteeing the
participation of federal and state agencies and the public in key
decisions, must be followed before cleanup of a nonstockpile site
proceeds.
The Hazardous Materials Transportation Act governs the transportation
of most nonstockpile chemical materiel and limits the movement of the
materiel without special permits, licenses, and authorizations. The
act delegates regulatory and enforcement responsibilities to the
states but limits some state regulations. Nevertheless, states may
still implement routing restrictions, transportation curfews,
notification deadlines, and public right-to-know requirements. The
Army anticipates that each state the materiel originates in, passes
through, or terminates in will have some jurisdiction over part of
the transportation program.
The nonstockpile disposal program has not reached the stage where
appropriate laws, regulations, and concerns can be specifically
identified for each location with nonstockpile chemical materiel.
The applicability of laws and regulations to the recovery,
transportation, storage, and disposal of nonstockpile materiel
ultimately depends on the circumstances of the materiel. The
participation of the states, local governments, and the public also
affects the Army's decisions concerning the transportation and
disposal of the nonstockpile materiel. With respect to the
nonstockpile program, the Army's planning process must cover at least
185 potential burial sites with various environmental conditions and
considerations,
29 different states with state-oriented environmental laws and
regulations, numerous local governments, and the general public.
STRONG PUBLIC OPPOSITION TO
INCINERATION
---------------------------------------------------------- Letter :4.2
As demonstrated in the stockpile disposal program, there is
considerable public opposition to the incineration of chemical
munitions or agents. However, the Army based its 1993 preliminary
cost and schedule estimates on the use of incinerators to destroy
potentially large portions of its nonstockpile chemical materiel.
The opposition centers around concerns about adverse health effects
and environmental hazards. This opposition, which has come from
several citizen groups, environmental organizations, and state
governments, has extended the environmental review and approval
process and resulted in postponing the construction and operation of
fixed incinerators. The actual disposal methods for the nonstockpile
program will be selected by the Army after comprehensive
environmental reviews are completed with the participation of the
affected states, local governments, and public.
In our 1994 report on the stockpile disposal program, we concluded
that alternative technologies were unlikely to reach maturity in time
to destroy the chemical weapons stockpile because they are in the
initial development stages and over a decade away from full
operations. Similarly, it is unlikely that these alternative
technologies, if ever operational, will be available within the
Chemical Weapons Convention's established time frames for the
nonstockpile disposal program. According to Army officials, they
believe that the neutralization process will be operational in the
1996-97 time frame. The Environmental Protection Agency has stated
that any proposed chemical disposal technology would have to undergo
the same type of rigorous analysis and evaluation that the
incineration process has gone through--a process that has required at
least 9 years.
POTENTIAL TECHNICAL AND
MECHANICAL PROBLEMS
---------------------------------------------------------- Letter :4.3
The nonstockpile disposal program is vulnerable to change because it
depends on disposal methods and destruction rates that have not been
demonstrated. In our 1991 report on the stockpile program's cost
growth and schedule slippages, we concluded that the Army had limited
experience with destroying stockpile chemical weapons and was
unfamiliar with types of technical and mechanical problems to expect.
As a result of these problems, the Army has not achieved its expected
disposal rates for the stockpile program. Similarly, no nonstockpile
chemical disposal project has been completed. Therefore, little
procedure, cost, schedule, or engineering data are available, and the
Army's proposed disposal methods and estimated destruction rates have
not yet been demonstrated. In its 1993 report, the Army concluded
that the technical risk for the nonstockpile disposal program was
high because none of the disposal projects were completed. The Army
also concluded that if effective processes or procedures were not
discovered, it would have to fund "a major research and development
program."
The Army has reported that unforeseen events, such as an accidental
chemical release or explosion, would increase the cost and duration
of the nonstockpile disposal program. For example, the Army's
stockpile disposal facility at Johnston Atoll was shut down on March
23, 1994, and restarted again on July 12, 1994, because of a chemical
agent release. According to Army officials, the release was
small--approximately
11 milligrams. In addition, because of a hurricane and subsequent
damage, the Johnston stockpile disposal facility was shut down on
August 25, 1994, for more than 2 months.
RECOMMENDATIONS TO THE
SECRETARY OF THE ARMY
------------------------------------------------------------ Letter :5
We recommend that the Secretary of the Army
ensure that lessons learned from the stockpile disposal program are
systematically incorporated into the nonstockpile planning process
and
establish milestones for developing accurate and complete cost data
to effectively plan for and control future program expenditures.
---------------------------------------------------------- Letter :5.1
We conducted our review from June 1993 to November 1994 in accordance
with generally accepted government auditing standards.
Unless you publicly announce this report's contents earlier, we plan
no further distribution until 30 days from its issue date. At that
time, we will send copies to the Chairmen, House and Senate
Committees on Armed Services and on Appropriations; the Secretaries
of Defense and the Army; the Director of the Office of Management and
Budget; and other interested parties. We will make copies available
to others upon request.
Please contact me at (202) 512-8412 if you or your staff have any
questions. Major contributors to this report are listed in appendix
VI.
Sincerely yours,
Donna M. Heivilin
Director, Defense Management
and NASA Issues
SCOPE AND METHODOLOGY
=========================================================== Appendix I
In reviewing the Army's nonstockpile chemical disposal program, we
interviewed and obtained data from officials of the Department of
Defense (DOD), the Department of the Army, the Army Chemical
Demilitarization and Remediation Activity, the Army Chemical and
Biological Defense Agency, and the U.S. Army Corps of Engineers. We
also met with U.S. Environmental Protection Agency officials to
discuss and collect data on environmental and legal issues related to
the nonstockpile disposal program. We did not include overseas
abandoned chemical warfare materiel in our review.
To identify lessons learned from the Army's stockpile disposal
program, we reviewed our previous reports and testimonies and their
supporting documentation. To assess the estimated disposal cost and
schedule, we analyzed pertinent documentation and discussed the
estimation methodology and problems that could affect the cost and
duration of the program with Army and contractor officials. To
assess the extent and nature of the nonstockpile disposal program, we
visited Aberdeen Proving Ground, Maryland; Rocky Mountain Arsenal,
Colorado; the former Raritan Arsenal, New Jersey; and the Spring
Valley site, Washington, D.C.
As requested, we did not obtain official agency comments, but we
discussed our findings with officials from DOD and the Army and
incorporated their views where appropriate.
DESCRIPTION OF THE ARMY'S
NONSTOCKPILE CHEMICAL WARFARE
MATERIEL
========================================================== Appendix II
Binary chemical weapons: Chemical weapons formed from two nonlethal
elements (called precursors) through a chemical reaction after the
munitions are fired or launched. Binary weapons were manufactured,
stored, and transported with only one of the chemical elements in the
weapon. The second element was to be loaded into the weapon at the
battlefield. As of November 1993, the precursors for the binary
chemical weapons are stored at Aberdeen Proving Ground, Maryland;
Pine Bluff Arsenal, Arkansas; Tooele Army Depot, Utah; and Umatilla
Depot Activity, Oregon.
Miscellaneous chemical warfare materiel: Materiel designed for use
in the employment of chemical weapons, including unfilled munitions
and components and support equipment and devices. According to Army
records, miscellaneous materiel are stored at the Aberdeen Proving
Ground, Maryland; Anniston Army Depot, Alabama; Blue Grass Army
Depot, Kentucky; Dugway Proving Ground, Utah; Johnston Atoll, Pacific
Ocean; Newport Army Ammunition Plant, Indiana; Pine Bluff Arsenal,
Arkansas; Pueblo Depot Activity, Colorado; Tooele Army Depot, Utah;
and Umatilla Army Depot Activity, Oregon.
Recovered chemical weapons: Chemical weapons recovered from
range-clearing operations, chemical burial sites, and research and
development test areas. According to the Army's 1993 report,
recovered items are stored at Aberdeen Proving Ground, Maryland;
Anniston Army Depot, Alabama; Dugway Proving Ground, Utah; Johnston
Atoll, Pacific Ocean; Pine Bluff Arsenal, Arkansas; and Tooele Army
Depot, Utah.
Former chemical weapon production facilities: Government-owned or
-contracted facilities used to (1) produce chemical agents,
precursors for chemical agents, or other components for chemical
weapons or (2) load or fill chemical weapons. These facilities are
located at Aberdeen Proving Ground, Maryland; Newport Army Ammunition
Plant, Indiana; Pine Bluff Arsenal, Arkansas; and Rocky Mountain
Arsenal, Colorado.
Buried chemical warfare materiel: Chemical warfare materiel, which
are buried on both private lands and military installations,
consisting of various munitions, bombs, rockets, and containers that
may have been contaminated with nerve, blister, blood, or choking
agents. At some sites, chemical munitions and agents were drained
into holes in the ground, covered with lime or burned in an open pit,
and finally covered with earth. Based on preliminary analyses, the
Army has identified potential chemical warfare materiel at 215 burial
sites in 33 states, the U.S. Virgin Islands, and Washington, D.C.
The Army has determined that 30 of the 215 potential burial sites
warrant no further remediation activity. This determination is based
on the Army's assessment of the potential burial site, prior remedial
work, or accessibility to the site.
ROLES AND RESPONSIBILITIES FOR THE
NONSTOCKPILE CHEMICAL WARFARE
DISPOSAL PROGRAM
========================================================= Appendix III
The U.S. Army Chemical Demilitarization and Remediation Activity is
responsible for implementing the destruction of all U.S. chemical
warfare-related materiel, including the chemical weapons stockpile
and nonstockpile chemical materiel, and for ensuring maximum
protection to the environment, general public, and personnel involved
in the destruction. The activity's office of Program Manager for
Nonstockpile Chemical Materiel is responsible for
collecting and analyzing data on nonstockpile chemical materiel;
identifying and assessing sites with possible buried chemical warfare
materiel;
coordinating the transportation of recovered chemical weapons to
locations for interim storage;
destroying recovered chemical warfare materiel on-site as needed to
protect the general public and environment;
researching, developing, evaluating, and selecting disposal methods
for all nonstockpile chemical materiel;
destroying binary chemical weapons, miscellaneous chemical warfare
materiel, recovered chemical weapons, and former production
facilities in accordance with the Chemical Weapons Convention, in
compliance with public safety and environmental requirements and
regulations, and in coordination with the potentially affected
public; and
reclaiming and destroying buried chemical warfare materiel in the
interest of safeguarding the general public and environment.
Although the Army Chemical Demilitarization and Remediation Activity
has overall responsibility for disposing of nonstockpile chemical
materiel, other organizations within or outside DOD contribute to the
disposal program. The involvement of the following organizations
depends on the location and particulars of the materiel, storage
area, or burial site:
The Army Corps of Engineers provides technical support for site
investigations, recoveries, and site restorations to Army and DOD
organizations and is responsible for cleaning up formerly used
defense sites. Restoration activities concerning the handling and
disposal of nonstockpile chemical warfare materiel are coordinated
with and authorized by the Army Chemical Demilitarization and
Remediation Activity.
The Technical Escort Unit, the Army Chemical and Biological Defense
Agency, is responsible for the escort of nonstockpile chemical
materiel, emergency destruction of chemical munitions, and emergency
response to chemical agent incidents.
The Army Environmental Center develops and oversees environmental
policies and programs for the Army.
The Army Surgeon General's office provides advice to Army commands on
health and safety issues related to handling, transporting, and
processing chemical agents and materiel.
The Air Force Civil Engineer provides program management and
technical support to Air Force commands and installations on
environmental compliance and restoration programs.
The Environmental Protection, Safety & Occupational Health Division,
Office of Naval Operations, provides environmental policy and
management support to Navy activities on environmental or
safety-related programs.
The Office of Installation Services and Environmental Protection,
Defense Logistics Agency, provides environmental policy and
management support to the agency's field commands and installations.
The U.S. Environmental Protection Agency enforces federal laws
protecting the environment and ensures that regulations mandated by
federal statutes are followed.
The U.S. Department of Health and Human Services reviews and
provides recommendations on the Army's plans to transport or destroy
chemical warfare materiel in order to help ensure public health and
safety.
The Occupational Safety and Health Administration oversees and
regulates safety and health conditions at the workplace.
The U.S. Department of Transportation enforces regulations governing
the transportation of hazardous or nonhazardous materiel.
State governments and communities affected by the nonstockpile
disposal program provide information for and have input into the
Army's decision-making process. They also review and comment on the
Army's planning and decision documents; grant necessary permits; and
monitor and enforce their state, regional, and local statutes.
The responsibilities for remedial activities differ between burial
sites located on active defense installations and formerly used
defense sites. At active installations, the installation commander
has overall responsibility for remedial activities at the potential
burial sites. The Army Corps of Engineers and the Army Environmental
Center support the installation commander in site investigation,
excavation, and environmental cleanup. At formerly used defense
sites, the Corps of Engineers has overall responsibility for site
investigations, planning, excavations, and environmental cleanups of
the potential burial sites. In both instances, the Army Chemical
Demilitarization and Remediation Activity is responsible for the
transportation, interim storage, and destruction of recovered
chemical warfare materiel. The activity is also responsible for the
development of the equipment and technologies to safely dispose of
the materiel.
DISPOSAL METHODS USED BY THE ARMY
TO DEVELOP THE 1993 PROGRAM COST
AND SCHEDULE ESTIMATES
========================================================== Appendix IV
Category Disposal method
----------------------------- -----------------------------
Binary chemical weapons
------------------------------------------------------------
Liquid precursors Off-site incineration
Sulfur Landfill
Metal bodies and other Crushing and smelting
uncontaminated materiel
Miscellaneous chemical warfare materiel
------------------------------------------------------------
Energetic materiel, such as Incineration
fuses,
bursters, and propellants
Uncontaminated metal parts Crushing and smelting
and
materiel
Recovered chemical weapons Neutralization\a
Former chemical weapon production facilities
------------------------------------------------------------
Contaminated materiel Incineration
Uncontaminated equipment and Demolition
facilities
Buried chemical warfare materiel
------------------------------------------------------------
Large quantity, explosive Large fixed incineration
sites
Small quantity, explosive Portable incineration
sites\b
Small quantity, nonexplosive Portable neutralization\a
sites\b
Chemical agent identification Portable neutralization\a
sets
------------------------------------------------------------
\a The neutralization process may be followed by incineration of the
remaining materiel.
\b Small sites are less than 10 acres, and the total excavation
volume is less than 1,000 cubic yards.
CASE STUDY: INVESTIGATION AND
DISPOSAL ACTIVITIES AT THE SPRING
VALLEY SITE IN WASHINGTON, D.C.
=========================================================== Appendix V
In January 1993, a construction crew unearthed World War I-era
chemical and high-explosive munitions during routine residential
construction activities in an area known as Spring Valley in
Washington, D.C., setting in motion emergency recovery and removal
operations, called phase I of Operation Safe Removal. Over 140
items, including mortars, projectiles, and debris, were recovered and
removed from the area by the Army's Chemical and Biological Defense
Agency during this phase. Some of the recovered items were
subsequently analyzed and determined to contain chemical agents. The
Army Corps of Engineers is currently proceeding with phase II of
Operation Safe Removal, which is the comprehensive investigation and
cleanup of the Spring Valley site under the Defense Environmental
Restoration Program.
HISTORY OF THE SPRING VALLEY SITE
In 1917, the Chemical Warfare Service of the U.S. Bureau of Mines
leased 92 acres from American University to establish the American
University Experiment Station. The station was used by the Chemical
Warfare Service, with personnel from the Army and the Navy, to
research and conduct testing of chemical warfare items.
Subsequently, additional land was leased northwest of American
University to field test the chemicals and munitions developed at the
station. In 1918, the Chemical Warfare Service was transferred from
the Bureau of Mines to the War Department, and the station was
renamed Camp American University Experiment Station, encompassing a
total of 425 acres. During this period, the War Department also
leased 84 acres northeast of American University to establish Camp
Leach. This camp had mainly tents and barracks, along with staging
and training areas for troops. According to the Army, no chemical
testing was conducted at Camp Leach.
From mid-1917 through 1918, 100,000 troops were trained in trench
warfare and the handling of chemical munitions at Camps American
University and Leach. In addition, mortars and projectiles were
test-fired and chemical munitions were tested in various areas of the
camps. The American University Experiment Station was also used to
prepare and test chemical warfare agents and munitions for possible
use in gas warfare;
develop procedures and methods to produce chemical warfare agents and
munitions; and
develop gas masks, protective clothing, canisters, incendiaries,
smokes, and signals.
In December 1918, the War Department discontinued using Camps
American University and Leach and burned all temporary buildings that
had become unusable. In 1920, the department vacated the remaining
buildings. The trenches and pits were filled in and the land
returned to the original owners. Between 1942 and 1946, the
Department of the Navy leased 5 acres and 15 buildings from American
University to establish the Navy Bomb Disposal School. The Navy used
the property and buildings for educational purposes.
DESCRIPTION OF THE SPRING VALLEY
SITE
The Spring Valley site is a residential community located in
northwest Washington, D.C., near the American University, schools,
churches, a community park, hospital, a theological seminary, a new
housing development project, and approximately 1,200 residences. The
community is comprised of upper middle and upper income families, and
the houses are valued from $600,000 to $1 million. The area
immediately surrounding the initial discovery site consists of
recently constructed or under-construction homes. Since the initial
discovery of the munitions, the area of concern expanded to
approximately 616 acres based on archival records.
TWO PHASES OF OPERATION SAFE
REMOVAL
Operation Safe Removal is conducted under the Comprehensive
Environmental Response, Compensation, and Liability Act procedures
and provisions in two operational phases. The Chemical and
Biological Defense Agency was responsible for phase I, or the
emergency recovery and removal operational phase. Phase I was
completed on February 2, 1993. The Army Corps of Engineers is
proceeding with phase II, or the long-term investigation and cleanup
operational phase of the site with the fieldwork scheduled to be
completed in January 1995.
PHASE I IS COMPLETED
------------------------------------------------------- Appendix V:0.1
On January 5, 1993, a construction crew unearthed a World War I-era
chemical and high-explosive munitions disposal pit while installing a
sewer line in the Spring Valley area. This discovery set in motion
phase I of Operation Safe Removal.
Shortly after the discovery, the Army's emergency response force
confirmed that several of the unearthed munitions were filled with
chemical warfare materiel. Personnel in protective clothing
recovered the visible munitions, sifted through the dirt piles, and
segregated the liquid- and solid-filled munitions. During this
period, residents of the Spring Valley area were evacuated. On the
third day of the initial discovery, the Army activated a service
response force to complete the removal operation. The service
response force consisted of specialists to coordinate the on-site
safety, security, and medical support; historical research; public
affairs; hazard analysis; legal advice; environmental issues; and
transportation of the recovered munitions. Within a few days,
specialists from the Army Corps of Engineers, Army Chemical
Demilitarization and Remediation Activity, Environmental Protection
Agency, Federal Emergency Management Agency, Centers for Disease
Control, Occupational Safety and Health Administration, American
National Red Cross, local police and fire departments, and others
were on-site.
Numerous miscellaneous items, tons of scrap, and over 140 munitions
were removed from the Spring Valley site during phase I. Most
liquid-filled munitions were flown off-site by helicopter to Andrews
Air Force Base, Maryland, and then air-shipped to Pine Bluff Arsenal,
Arkansas, for storage. The solid-filled munitions were flown to Fort
A.P. Hill, Virginia, for explosive destruction. The miscellaneous
items were moved off-site for testing, and the scrap materiel were
sent to a landfill in New York. Both on-site and off-site analyses
confirmed that some of the recovered munitions contained or at one
time contained chemical or toxic smoke agents. Table V.1 shows the
disposition of the recovered materiel.
Table V.1
Disposition of Materiel Removed From the
Spring Valley Site During Phase I
Recovered Amount
materiel removed Destination Purpose
-------------- ---------- -------------------- ----------
Suspected 35 rounds Pine Bluff Arsenal, Storage
chemical Arkansas
rounds
9 rounds Aberdeen Proving Testing
Ground, Maryland
Conventional 97 items Fort A.P. Hill, Detonation
explosive Virginia
rounds
and components
Miscellaneous Several Aberdeen Proving Testing
items items Ground, Maryland
Scrap materiel Several Landfill site in New Disposal
tons York
------------------------------------------------------------
PHASE II FIELDWORK IS
SCHEDULED TO BE COMPLETED IN
JANUARY 1995
------------------------------------------------------- Appendix V:0.2
The Army Corps of Engineers is responsible for the overall project
management, investigation, design, and construction activities during
phase II of Operation Safe Removal. Its mission is to investigate
and verify that no additional World War I-era munitions remain in the
Spring Valley area and, if necessary, to excavate, remove, and
destroy any munitions discovered.
SITE INVESTIGATION
----------------------------------------------------- Appendix V:0.2.1
The decision to continue the investigation of the Spring Valley site
was based on research of archival data, topographic maps, aerial
photographs, and anecdotal information, which indicated that more
areas of interest existed. The Army also conducted geophysical
investigations, including ground conductivity surveys, magnetometer
sweeps, and soil and water sampling at the Spring Valley site. A
computer system merged these data and maps and allowed the Corps of
Engineers to create visual composite maps that summarized the
investigations. Based on the results of the process, the Corps
located suspected anomalies that required excavation to verify the
presence or absence of munitions.
EXCAVATION
----------------------------------------------------- Appendix V:0.2.2
The excavation process, which was approved in a safety plan, began
with a Corps contractor mechanically digging to within 12 inches of
the suspected anomaly, and then the process was turned over to the
Army Technical Escort Unit for final excavation, exposure,
identification, and removal. The excavation recovered several
munitions and potential chemical warfare materiel. A brief
description of some of the recovered materiel follows:
A corroded piece of pipe, similar to shipping containers for liquid
and gases during World War I, was recovered and moved to Pine Bluff
Arsenal, Arkansas, for storage in June 1993.
A 75-mm projectile, identified as a suspected chemical weapon, was
recovered and flown to Pine Bluff Arsenal, Arkansas, for storage in
October 1993.
Shrapnel from several expended 75-mm projectiles were recovered and
disposed of as scrap.
A Livens smoke projectile was recovered and destroyed by incineration
as waste munition in April 1994.
Three glass vials, containing a clear liquid, were recovered and
moved to Aberdeen Proving Ground, Maryland, for testing in November
1994.
Also, various nonmilitary metallic materiel encompassing ferrous
rocks, a bundle of 14-gauge wire, a 28- by 10-foot steel plate, and
construction debris were recovered and moved to other locations.
INTERIM HOLDING AREA
----------------------------------------------------- Appendix V:0.2.3
As part of the Spring Valley Safety and Work Plans, an interim
holding area and helicopter pad were constructed at a cost of
$284,000. They were designed to provide immediate, although
temporary safe storage, for any recovered munitions prior to being
moved by Army helicopter out of the Spring Valley area. The holding
area and pad contain a fire suppression system, air filtration
system, lightning arrester system, and beacon lights. They are
located on federal property and are government controlled for
security reasons.
The interim holding area contains three storage magazines, one for
high-explosive munitions and two for chemical munitions. The two
chemical magazines are modified to include fire suppression and air
filtration systems. The magazines are enclosed by a timber structure
and earth embankment that provides a minimum of 3 feet of soil
encompassing the magazines. No munition will remain in the interim
holding area for longer than 10 consecutive days. The Corps of
Engineers intends to demolish the holding area and helicopter pad
once excavations at Spring Valley are completed.
TRANSPORTATION
----------------------------------------------------- Appendix V:0.2.4
Recovered chemical weapons were moved by helicopter from the interim
holding area to Andrews Air Force Base, Maryland, and then flown to
Pine Bluff Army Arsenal, Arkansas, for storage and future
destruction. Recovered high-explosive, conventional munitions were
moved by helicopter from the area and transported to Letterkenny Army
Depot, Pennsylvania. No shipment of other hazardous waste will be
moved into or out of the interim holding area.
INVESTIGATION AND CLEANUP COSTS OF
OPERATION SAFE REMOVAL
As of November 29, 1994, the Army Corps of Engineers estimated that
the investigation and cleanup of the Spring Valley site would cost
$20.22 million. (See table V.2.) The estimate includes the costs of
completing phase I operations, researching and investigating the
site, constructing and operating the interim holding area, removing
and sampling the recovered munitions and materiel, fulfilling safety
and environmental requirements, and performing management activities.
Table V.2
The Army Corps of Engineers Costs of
Operation Safe Removal
(Dollars in millions)
1995
1993 1994 Estimate
Cost element Actual Actual d Total
-------------------- -------- -------- -------- ========
Phase I $4.06 $0.20 $4.26
reimbursement
Baltimore District 2.31 1.94 $0.50 4.75
Huntsville Division 5.56 5.15 0.50 11.21
============================================================
Total $11.93 $7.29 $1.00 $20.22
------------------------------------------------------------
The Army Corps of Engineers costs include support costs for the Army
Technical Escort Unit; the Army Chemical and Biological Defense
Agency; Washington, D.C., government; resident office facilities;
community evacuation; and others.
COMMUNITY ISSUES AND CONCERNS
According to the Army Corps of Engineers, the primary issues and
concerns of the residents in Spring Valley are related to
their personal safety,
the effects of the presence of chemical munitions on the value of
their property,
the length of time their lives will be disrupted by the ongoing
investigation and cleanup of the site,
when the Spring Valley site will be certified safe and clear of
dangerous munitions after Operation Safe Removal is completed, and
the question of whether the Army is telling all that is known about
or going on at the site.
To address these issues and concerns, the Corps of Engineers
developed a public involvement and response plan to promote efficient
and effective communication among the Corps; various federal, city,
and local agencies and officials; property owners; the housing
development corporation; general public; and news media. The primary
objectives of the plan are to (1) provide for clear and open exchange
of information regarding current and planned investigation and
cleanup activities, (2) address local community issues and concerns,
(3) provide government agencies and the public the opportunity to
participate in the Corps of Engineers' planning and decision-making
process, and (4) provide government agencies and the public with a
centralized point of contact. According to the Corps of Engineers,
the plan is flexible and can be modified as events, community issues
and concerns, and situations change. We did not evaluate the
effectiveness of the Army's public involvement and response plan.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI
NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C.
David R. Warren, Associate Director
Thomas J. Howard, Assistant Director
Glenn D. Furbish, Senior Evaluator
Mark A. Little, Evaluator-in-Charge
Pauline F. Nowak, Evaluator