oversight

Chemical Weapons: Obstacles to the Army's Plan to Destroy Obsolete U.S. Stockpile

Published by the Government Accountability Office on 1990-05-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                         KLLLN3LU
RESTRICTED --Not       to be released outside the
General Accounting Office unless specifically
approved by the Office of Congressional
  tlations.
National Security and
International Affairs Division

B-238728

May 24,199O

The Honorable John Glenn
Chairman, Committee on Governmental
  Affairs
United States Senate

The Honorable John Conyers, Jr.
Chairman, Legislation and National
  Security Subcommittee
Committee on Government Operations
House of Representatives

The Honorable Earl Hutto
Chairman, Subcommittee on Readiness
Committee on Armed Services
House of Representatives

This report responds to your requests that we review the Department of Defense’s Chemical
Stockpile Disposal Program and determine the status of its efforts to destroy obsolete
chemical weapons.

Unless you publicly announce its contents earlier, we plan no further distribution of this
report for 30 days. At that time, we will send copies to the Chairmen of the 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.

This report was prepared under the direction of Richard Davis, Director, Army Issues, who
may be reached on (202) 275-4141 if you or your staff have any questions. Other major
contributors are listed in appendix I.




Frank C. Conahan
Assistant Comptroller General
Ekeeutive Summary


                   The United States has stockpiled chemical weapons since World War I.
Purpose            In November 1982, after determining that most of the existing stockpile
                   had little or no military value, the Department of Defense began seeking
                   congressional approval for a chemical weapons modernization program.
                   In conjunction with its authorization to develop modernized weapons,
                   the Congress, in November 1985, directed the Department of Defense to
                   destroy the existing stockpile.

                   The Chairmen of the Subcommittee on Readiness, House Committee on
                   Armed Services; Legislation and National Security Subcommittee, House
                   Committee on Government Operations; and the Senate Committee on
                   Governmental Affairs asked GAO to determine the status of the Army’s
                   chemical stockpile disposal program.


                   The chemical weapons to be destroyed contain agents that can blister
Background         the skin or disturb the nervous system. In fiscal year 1988, the Army, as
                   the Defense Department’s lead service in chemical matters, constructed
                   a high-temperature incineration facility to destroy chemical weapons on
                   Johnston Atoll in the Pacific Ocean. Also in 1988, the Army announced
                   that it planned to build similar disposal facilities at each of the eight
                   chemical munitions storage sites in the continental United States-
                   Tooele, Utah; Anniston, Alabama; Pine Bluff, Arkansas; Umatilla,
                   Oregon; Pueblo, Colorado; Newport, Indiana; Lexington-Blue Grass,
                   Kentucky; and Aberdeen, Maryland. The Army began to construct the
                   Tooele plant in late fiscal year 1989 and plans to start construction of
                   the Anniston plant in fiscal year 1991.

                   The disposal program, by law, is to be completed by April 30, 1997. The
                   program must conform to the Environmental Protection Agency’s stan-
                   dards for hazardous waste disposal. Prior to constructing its disposal
                   facilities, the Army must obtain various environmental permits. The
                   Environmental Protection Agency has delegated the permit-approval
                   function to the individual states.


                   The Army’s cost estimates to complete the on-site disposal program
Results in Brief   have doubled since 1985-from $1.7 billion to over $3.4 billion-and
                   will likely continue to escalate.

                   The Army probably will not complete its destruction of the stockpile by
                   the congressionally mandated date of April 30, 1997. The Army believes
                   that meeting the 1997 date is in jeopardy because of (1) more stringent


                   Page 2                        GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                            Executive Summary




                            than anticipated environmental requirements to operate its first conti-
                            nental U.S. incineration plant, (2) program budget cuts, and (3) opera-
                            tional delays at its initial disposal plant on Johnston Atoll. GAO believes
                            that the Army’s disposal of weapons by the 1997 date is further jeop-
                            ardized by strong citizen opposition to these plants in some states and
                            the Army’s failure to allow sufficient time to obtain environmental per-
                            mits. Moreover, because of the probable delay in obtaining the required
                            environmental permit for the Anniston facility, GAO believes that most
                            of the $123 million requested by the Army for use in fiscal year 1991
                            may not be needed until fiscal year 1992.



Principal Findings

Cost Estimates Are Likely   In October 1985, the Army’s life-cycle cost estimate to destroy its chemi-
                            cal weapons st,ockpile at the eight storage sites and at the Johnston Atoll
to Increase                 plant was $1.7 billion. In March 1988, information available to the Army
                            showed a total program cost of $3.4 billion. Although the Army is not
                            expected to release a revised program cost estimate until the later half
                            of fiscal year 1990, the total cost is likely to increase further because
                            current construction, equipment, and personnel requirements are at
                            least $300 million greater than estimated in March 1988.


Army Not Likely to Meet     The Army believes that it probably will not complete the stockpile dis-
Disposal Completion Date    posal by April 30, 1997. The Utah environmental permit requires the
                            Army to periodically operate the disposal plant at 50 percent capacity
                            while environmental test data is analyzed. The Army did not expect this
                            restriction. Second, a $37 million shortfall in fiscal year 1990 funding
                            delayed the acquisition of equipment for the Utah plant. In addition,
                            operational delays at the initial plant on Johnston Atoll have adversely
                            affected the Army’s ability to incorporate lessons learned at this plant
                            into the design and construction plans for the continental U.S. disposal
                            facilities.

                            The Army will also likely encounter obstacles in obtaining environmen-
                            tal permits and dealing with opposition in some states where disposal
                            facilities are planned. The Army’s construction schedule, which must be
                            followed to achieve the 1997 completion date, does not allow state agen-
                            cies sufficient time to review applications and issue the required envi-
                            ronmental permits. In addition, citizen opposition in Indiana, Kentucky,


                            Page 3                         GAO/NSL4D-90-155 Army’s Chemical Weapons Disposal
                             Executive Summary




                             and Maryland to the disposal facilities makes it increasingly unlikely
                             that the Army will complete disposal operations as scheduled.


Funds Requested for Fiscal   Because of a probable delay in obtaining required environmental per-
Year 1991 May Not Be         mits for the Anniston facility, most of the $123 million requested by the
                             Army for use in fiscal year 1991 may not be needed until fiscal year
Needed Until Fiscal Year     1992.
1992
                             The Army’s current expectations include plans for soliciting bids in
                             March 1991 and awarding a construction contract for the Anniston facil-
                             ity in September 1991. This plan is based on the assumption that the
                             state will issue a required environmental permit 15 months after the
                             application is resubmitted to the state. On the basis of comments pro-
                             vided by state officials concerning the time needed to process permit
                             applications, the Army will not be allowed to begin construction until
                             late fiscal year 1992. Accordingly, the $64.5 million requested for con-
                             struction and some of the $58.4 million requested for procurement of
                             equipment probably will not be needed until fiscal year 1992.

                             Unless the Army establishes realistic target dates for issuance of
                             required environmental permits, bids for construction contracts could be
                             prematurely solicited and equipment could be obtained before it is
                             needed.


                             GAO  recommends that the Secretary of the Army direct procurement
Recommendations              officials not to solicit bids for the construction contracts or issue equip-
                             ment purchase orders for any additional facilities until realistic dates
                             can be established for receipt of all required environmental permits.

                             Other recommendations that are designed to improve the management
                             and execution of the program are included in chapters 2,3,4, and 5.


                             As requested, GAO did not obtain official agency comments on this
Agency Comments              report. However, it discussed information obtained during the review
                             with agency officials and included their views where appropriate.




                             Page 4                          GAO/NSIAD-90-166 Army’s Chemical Weapons Diiposal
Page 5   GAO/NSIADgO-155 Army’s Chemical Weapons Disposal
Contents


Executive Summary                                                                                    2

Chapter 1                                                                                          ,8
Introduction            Background                                                                   9
                        Management Structure of the Disposal Program                                11
                        Johnston Atoll Disposal Program                                             11
                        Incineration Process                                                        12
                        Objectives, Scope, and Methodology                                          13

Chapter 2                                                                                          15
Projected Program       Reasons for Cost Increases                                                 15
                        Costs Are Expected to Increase Further                                     16
Costs Have Increased    conclusions                                                                19
and Are Likely to       Recommendation                                                             19
Continue to Grow
Chapter 3                                                                                          20
The Army’s Chemical     Events Influencing the Army’s Belief That the Completion                   20
                            Date Will Not Be Met
Stockpile Disposal      Environmental Requirements Must Be Met Before                              21
Operations May Not          Construction Can Begin
                        Army’s Schedule for Obtaining Environmental Permits Is                     23
Be Completed on Time        Unrealistic
                        Community Opposition and Environmental Requirements                        25
                            Could Delay the Construction of Additional Sites
                        Funds Requested for Fiscal Year 1991 May Not Be                            26
                            Needed Until Fiscal Year 1992
                        Conclusions                                                                27
                        Recommendations                                                            27

Chapter 4                                                                                          29
The Army’s Plans to     Origins of the Emergency Preparedness Program                              29
                        Previous Delays in Program Execution                                       30
Upgrade Emergency       Conclusions                                                                31
Preparedness Before     Recommendations                                                            32
the Start of Disposal
Operations


                        Page 6                       GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                      Contents




Chapter 5                                                                                        33
Chemical Stockpile    Legislation Prohibits the Use of CSDP Facilities for Other                 33
                          Purposes
Disposal Program      Congressionally Directed Study of Other Possible Uses                      33
Facilities Could Be   Disposal Facilities Could Be Used for Other Purposes                       34
                      Conclusions                                                                35
Used for Other        Recommendations                                                            35
Purposes
Appendix              Appendix I: Major Contributors to This Report                              36

Tables                Table 1.1: Construction and Operation Schedules                            11
                      Table 2.1: Change in Total Estimated Program Cost                          16
                      Table 2.2: Increased Equipment Cost Estimates                              18

Figures               Figure 1 .l: Storage Locations in the Continental United
                          States
                      Figure 1.2: Incineration Process for Chemical Munitions                    12




                      Abbreviations

                      CSDP       Chemical Stockpile Disposal Program
                      DOD        Department of Defense
                      EPA        Environmental Protection Agency
                      GAO        General Accounting Office
                      RCRA       Resource Conservation Recovery Act


                      Page 7                         GAO/NSm%156    Army’s Chemical Weapons Disposal
                                                                                                           ,


Chapter 1

Introduction


               In November 1985, the Congress directed the Department of Defense
               (DOD) to destroy the U.S. stockpile of obsolete chemical munitions and
               agents. The Congress required DOD to establish a management organiza-
               tion within the Department of the Army to carry out the Chemical
               Stockpile Disposal Program (CSDP). The chemical munitions to be
               destroyed contain three types of lethal agents: GB, VX, and H. The
               “nonpersistent” nerve agent GB and the “persistent” nerve agent VX
               disrupt the nervous system and lead to the loss of muscular control and
               usually death.’ Mustard agents (the H series) blister the skin and can be
               lethal in large amounts.

               These three types of chemical agents are contained in various munitions.
               M55 rockets contain GB or VX; M23 mines and spray tanks contain VX;
               bombs contain GB; and 105mm, 155-mm, 4.2-inch, and 8-inch projectiles
               contain GB, VX, or HD. All three agents are stored in l-ton containers
               for possible future transfer to chemical munitions. None of these agents
               or munitions have been manufactured since 1968. All are at least 21
               years old, and some are more than 45 years old.

               Most of the chemical agent and munitions stockpile is stored at eight
               Army depots in the continental United States: at Anniston, Alabama;
               Pine Bluff, Arkansas; Pueblo, Colorado; Newport, Indiana; Lexington,
               Kentucky; Aberdeen, Maryland; Umatilla, Oregon; and Tooele, Utah. A
               portion of the stockpile is stored at two overseas locations. Figure 1.1
               shows the storage locations in the continental United States.




               ‘“Nonpersistent” agents vaporize and dissipate readily, while “persistent” agents remain in liquid
               form for several days.



               Page 8                                    GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                                                Chapter 1
                                                Introduction




Figure 1.1: Storage Locations   in the Continental   United States

                    T   Umatilla, Oregon,
          *iviti

                                                                                   r   Newport, Indiana,
                                                                                       Army Ammunition Plant




                                                                                                               -    Aberdeen, Maryland,
                                                                                                                    Proving Ground




                                                                                                           L       Lexington-Blue
                                                                                                                   Grass, Kentucky,
                                                                                                                   Armv Deoot


                                                                                                    L     Anniston, Alabama,
       Army uepor                                                                                                lepot



                                                                     L   L3l;ff.       Arkansas,)




                                                Before 1969, the Army, as DOD’S lead service in chemical matters, dis-
Background                                      posed of obsolete lethal chemical munitions by various means, including
                                                deep ocean dumping and open-pit burning. However, in a 1969 report,
                                                the National Academy of Sciencesconcluded that ocean dumping should
                                                be avoided and alternative disposal methods should be studied. In 1972,
                                                the Congress passed the Marine Protection, Research and Sanctuaries
                                                Act (Public Law 92-532), which prohibited any further ocean disposal of
                                                chemical agents.

                                                After the enactment of Public Law 92-532, the Army began researching
                                                two disposal technologies: one involving chemical neutralization and the
                                                other involving high-temperature incineration. In 1984, the National



                                                Page 9                             GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
Chapter 1
Introduction




Academy of Sciences concluded that of the two disposal processes being
considered, high-temperature incineration was the more desirable
approach. The Academy based its conclusion on tests that had shown
that the neutralization process was more costly and produced larger
quantities of waste than previously anticipated.

Public Law 99-146, which directed DOD to destroy the existing stockpile
by September 30, 1994, also specified that the disposal program should
provide for the maximum protection of the environment, the general
public, and personnel involved with the actual destruction of chemical
munitions. The law also stipulated that (1) disposal plants should be
designed solely for the destruction of chemical munitions, (2) the facili-
ties could not be used for any other purpose, and (3) when the stockpile
was destroyed, the facilities would be cleaned, dismantled, and disposed
of in accordance with applicable laws and regulations. Further, the law
required that DOD develop a comprehensive disposal plan, including
milestone dates and a description of the disposal method(s) to be used.

In March 1986, the Army submitted to the Congress a disposal plan,
which considered the costs and problems associated with three disposal
alternatives: (1) transferring and disposing of the U.S. chemical stock-
pile at one national disposal site, (2) transferring and disposing of the
stockpile at two regional sites, or (3) simultaneously building and oper-
ating separate disposal plants at the eight storage locations.

In February 1988, the Army formally announced that on-site incinera-
tion at the eight locations was the preferred alternative. The Army also
said that the on-site destruction process would be accomplished by dis-
assembling and incinerating the munitions.

In March 1988, the Army published its plan and schedule for construct-
ing and operating disposal plants at the eight storage sites. The 1988
plan, unlike the 1986 plan, included a staggered construction schedule,
providing for construction to begin on one plant in fiscal year 1989, on
three plants in fiscal year 1991, and on four plants in fiscal year 1992.
On the basis of this schedule, the Army notified the Congress that the
completion of the disposal program would be extended from
September 30, 1994, to April 30, 1997. In September 1988, the Congress
passed Public Law 100-456, which authorized the April 30, 1997, com-
pletion date.

Table 1.1 summarizes the Army’s schedule, as of August 1989, for con-
struction, preoperational testing, and disposal operations.


Page 10                       GAO/NSLAD90-155 Army’s Chemical Weapons Disposal
                                        Chapter 1
                                        Introduction




Table 1.1: Construction and Operation
Schedules (as of August 1989)                                                              Preoperational    Disposal
                                        Storage site                     Construction      testing           opdrations
                                        Tooele, Utah                     08189 to 01192    02192 to 01193    02193 to 04197
                                        Pane Bluff, Arkansas             09/91 to 02194    03194 to 0219.5   03195 to 12196
                                        Umatllla. Oreoon                 09/91 to 02194    03194 to 02195    0319.5 to 1 l/96
                                        Anniston, Alabama                09/91 to 02;94    03;94 to 02;95    03195 to 04197
                                        Pueblo, Colorado                 05192 to 10194    1 I/94 to 10195   1 l/95 to 02197
                                        Newoort. Indiana
                                             I
                                                                         05192 to 03194    04194 to 03/95    04195 to 07196
                                        Aberdeen, Varyland               05192 to 03194    04;94 to 03;95    04;95 to 07;96
                                        Lexington-Blue Grass, Kentucky   09192 to 02/95    03195 to 02196    03196 to 02197




                                        Public Law 99-145 directed the Secretary of Defense to establish a man-
Management Structure                    agement organization within the Department of the Army to be respon-
of the Disposal                         sible for the CSDPand to designate a general officer to direct the
Program                                 program. The law requires the Secretary of Defense to provide a report
                                        to the Congress each year by December 15 regarding the CSDPactivities
                                        for the preceding fiscal year ending on September 30. The Army has
                                        complied with this annual reporting requirement.

                                        The Army’s management organization is headed by the Program
                                        Manager for Chemical Demilitarization, who is located in the Edgewood
                                        area of Aberdeen Proving Ground, Maryland, and reports to the Office
                                        of the Assistant Secretary of the Army for Installations, Logistics, and
                                        the Environment. The Program Manager is responsible for providing
                                        technical, engineering, and direct management control. The Deputy for
                                        Chemical Demilitarization, located in the same office, is responsible for
                                        providing program policy and oversight.


                                        The Army, in fiscal year 1988, completed construction of a prototype
Johnston Atoll                          disposal facility for the on-site incineration of chemical munitions and
Disposal Program                        agents currently stored on Johnston Atoll in the Pacific Ocean. The
                                        Army’s March 1988 implementation plan stated that a 16-month opera-
                                        tional verification test program would be conducted at the Johnston
                                        Atoll plant starting in August 1989. Further, the plan stated that the
                                        Army would delay the completion of most continental US. plant designs
                                        and the acquisition of most equipment until the Johnston Atoll opera-
                                        tional verification tests were completed. Public Law 100-456, enacted in
                                        September 1988, specifies that equipment prove-out and system testing
                                        at stateside disposal sites cannot start until operational data from the
                                        Johnston Atoll facility has been fully analyzed. The start of operational


                                        Page 11                             GAO/NSLAD-90-155 Army’s Chemical Weapons Disposal
                                                    Chapter 1
                                                    Introduction




                                                    verification testing on Johnston Atoll has been delayed for 9 months-
                                                    until May 1990.


                                                   The high-temperature incineration process involves a disassembly pro-
Incineration Process                               cedure, which breaks down munitions into their component parts. Muni-
                                                   tions will be disassembled automatically by specialized equipment. Once
                                                   disassembled, the agent and the chemical munition components are
                                                   burned separately in four specially designed furnaces. The liquid fur-
                                                   nace destroys the lethal agent. The deactivation furnace burns explosive
                                                    and propellent materials. The metal parts furnace decontaminates pro-
                                                   jectile and bulk munition bodies by evaporating and burning the residual
                                                    agent. The trash and dunnage created by the operations are destroyed in
                                                   the dunnage incinerator. Figure 1.2 illustrates the process.

Figure 1.2: Incineration   Process for Chemical        Munitions




                                                                                          i   Pollution
                                                                                              Abatement




    I                                                                                     I
                                                                                          I
                                                                                              Pollution
                                                                                              Abatement



                                                                                          /

                                       I
                                                                                          i   Pollution
                                                                                          I   Abatement
                                                                                                            )     Brine/Salts
                                                                                          I
                                       I

                                       IL---------------------                            I




                                                    Page 12                       GAO/NSLAD-90-155 Army’s Chemical Weapons Disposal
                         Chapter 1
                         introduction




                         Each of the four furnaces has its own pollution abatement system,
                         which cools and scrubs the exhaust gases and removes particles so that
                         the gases can be safely released into the atmosphere. Concentrated brine
                         from the scrubber towers is placed in rotary double-drum dryers to
                         evaporate the water. The remaining dried salts are classified as hazard-
                         ous waste because they contain traces of heavy metals. They are placed
                         in containers and disposed of in approved landfills.

                         The high-temperature disassembly technology is based on the chemical
                         agent and munition incineration experience that the Army gained from
                         its operations at the Rocky Mountain Arsenal from 1972 to 1976 and at
                         the Chemical Agents Munitions Disposal System pilot-scale plant at the
                         Tooele Army Depot from 1979 to 1989. The Army has also benefited
                         from DOD'S experience in the incineration of conventional ammunition
                         and from the private sector’s experience with the incineration of haz-
                         ardous materials.


                         The Chairmen of the Subcommittee on Readiness, House Committee on
Objectives, Scope, and   Armed Services; Legislation and National Security Subcommittee, House
Methodology              Committee on Government Operations; and the Senate Committee on
                         Governmental Affairs asked us to determine the status of DOD'S program
                         to destroy the stockpile of obsolete chemical munitions and agents
                         stored within the continental United States and on Johnston Atoll in the
                         Pacific Ocean. The Committees also requested that we identify problems
                         that could impede the orderly and timely completion of the program.
                         This report discusses overall program cost estimates and problems con-
                         cerning the planned construction of disposal sites within the continental
                         United States. The Johnston Atoll disposal program will be discussed in
                         a separate report.

                         Officials at Headquarters, Department of the Army, and the Deputy for
                         Chemical Demilitarization and his staff in the Office of the Assistant
                         Secretary of the Army for Installations, Logistics, and the Environment
                         provided us information on program policy and oversight.

                         At the Office of the Program Manager for Chemical Demilitarization in
                         the Edgewood area of Aberdeen Proving Ground, Maryland, we obtained
                         and analyzed detailed program documentation from officials responsible
                         for providing technical and day-to-day management for the chemical
                         demilitarization program.




                         Page 13                       GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
Chapter 1
Introduction




In visits to four of the planned eight continental US. construction sites
for future chemical disposal facilities-Pine Bluff Arsenal, Arkansas;
Anniston Army Depot, Alabama; Lexington-Blue Grass Army Depot,
Kentucky; and Aberdeen, Maryland-we obtained documentation and a
general overview of specific problems or concerns that may affect the
future disposal operations and the status of installation planning needed
to support disposal operations at these sites.

Our review included visits to the four sites because (1) the Army
planned to request construction funding in fiscal year 1991 for two of
the sites (Pine Bluff and Anniston) and (2) the communities have
opposed the Army’s decision to locate disposal facilities at two of the
sjtes (Aberdeen and Lexington-Blue Grass).

In addition, interviews were conducted and documentation was obtained
from responsible officials representing the Environmental Protection
Agency (EPA) and the Federal Emergency Management Agency regional
offices located in Philadelphia, Pennsylvania, and Atlanta, Georgia.
These regions are responsible for providing environmental and
preparedness oversight in Maryland, Alabama, and Kentucky. EPA pro-
vides management oversight of state regulatory agencies, and the Fed-
eral Emergency Management Agency serves as a conduit for Army
funds provided to state and local governments for emergency prepared-
ness programs.

Finally, we interviewed officials and obtained pertinent documentation
from state and local agencies responsible for environmental regulations
and emergency preparedness at the four future disposal sites because
state agencies review and approve environmental permit applications
and county organizations develop and manage emergency preparedness
programs.

Our review was conducted from April to December 1989 in accordance
with generally accepted government auditing standards. We did not
obtain written agency comments but did discuss our findings with Army
and DOD officials. Their views are included in the report where
appropriate.




Page 14                       GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
Chapter 2

ProjectedProgramCostsHave Inereasedand
Are Likely to Continueto Grow

                   Total program cost estimates to destroy the Army’s stockpile of chemi-
                   cal munitions and agents have doubled since 1985. During our prior
                   examination of the Chemical Stockpile Disposal Program, Army officials
                   told us that the estimated cost, as of October 1985, for on-site destruc-
                   tion of the chemical munitions stockpile at the eight sites in the conti-
                   nental United States and a facility at Johnston Atoll in the Pacific Ocean
                   was about $1.7 billion.’ In March 1988, the Army reported to the
                   Congress that an additional $3.1 billion would be required to complete
                   the disposal program, exclusive of funds already appropriated.2
                   Although revised estimates will not be available until the later half of
                   fiscal year 1990, information already available from the Army shows
                   that total program costs will continue to grow because the current con-
                   struction, equipment, and support personnel costs are at least $300 mil-
                   lion greater than costs the Army used to develop the March 1988
                   estimate.


Reasons for Cost   revised upward to almost $2.0 billion in March 1986. The Army attrib-
Increases          uted most of this increase to the addition of program support costs,
                   which were not included in the October 1985 estimate. These program
                   support costs include administrative expenses for program management,
                   medical support, engineering support, and technology development.

                   In March 1988, information available to the Army indicated that over
                   $3.4 billion would be required to carry out the disposal program. Army
                   officials told us that about $544 million of the additional cost could be
                   attributed to the expected impact of inflation on future requirements.3
                   Other projected increases totaling about $345 million are the result of
                   adding cost elements not included in the earlier estimates. The remain-
                   ing amount ($546 million) results from prior year expenditures and
                   increased cost estimates for facility construction and acquisition, instal-
                   lation, and testing of plant equipment. The estimated cost growth for
                   construction and equipment resulted from consideration of later designs
                   and actual costs incurred for the Johnston Atoll project. (See table 2.1.)

                   ‘Chemical Munitions: Cost Estimates for Demilitarization and Production (GAO/NSIAD-86-E%,
                   Oct. 31, 1985). This estimate was in fiscal year 1985 constant dollars.

                   2The Army’s March 1988 estimate to complete the disposal program of $3.136 billion did not include
                   $271 million appropriated in fiscal years 1986 and 1987 for construction and equipment. Inclusion of
                   these funds increases the projection of total program cost as of March 1988 to over $3.4 billion.

                   3The October 1985 and March 1986 estimates were based on fiscal year 1985 and 1986 constant
                   dollar requirements and did not include allowances for inflation.



                   Page 15                                  GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                                       Chapter 2
                                       Projected Program Costs Have Increased and
                                       Are Likely to Continue to Grow




Table 2.1: Change in Total Estimated
Program Cost                           Dollars in mllllons
                                       Cost element                                                                               Amount
                                       Program cost projection as of October 1985                                                 $1,700.0
                                       Program support cost                                                                          272.0
                                       Impact of lnflatlon                                                                           544.0
                                       Added cost elements
                                         On-site transportation                                                                       119.0
                                          Emergency preparedness                                                                      114.0
                                         Alternative technology development                                                            80.0
                                         European stockpile movement                                                                   320
                                       Prior year expenditures and other cost increases                                               546 0
                                       Total disposal program cost as of March 1988                                               $3,407.0


                                       The majority of the added cost elements resulted from program
                                       enhancements that were designed, in part, to respond to concerns for the
                                       maximized safety of the public and of personnel involved in the stock-
                                       pile destruction. For example, the revised estimates reflect the added
                                       cost to design and acquire special munitions transport containers to min-
                                       imize the risk of munition damage and the accidental release of agents
                                       into the atmosphere. Also, the revised estimates provided funding for a
                                       new program requirement to upgrade emergency response capabilities in
                                       communities surrounding the disposal sites. This emergency response
                                       upgrade program is discussed in more detail in chapter 4. In addition,
                                       the Army’s March 1988 estimate includes the cost of developing an
                                       alternative disposal technology, which features munitions freezing,
                                       crushing, and high-temperature incineration.* The revised estimates also
                                       provided for the shipment and disposal of chemical stockpile items cur-
                                       rently stored in Europe.


                                       Army officials believe that the costs of constructing and operating eight
Costs Are Expected to                  continental U.S. disposal facilities will continue to increase because they
Increase Further                       expect construction, equipment, and personnel costs to be higher than
                                       estimated in March 1988.




                                       4This technique, which is commonly referred to as “cryofracture,” was intended to provide a backup
                                       to the munitions disassembly and high-temperature incineration process that the Army selected as its
                                       primary method of disposal.



                                       Page 16                                  GAO/NSlAD-90-155 Army’s Chemical Weapons Disposal
                     Chapter 2
                     Projected Program Costs Have Increased and
                     Are Likely to Continue to Grow




                     To provide a basis for its budget requests for fiscal years 1992 to 1997,
                     the Army, in December 1989, established a task force to update and doc-
                     ument program cost estimates. The Army expects to publish a revised
                     program estimate during the later part of fiscal year 1990.

                     Army officials told us that if funds are available, an attempt may be
                     made to develop a computerized system for tracking future changes in
                     program costs. Such a system could enable the Army to track its pro-
                     gram expenditures and analyze the causes of cost growth.


Construction Costs   The Army Corps of Engineers recently developed construction cost esti-
                     mates for each site. As of September 1989, construction cost estimates
                     totaled $351 million for the eight U.S. sites, an increase of about
                     $66 million over the March 1988 estimate.

                     Army program management officials told us that the increased con-
                     struction costs could be partly attributed to newly identified require-
                     ments for the construction of a container-handling building to off-load
                     and store on-site transport containers in an environmentally sealed
                     building. Also, the revised estimates are based on the cost of the com-
                     pleted facility design for the lead continental U.S. site (Tooele, Utah)
                     rather than the partial design that was available when the March 1988
                     estimate was prepared. Lastly, the updated construction estimates were
                     based on labor costs for the specific geographic locations.


Equipment Costs      Although final equipment cost estimates have not yet been developed
                     because site-specific designs are not complete, the Army has developed
                     revised estimates that indicate that the total equipment acquisition and
                     installation costs could increase by more than $197 million over the pub-
                     lished March 1988 program cost estimate. Table 2.2 compares equip-
                     ment cost estimates for each site.




                     Page 17                             GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                                          Chapter 2
                                          Projected Program Costs Have Increased and
                                          Are Likely to Continue to Grow




Table 2.2: Increased   Equipment   Cost
Estimates                                 Dollars In mhons
                                                                                                 Estimated   cost
                                                                                                              September
                                          Site                                                  M~~~~               1989    Increase
                                          Tralnlng facilitya                                     $23.5              $28.8         $5.3
                                          Tooele                                                  105.5             155.5         50.0
                                          Annlston                                                 95.0             122.9         27.9
                                          Umatilla                                                1093              133.7        24.4
                                          Pine Bluff                                               65.1              84.0         18.9
                                          Pueblo                                                   94 8             120.8         26.0
                                          Newport                                                  61 0              67.2          6.2
                                          Aberdeen                                                 56.0              69.1         13.1
                                          Lexington                                                92.4             118.1         25.7
                                          Total                                                 $702.6            $900.1       $197.5
                                          aTralnlngfacihty IS located at Aberdeen, Maryland



Personnel Costs                           The Army requested that its depots determine how many supplemental
                                          personnel will be needed to support disposal planning and operations.
                                          The depots are determining how many more support personnel will be
                                          needed than originally estimated. For example, the March 1988 esti-
                                          mates assumed that the Anniston depot would need to hire about
                                          68 support personnel. However, Anniston depot representatives pro-
                                          vided us with documentation that indicates they will need to employ, on
                                          average, 99 support employees starting in fiscal year 1992 through
                                          scheduled program completion in fiscal year 1997.

                                          At an average cost of $35,000 per staff-year, employing the additional
                                          31 people for 6 years could escalate costs by about $6.5 million for this
                                          site alone. These employees will be needed to transport munitions and
                                          chemical agents from the storage sites to the disposal plant, act as a
                                          supplement to the existing security forces, and perform laundry ser-
                                          vices. The Army understated its initial personnel support estimates
                                          because it did not accurately estimate the numbers of transport workers
                                          needed for transporting munitions in the on-site containers, which are
                                          designed to enhance the accident-free movement of munitions.

                                          Army officials told us that the number of contractor-employed person-
                                          nel needed to operate the disposal plant will also increase in comparison
                                          to the original plan. For example, the experience gained from the
                                          Johnston Atoll facility has shown that greater-than-expected numbers



                                          Page 18                                   GAO/NSLAD-90-155 Army’s Chemical Weapons Disposal
                 Chapter 2
                 Projected Program Costs Have Increased and
                 Are Likely to Continue to Grow




                 of employees will be needed during the equipment installation and test-
                 ing phase. The program management office also plans to hire a program
                 integration contractor to monitor the progress of the operating contrac-
                 tor and to provide support to Army staff. Since the Army only recently
                 developed this concept, costs for the program integration contractor
                 were not included in the March 1988 estimates.


                 Cost estimates for completing the Army’s CSDP have doubled since 1985
Conclusions      and are likely to continue to grow. The preliminary estimate of $1.7 bil-
                 lion grew to more than $3.4 billion by 1988. Some of the cost growth to
                 date can be attributed to (1) the addition of program enhancements
                 designed, in part, to address concerns for maximized safety and (2) the
                 fact that early estimates were based on incomplete information (the
                 Army lacked completed designs and actual cost information from a com-
                 parable operating facility). Since current construction, equipment, and
                 personnel requirements have continued to rise, total program costs will
                 increase even more.

                 The Army plans to use contractors to construct and operate eight dispo-
                 sal facilities in the continental United States over a g-year period. Using
                 contractors will increase the importance of the Army’s timely cost anal-
                 ysis and control. Close management attention over the cost estimating
                 process will be needed to maintain effective control over future multibil-
                 lion dollar expenditures for this program.


                 We recommend that the Secretary of the Army ensure that accurate and
Recommendation   complete cost information is developed to effectively control future pro-
                 gram expenditures.




                 Page 19                             GAO/NSIAD-99-155 Army’s Chemical Weapons Disposal
Chapter 3

The Army’s ChemicalStockpileDisposal
OperationsMay Not Be Completedon Time

                           The Army’s chemical stockpile disposal program has encountered sev-
                           eral setbacks, which may prevent the successful completion of the dis-
                           posal operations by April 1997. The Army believes that the
                           congressionally mandated 1997 completion date is in jeopardy for the
                           following reasons: (1) its fiscal year 1990 procurement request was not
                           fully funded; (2) an environmental permit obtained from the state of
                           Utah requires that the disposal facility in that state periodically operate
                           at less than full capacity; and (3) the schedule was delayed to permit
                           incorporating the lessons learned from the Johnston Atoll disposal plant
                           into the design and construction of the continental U.S. disposal
                           facilities.

                           In addition to these setbacks, the Army will likely encounter additional
                           obstacles in obtaining environmental permits and dealing with opposi-
                           tion in some states where future disposal facilities are planned. The
                           Army’s disposal plant construction schedule, which must be followed to
                           achieve the 1997 completion date, does not allow state agencies suffi-
                           cient time to review applications and issue the required environmental
                           permits. In particular, it appears unlikely that the necessary permits can
                           be obtained in time to start construction of the Anniston, Alabama, facil-
                           ity in September 1991. Consequently, the Army could delay the award
                           of the construction contract and the issuance of some equipment
                           purchase orders until fiscal year 1992.

                           Moreover, potential problems may delay the start of construction at
                           three of the four sites the Army planned to begin in fiscal year 1992.
                           These potential problems include opposition from local citizen groups
                           and stringent regulations and requirements imposed by two of the states
                           for acquiring the necessary environmental permits.


                           The Army believes that several factors have adversely affected its abil-
Events Influencing the     ity to meet the mandated April 30, 1997, disposal completion date:
AITIIY’S Belief That the   (1) its fiscal year 1990 procurement funding request was cut by $37 mil-
Completion Date Will       lion, adversely affecting equipment acquisition and installation for the
                           Tooele, Utah, site and design efforts for some follow-on sites; (2) Utah’s
Not Be Met                 environmental permit will require the Army to periodically operate the
                           facility at 50 percent of capacity; and (3) a g-month delay in the start of
                           congressionally mandated operational verification testing for the
                           Johnston Atoll facility will extend the schedule for incorporating lessons
                           learned into the design of continental U.S. facilities.




                           Page 20                        GAO/NSLAD-90-155 Army’s Chemical Weapons Disposal
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                                Chapter 3
                                The Army’s Chemical Stockpile Disposal
                                Operations May Not Be Completed on Time




                                According to the Army, the $37 million reduction in fiscal year 1990
                                procurement funding will delay the acquisition of some plant equip-
                                ment, which will in turn cause a 12-month delay in completing the con-
                                struction and implementation of disposal operations at Tooele, Utah.
                                Further, the Utah environmental permit contains a provision requiring
                                the Army to conduct up to 12 test burns. While the state analyzes the
                                trial burn data, the facilities can operate at only 50 percent of their
                                capacity. The Army did not anticipate that the permit would contain
                                such a stringent requirement when it made up its completion schedule
                                for Tooele. Since the Tooele facility was already scheduled to operate
                                through April 1997, these additional requirements will likely extend the
                                Tooele operations beyond the congressionally mandated completion
                                date.

                                Public Law 100-180, enacted in December 1987, requires the Army to
                                conduct operational verification testing of the disposal technology. The
                                Army’s March 1988 implementation plan states that, with the exception
                                of the Tooele plant, final facility design and construction of the disposal
                                plants will be scheduled to take advantage of lessons learned from the
                                Johnston Atoll operational testing. Because of a g-month delay in the
                                start of operational verification testing at Johnston Atoll, the Army
                                believes that the overall program has slipped and that therefore the
                                complete disposal of the chemical weapons stockpile by April 1997 is
                                improbable.


Environmental        the following mandatory environmental permits for each of the pro-
Requirements Must Be posed  sites.
Met Before           The Resource Conservation and Recovery Act (RCRA) of 1976 (Public
Construction Can     Law 94-580) establishes the guidelines for the treatment, storage, or dis-
Begin                posal of hazardous wastes. The physical construction of a new hazard-
                                ous waste management facility cannot begin without an RCRA permit.
                                Review and approval authority for RCRA permit applications has been
                                delegated by EPA to applicable state regulatory agencies.

                                Air permits are also required for disposal facilities to certify that they
                                abide by the Clean Air Act Amendments of 1977 (Public Law 95-95),
                                which establish national emissions standards for hazardous air pollu-
                                tants. Each state will issue a separate air permit, except for Maryland,
                                where the air permit requirements will be incorporated into require-
                                ments for the RCRA permit.


                                Page 21                             GAO/NSLAD-SO-155Army’s Chemical Weapons Disposal
               Chapter 3
               The Army’s Chemical Stockpile Disposal
               Operations May Not Be Completed on Time




               The National Environmental Policy Act of 1969 (Public Law 91-190)
               requires the Army to develop an environmental impact statement on the
               environmental effects of destroying the chemical stockpile. Because the
               CSDPcould affect 20 different states, the impact was initially assessedon
               a “programmatic” basis-taking into account the collective impact of all
               disposal sites-starting in January 1986. During the development of the
               programmatic environmental impact statement, the Army considered
               the risk to the public of destroying its stockpile (1) at a national site,
               (2) at two regional sites, and (3) on-site at each storage location. A draft
               of the impact statement was provided to the public, and the Army was
               required to address the public’s comments. In February 1988, the Army
               made public its Record of Decision, selecting on-site destruction as the
               preferred alternative because it posed the least risk to public health and
               the environment. Additionally, the Army believed that on-site disposal
               posed the least risk of sabotage and terrorism and provided the greatest
               benefits for enhanced emergency preparedness.

               Before beginning construction at any site, the Army must collect
               detailed environmental information specific to that site, compare it to
               the data gathered during the programmatic study, and then submit a
               site-specific environmental impact statement for each site. The Army
               also is required to issue another formal Record of Decision prior to the
               start of construction at each of the sites, again selecting the preferred
               method of destruction.


RCRA Process   The RCRA permit is the most difficult of all the environmental permits
               that the Army must obtain. RCRA permit application requirements
               include providing a general facility description, chemical and physical
               analyses of waste to be managed, security procedures, a contingency
               plan listing procedures during emergency operations, and other opera-
               tional support data. Additional information must be provided on how
               waste will be stored, such as a description of containers and procedures
               for managing, inspecting, and tracking each waste container while it is
               in storage. Incineration data, such as data on the demonstration of per-
               formance standards at specific operating conditions, particulate emis-
               sion limits, monitoring procedures, and trial burn schedules, must also
               be included in the application. The Tooele RCRA documentation, for
               example, contained 14 volumes of data.

               The RCRA process begins when an application is submitted to the state.
               The state’s review of the application results in a notice of deficiencies
               usually within 3 months. The applicant must then revise and resubmit


               Page 22                            GAO/NSIAD-SO-155 Army’s Chemical Weapons Disposal
     .



                         Chapter 3
                         The Army’s Chemical Stockpile Disposal
                         Operations May Not Be Completed on Time




                         the application. This process continues until the state accepts the appli-
                         cation. A draft permit is then prepared by the state and is sent to the
                         federal EPA and its regional offices for comments; this exchange can be
                         completed in approximately 3 months. After incorporating EPA’S com-
                         ments, the state finalizes the draft and issues a public notice of intent to
                         issue an RCRA permit; this process takes about 1 month. A public com-
                         ment period is held for 45 days, and a public hearing is held if requested
                         by any concerned citizen. If there is a hearing, an additional public com-
                         ment period of 15 days must be provided. The state then takes about
                         45 days to finalize the permit and issue a notification of intent to issue a
                         permit authorizing the start of construction. The permit is not effective
                         until 30 days after the notification of intent is issued. During this period,
                         the public can appeal the pending issuance of the permit. According to
                         state officials, these time frames apply only if the application is being
                         reviewed full-time and there is no public appeal.


                         In September 1986, the Army submitted individual RCRA permit applica-
Army’s Schedule for      tions for the Pine Bluff, Umatilla, and Anniston facilities. The Army
Obtaining                plans to resubmit final RCRA applications for Anniston in May 1990 and
Environmental            for Pine Bluff and Umatilla in August 1990. According to the Army,
                         these applications cannot be resubmitted sooner because schedules for
Permits Is Unrealistic   Army contractors preparing facility designs and permit applications
                         cannot be further expedited.

                         The Army plans to begin construction of the Anniston facility in
                         September 1991 but will be able to do so only if the state issues a final
                         RCRA permit by August 1991 (15 months after the date of submission).
                         The planned start date of construction for the Pine Bluff and Umatilla
                         sites was deferred from September 1991 to June 1992. The new start
                         date allows the Arkansas and Oregon state agencies 22 months to
                         review, process, and issue RCRA permits.

                         Army officials told us that some state environmental regulatory agen-
                         cies had already informed the Army that the amount of time it had allot-
                         ted for reviewing and processing the RCRA permit applications was not
                         sufficient. They said that, as a result, they planned to meet with the
                         state agencies to determine whether the review and approval process
                         could be expedited. We were told that if the states agree, the Army
                         might consider providing funds for the states to hire consultants or
                         additional employees to work on the RCRA applications.




                         Page 23                             GAO/NSIADSO-155 Army’s Chemical Weapons Disposal
Chapter 3
The Army’s Chemical Stockpile Disposal
Operations May Not Be Completed on Tie




State officials responsible for RCRA programs at four of the eight sites,
including Anniston and Pine Bluff, told us that the Army’s schedule
should allow 24 to 36 months between the time the Army submits its
final RCRA applications and the time of permit issuance. For example,
officials from the Arkansas Department of Pollution Control and
Ecology told us that it would most likely take 2 years to issue an RCRA
permit for the Pine Bluff Arsenal after the application is resubmitted.
Therefore, final RCRA approval will probably not occur until fiscal year
1992. The Army’s recent decision to defer a request for funding for the
construction of its Pine Bluff facilities to fiscal year 1992 appears to
have been a prudent decision, based on the 24-month period needed for
reviewing, processing, and issuing the environmental permits for that
site.

Army officials told us that the Alabama Department of Environmental
Management has informed them that the Army should allow 24 to
30 months for the review and approval of the RCRA application for the
Anniston facility. Therefore, if the Army submits its final RCRA applica-
tion in May 1990-in accordance with its current schedule-the earliest
an RCRA permit would be granted appears to be May 1992. This date
would be a full 9 months after the Army’s target date of August 1991.

State officials informed us that the review of the application for the
Anniston Army Depot will require substantial involvement by approxi-
mately 40 percent of their engineering staff in the Hazardous Waste
Division. The Army already has three RCRA applications pending for
other activities at the depot, and the limited number of state agency
staff cannot be completely devoted to the Army. State officials also told
us that their agency will not allow the Army to provide funds for con-
sultants to facilitate the state’s review of the Army’s RCRA application.
They believe that a consultant’s review of the Army’s application would
not be as independent or critical as the state’s review.

The Kentucky Department for Environmental Protection may ask the
Army to provide voluntary funding to hire someone to help in the
review and processing of the Lexington-Blue Grass Army Depot RCRA
permit application. Army officials told us that other states charge a
processing fee for RCRA permits, but Kentucky state law prohibits it from
charging the federal government a fee.




Page 24                             GAO/NSIAD-SO-155 Army’s Chemical Weapons Disposal
                          Chapter 3
                          The Army’s Chemical Stockpile Disposal
                          Operations May Not Be Completed on Time




                          Construction could be delayed at three sites (Lexington-Blue Grass,
Community                 Aberdeen, and Newport) because of community opposition to the on-site
Opposition and            incineration of lethal chemicals and at two sites because of added
Environmental             restrictions imposed by regulatory agencies.
Requirements Could        Public comments from community representatives at the eight CSDP sites
Delay the                 were published in the January 1988 Final Programmatic Environmental
                          Impact Statement. While a few citizens from Arkansas and Oregon made
Construction of           comments in support of the Army’s on-site incineration plans, numerous
Additional Sites          citizens from Maryland, Kentucky, and Indiana voiced concerns and
                          arguments against these plans.

                          Community opposition in Kentucky is particularly strong and well
                          organized. Opposition groups in Kentucky include key political, aca-
                          demic, and civic leaders who have continued their fight against the
                          Army’s plans to build an incinerator in their state. We were told that
                          these citizens are prepared to do whatever it takes (including taking
                          legal action) to halt on-site incineration plans. They want the Army to
                          transport the stockpile to a less populated area for disposal. The pres-
                          ence of such organized opposition, particularly in Kentucky, could
                          impede the successful completion of the stockpile disposal program by
                          April 1997.


Restrictions Imposed by   In addition to organized citizen opposition, new state legislation in
Regulatory Agencies May   Kentucky and additional requirements in Maryland could prevent the
                          Army from obtaining the needed environmental permits within the 15
Delay
-      the Issuance of    months it has allotted for obtaining them. Such a delay could, in turn,
Permits                   result in postI>ned construction.

                          It appears unlikely that the Army will obtain environmental permits for
                          the disposal facility at the Lexington-Blue Grass Army Depot in time to
                          start construction in June 1992. Kentucky officials told us that the state
                          of Kentucky has passed legislation that adds requirements to the envi-
                          ronmental permit process. First, the Army will be required to demon-
                          strate that incineration has been proven in a comparable facility for a
                          “sufficient period of time” to provide assurance of 99.9999 percent
                          destruction of each agent. Second, the Army must provide data from a
                          similar incineration facility to demonstrate that emissions from the
                          incinerator present no risk to human health or the environment. Accord-
                          ing to the Centers for Disease Control in Atlanta, Georgia, to demon-
                          strate “no effect” (that the emissions do not cause cancer), one must



                          Page 25                            GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                       Chapter 3
                       The Army’s Chemical Stockpile Disposal
                       Operations May Not Be Completed on Time




                       conduct a 30-year epidemiological study of persons living in a commu-
                       nity surrounding an incinerator. Depending on how the language of the
                       legislation is interpreted, the permit process could be delayed
                       indefinitely.

                       An official from the Maryland Department of the Environment told us
                       that two factors could delay the permit review process for the Aberdeen
                       Proving Ground. First, the state of Maryland will require the Army to
                       provide operating data from the Johnston Atoll and Tooele, Utah, facili-
                       ties before the RCRA application will be reviewed. Second, the Army may
                       have to address opposition from citizens in the Aberdeen area who
                       would like chemical agents shipped to and incinerated at another site.


                       The Army has requested almost $123 million in fiscal year 1991 funding
Funds Requested for    for the Anniston disposal facility. This includes $64.5 million for the
Fiscal Year 1991 May   award of a contract to construct the disposal plant and upgrade depot
Not Be Needed Until    facilities and $58.4 million to purchase critical equipment that requires
                       a lengthy production and delivery time. Because of the probable delay in
Fiscal Year 1992       obtaining the required RCRA permit, the Army most likely will not bene-
                       fit from the planned award of this construction contract or the issuance
                       of most of the equipment purchase orders in fiscal year 1991. This same
                       issue could affect the other facilities planned for later fiscal years.

                       The Army’s current expectation of soliciting bids in March 1991 for a
                       construction contract and beginning construction of the Anniston facil-
                       ity in September 1991 is based on the assumption that the State will
                       review and approve an RCRA application in 15 months. Any delay in the
                       approval of the RCXA permits beyond the 15-month allotted time sched-
                       uled by the Army would mean that the construction contract
                       would not have to be awarded until fiscal year 1992. On the basis of the
                       expected application submittal date of May 1990 and comments from
                       state officials concerning the time needed to process the application, we
                       estimate that the Army will not be permitted to begin construction until
                       late fiscal year 1992. Accordingly, the $64.5 million in construction
                       funding will probably not be needed for the award of a contract until
                       fiscal year 1992.

                       Similarly, some of the $58.4 million requested for the fiscal year 1991
                       procurement of equipment may not be needed. For example, based on
                       the Army’s current schedule, the four incineration furnaces would not
                       be needed at the construction site until mid-fiscal year 1993. Based on



                       Page 26                            GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                  Chapter 3
                  The Army’s Chemical Stockpile Disposal
                  Operations May Not Be Completed on Time




                  the established procurement lead times, orders for these furnaces could
                  be deferred from fiscal year 1991 to 1992.

                  The Army recently delayed the expected start of construction for the
                  Pine Bluff and Umatilla facilities from September 1991 to June 1992.
                  While this gives the states several additional months to review the RCRA
                  applications, the total time available is still less than state officials
                  believe will be needed.

                  Unless the Army establishes realistic target dates for the issuance of
                  required environmental permits, bids for construction contracts could be
                  prematurely solicited, and equipment could be obtained before it is
                  needed.


                  The Army probably will not complete its chemical stockpile disposal
Conclusions       operations by April 30, 1997, as mandated by the Congress. The Army
                  cites several reasons that it believes this completion date is now improb-
                  able. In addition to those reasons, we also believe that the Army’s expec-
                  tation of acquiring state-approved environmental permits in an
                  unusually short time is unrealistic. If permits are not obtained as
                  planned, the start of construction and the ultimate completion of the
                  stockpile disposal will be delayed. Unless the Army can arrange for an
                  expedited review and approval of its RCRA applications, it should adjust
                  its schedule for awarding construction contracts and placing orders for
                  plant equipment. To expedite the review process, the Army is consider-
                  ing providing funds to the states, if the states agree, for hiring extra
                  employees or consultants to review the applications. However, questions
                  can be raised about the independence of these individuals, the appear-
                  ance of a conflict of interest, and the extent to which the employment of
                  such individuals will expedite the review and approval process. Citizen
                  opposition in some states may also prevent the Army from completing
                  its disposal program by April 30, 1997.


                  We recommend that the Secretary of the Army direct procurement offi-
Recommendations   cials not to solicit bids for the construction contracts or issue equipment
                  purchase orders for any of the remaining disposal facilities until realis-
                  tic dates can be established for receipt of all required environmental
                  permits.

                  We also recommend that the Secretary of the Army prohibit the use of
                  Army funds for the hiring of consultants or other personnel by state


                  Page 27                            GAO/NSIAD90-155 Army’s Chemical Weapons Disposal
Chapter 3
The Army’s Chemical Stockpile Disposal
Operations May Not Be Completed on Time




regulatory agencies to assist in the review of permit applications unless
it can be determined that (1) such action will sufficiently expedite the
RCRA application process to permit the Army to complete the disposal
program by April 1997 and (2) the use of Army funds for this purpose
will not, or in any way appear to, compromise the independence of the
review process.




Page 28                            GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
     ,


Chapter 4

The Army’s Plansto UpgradeEbmergeney
PreparednessBeforethe Start of
DisposalOperations
                       The Army’s progress toward assisting local communities to prepare for
                       emergencies at the planned disposal sites has been slow. Its goal is to
                       have emergency preparedness plans implemented and equipment
                       installed in the communities surrounding the eight sites before disposal
                       operations begin. The March 1988 implementation plan for the stockpile
                       disposal program, published by the Army, stated that the major portion
                       of its upgrades to local emergency planning and equipment was to be
                       completed by 1991. Army officials recently told us that it is likely that
                       the completion date will be delayed until December 1992.

                       The Army’s March 1988 cost estimates for this program totaled
                       $114 million, about $65.8 million of which Army officials told us has
                       been appropriated.


                       The Emergency Preparedness Program was developed to fulfill two leg-
Origins of the         islative requirements. First, the Army’s decision to upgrade emergency
Emergency              preparedness was made to mitigate the potential environmental impacts
Preparedness Program   of the CSDP pursuant to the National Environmental Policy Act. Second,
                       the Congress directed, in Public Law 99-145, that the disposal program
                       provide maximum protection for the environment, the general public,
                       and the personnel involved in the destruction of the chemical stockpile.

                       The emergency preparedness program was also initiated in response to
                       public opinion. Emergency response and preparedness became high pri-
                       ority concerns for the Army because during the public hearings on its
                       overall programmatic environmental impact statement, these issues
                       were the most frequently mentioned concerns.

                       Community representatives focused on the need for an emergency
                       preparedness program because most of these communities had little or
                       no emergency response capability. For instance, Talladega County,
                       Alabama (near the Anniston Army Depot), has virtually no emergency
                       response equipment.’ According to Talladega County officials, if an acci-
                       dent occurred today, their only recourse would be to send someone out
                       to verbally warn people about the emergency. Similarly, officials in
                       Kentucky stated that in the event of an accident there would be total
                       confusion and panic because residents and medical and emergency
                       response personnel are not prepared or trained to handle a chemical
                       emergency.


                       ‘Emergency responseequipment includes sirens, radios, dedicated telephone lines, and beepers.



                       Page 29                                 GAO/NSIAD-90-155 Army’s Chemical Weapons Disposal
                     Chapter 4
                     The Army’s Plans to Upgrade Emergency
                     Preparedness Before the Start of
                     Disposal Operations




                     After hearing the public’s concerns about emergency preparedness, the
                     Army determined that a program to upgrade emergency response capa-
                     bilities in the areas surrounding the eight sites was essential. After
                     working with the Federal Emergency Management Agency, the EPA, and
                     the Department of Health and Human Services, the Army published an
                     emergency response concept plan in July 1987. This preliminary plan
                     called for the development of site-specific plans for each of the eight
                     locations.

                     In March 1988, the Army estimated that the cost of the emergency
                     upgrade program would be $114 million. The Army will provide funds
                     to the local communities surrounding the eight planned disposal sites.
                     These funds will be administered through the Federal Emergency
                     Management Agency and sent to state emergency management agencies
                     and then to local county emergency management agencies. The money
                     will be used in accordance with guidelines established by the Federal
                     Emergency Management Agency to augment current emergency
                     preparedness capabilities.

                     To facilitate communications at all levels, the Army created national
                     and local Intergovernmental Consultation and Coordination Boards.
                     These boards are intended to facilitate the exchange of information
                     among program participants. The membership list for the national board
                     includes representatives from the Army, EPA, the Federal Emergency
                     Management Agency, the Department of Health and Human Services,
                     and local communities. Local board members include regional represent-
                     atives from these same federal agencies; Army, state, and local officials;
                     and community representatives.


                     Since the Army implemented its program to upgrade emergency
Previous Delays in   preparedness in 1988, it has been behind schedule in meeting its mile-
Program Execution    stones. A program schedule dated March 1989 indicates that the Army
                     anticipated that its management plan would be finalized no later than
                     April 1989. However, it now hopes to have the management plan final-
                     ized by early 1990. The Army also originally expected to have com-
                     pleted guidelines for the development of site-specific emergency
                     preparedness plans and standards and criteria manuals by
                     September 1989. A draft of the planning guidance document was distrib-
                     uted in November 1989; however, the standards and criteria manual has
                     not been developed. The Army anticipates having portions of the stan-
                     dards and criteria manual completed by late spring 1990 and the entire
                     document completed by the end of fiscal year 1990. In March 1989, the


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    t



                           Chapter 4
                           The Army’s Plans to Upgrade Emergency
                           Preparedness Before the Start of
                           Disposal Operations




                           Army also estimated that it would acquire and install emergency
                           response equipment at the eight sites between December 1989 and June
                           1991. Now it estimates that this work will not be completed until Decem-
                           ber 1992.

                           Despite these delays, the Army has attempted to expedite the prepared-
                           ness program. For example, it held a conference in November 1989 at
                           Park City, Utah, at which key offici& from the Army, the Federal
                           Emergency Management Agency, and state and local governments met
                           to discuss various aspects of the program plan. Prior to this meeting,
                           local planners had little or no guidance from the Army on how to pro-
                           ceed with their efforts. Several local planning officials thought that this
                           event marked a turning point for the emergency preparedness upgrade
                           process because it was the first time that the Army had provided local
                           planners with a substantial amount of guidance or assistance.


Status of Local Planning   Local planners have recently started working on local site-specific emer-
Efforts                    gency preparedness plans. We visited four of the eight local communi-
                           ties and found that planners had recently been hired and had devoted
                           time to setting up their offices. In general, local planners could not begin
                           their site-specific work until after the Park City conference when they
                           received some written guidelines and instructions from the Army. Some
                           of the planners reported that since the conference, they have been
                           actively developing site-specific plans. While some planners are assess-
                           ing preliminary equipment and funding needs, others do not plan to
                           make these assessmentsuntil they receive further information from the
                           Army and various technical studies.

                           Many of the technical aspects of the emergency preparedness upgrade
                           program are currently being studied by contractors. Contractors have
                           completed pre-engineering studies on the alert and notification equip-
                           ment needs at each site. However, they have not yet completed final
                           studies on the siting and placement of equipment and computer systems
                           and other issues.


                           The Army expects to have completed all its upgrades of emergency
Conclusions                preparedness by the end of 1992 and prior to the scheduled start of dis-
                           posal operations at each site. Finalizing its emergency preparedness
                           management plan, planning guidelines, and the standards and criteria
                           manual is a critical step in reaching this goal. Establishment and adher-
                           ence to milestones for the completion of site-specific engineering studies,


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                                                                                              ,



                  Chapter 4
                  The Army’s Plans to Upgrade Emergency
                  Preparedness Before the Start of
                  Disposal Operations




                  completion of equipment procurement specifications, and acquisition
                  and installation of that equipment are also needed to prevent further
                  slippage in the emergency preparedness program, which could delay the
                  start of chemical disposal operations at the eight continental U.S. sites.


                  We recommend that the Secretary of the Army require the Deputy for
Recommendations   Chemical Demilitarization to (1) take action to ensure the timely comple-
                  tion of all emergency preparedness plans, guidelines, studies, and manu-
                  als, as well as the acquisition and installation of equipment, and
                  (2) report periodically on the progress being made in achieving key mile-
                  stones at each disposal site.




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       t
   .

Chapter 5

ChemicalStockpileDisposalProgramFacilities
Could Be Used for Other Purposes

                        Public Law 99-145, dated November 1985, specifies that all GSDP build-
                        ings and equipment must be dismantled after the chemical munition and
                        agent stockpile is destroyed. However, a November 1989 report by the
                        House and Senate Appropriations Committee of Conferees directed the
                        Army to study the feasibility and desirability of using CSDP plants for
                        other purposes. The Army plans to have a contractor investigate the
                        technical feasibility and desirability of using the incineration plants for
                        other purposes after the chemical munitions and agents are destroyed.
                        During our visit to selected stockpile storage areas, we identified some
                        potential for the expanded use of these facilities.


                        In its May 1984 report, the National Academy of Sciences stated that
Legislation Prohibits   chemical stockpile destruction costs could be minimized if the Army
the Use of CSDP         explored alternative uses for the incineration plants after completion of
Facilities for Other    their primary mission. According to the Academy, the use of CSDP incin-
                        erators to dispose of other hazardous wastes should be evaluated before
Purposes                final facility designs are completed. The Army did not assessthe
                        Academy’s recommendation because legislation passed by the Congress
                        in November 1985 prohibited the use of the facilities for any purpose
                        other than the destruction of obsolete chemical munitions and agents.

                        The November 1985 legislation specifies that chemical stockpile disposal
                        facilities may not be used for any purpose other than the disposal of
                        lethal chemical munitions and that when the stockpile destruction is
                        complete, the facilities should be cleaned, dismantled, and disposed of in
                        accordance with applicable laws and regulations. The Army has inter-
                        preted this legislation to mean that both buildings and equipment should
                        be destroyed and rendered useless.


                        In November 1989, the House and Senate Appropriations Committee of
Congressionally         Conferees directed the Army to investigate and report on the feasibility
Directed Study of       and desirability of using the disposal facilities for other purposes after
Other Possible Uses     the stockpile is destroyed. The Conferees did not specify a time frame
                        for completing the study and submitting the report to the Committee. In
                        requesting the study, the Conferees recognized that the continued use of
                        the facilities after stockpile destruction could require design changes to
                        the furnaces before they are purchased and installed at the disposal
                        sites.




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                                                                                                           l




                          Chapter 5
                          Chemical Stockpile Disposal Program
                          Facilities Could Be Used for Other Purposes




                          In January 1990, Army officials told us that they planned to have a
                          contractor complete the congressionally directed study. In earlier con-
                          versations, program officials told us that they were reluctant to initiate
                          such a study because the public has been told repeatedly that the CSDP
                          incinerators will not be used for any purposes other than the destruction
                          of obsolete chemical munitions and agents. The contractor’s study is
                          expected to be completed by the end of 1990.


                          During our visit to selected chemical stockpile storage areas, we identi-
Disposal Facilities       fied the following possible uses for the disposal plants after the chemi-
Could Be Used for         cal munitions stockpile is destroyed:
Other Purposes
                      l   The Edgewood area of Aberdeen Proving Ground has accumulated a
                          large number of empty l-ton containers, some of which at one time con-
                          tained lethal chemical agents. Army officials told us that since they no
                          longer contain agents, these containers are not considered part of the
                          chemical munitions stockpile and as such may not be processed through
                          CSDPfacilities. Army officials also told us that the scrap value of the
                          empty containers could exceed several million dollars. However, before
                          they can be sold, they must be thermally treated. The CSDPplants have
                          been designed to thermally process containers after agents are removed
                          from them; however, containers that are now empty are not considered
                          part of the stockpile and for that reason cannot be processed through
                          csup facilities.
                      l   The Edgewood area of Aberdeen Proving Ground is also dismantling an
                          unneeded pilot-scale chemical production plant. Many of the metal parts
                          being removed from the building were possibly contaminated during the
                          past production of various chemical agents. To decontaminate these
                          metal parts, the Army plans to request fiscal year 1993 and 1994 fund-
                          ing totaling $13.6 million for the construction of a separate incineration
                          facility. The cost of designing and acquiring the necessary environmen-
                          tal permits prior to construction will cost an additional $1.2 million.
                          Some of these expenditures could be avoided if the Army were allowed
                          to use the CSDP facility to accomplish the necessary decontamination.




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                  Chapter 5
                  Chemical Stockpile Disposal Program
                  Facilities Could Be Used for Other Purposes




                  The chemical stockpile disposal facilities have greater potential uses
Conclusions       than current legislation allows. Efficiency would dictate that this
                  expanded use be encouraged, particularly in view of the Army’s existing
                  plans to construct separate incinerators within the same general area of
                  at least one CSDPfacility.


                  If the congressionally directed study demonstrates that CSDPdisposal
Recommendations   facilities could be safely and efficiently used for the destruction of other
                  hazardous wastes, we recommend that the Secretary of Defense sponsor
                  a request for a legislative change that would allow such usage.

                  We also recommend that, regardless of the study’s results, the Secretary
                  of the Army propose an amendment to the existing legislation that
                  would allow the CSDPincinerators that the Army plans to build in Aber-
                  deen, Maryland, to be used to decontaminate and thermally treat empty
                  l-ton containers and metal parts removed from a former chemical pro-
                  duction plant.




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                                                                                             +
                                                                                                 .

Appendix I

Major Contributorsto This Report


NationalSeCUdtY   and   DerekB.Stewart,
                                     Advisor
International Affairs
Division, Washington,
D.C.

-
Philadelphia Regional   Marianne T. Rullo, Evaluator
Office                  Naveena D. Bembry, Evaluator




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