oversight

Chemical Weapons and Materiel: Key Factors Affecting Disposal Costs and Schedule

Published by the Government Accountability Office on 1997-02-10.

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

                  United States General Accounting Office

GAO               Report to Congressional Committees




February 1997
                  CHEMICAL WEAPONS
                  AND MATERIEL
                  Key Factors Affecting
                  Disposal Costs and
                  Schedule




GAO/NSIAD-97-18
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      National Security and
      International Affairs Division

      B-266135

      February 10, 1997

      The Honorable Ted Stevens
      Chairman
      The Honorable Daniel K. Inouye
      Ranking Minority Member
      Subcommittee on Defense
      Committee on Appropriations
      United States Senate

      The Honorable Floyd D. Spence
      Chairman
      The Honorable Ronald V. Dellums
      Ranking Minority Member
      Committee on National Security
      House of Representatives

      The Honorable C.W. Bill Young
      Chairman
      The Honorable John P. Murtha
      Ranking Minority Member
      Subcommittee on National Security
      Committee on Appropriations
      House of Representatives

      This report describes the Department of Defense’s programs for destroying the U.S. stockpile of
      chemical munitions and planning for the disposal of nonstockpile chemical warfare materiel.
      The programs’ combined life-cycle cost estimate is $27.6 billion, which includes $12.4 billion for
      the Chemical Stockpile Disposal Program and $15.2 billion for the Nonstockpile Chemical
      Materiel Program. This report provides an overall assessment of the programs’ cost and
      schedule, alternatives for improving program effectiveness and efficiency, and actions the Army
      has and is taking to improve the programs.

      Should the Congress wish to consider changing the programs’ current path, this report
      discusses several options for addressing the key factors affecting the programs. We are not
      taking a position on the options or current approach, rather the options are presented in
      context of the tradeoffs they present.

      We prepared this report under our basic legislative responsibilities. We are providing it to you
      because of your oversight responsibilities for chemical weapons disposal programs.
B-266135

We are sending copies of this report to the Secretaries of Defense and the Army, the Director of
the Office of Management and Budget, and other interested parties. We will make copies
available to others upon request.

This report was prepared under the direction of David R. Warren, Director, Defense
Management Issues, who may be reached at (202) 512-8412 if you or your staff have any
questions. Other major contributors are listed in appendix VI.




Henry L. Hinton, Jr.
Assistant Comptroller General




                     Page 2                            GAO/NSIAD-97-18 Chemical Weapons and Materiel
B-266135




           Page 3   GAO/NSIAD-97-18 Chemical Weapons and Materiel
Executive Summary


             Since 1985, the Army has spent $3.2 billion on its programs for destroying
Purpose      the U.S. stockpile of chemical munitions and planning for the disposal of
             nonstockpile chemical warfare materiel. Today, the programs are still in
             the early stages of implementation and the Army estimates that
             $24.4 billion more will be needed to complete them.1 Since 1990, GAO has
             issued a number of reports addressing opportunities to improve various
             aspects of the disposal programs. Due to continuing congressional and
             public interest about the progress and cost of the programs, GAO prepared
             this report under its basic legislative responsibilities to provide an overall
             assessment of the (1) programs’ cost and schedule, (2) alternatives for
             improving program effectiveness and efficiency, and (3) actions the Army
             has and is taking to improve the programs.


             In 1985, the Congress passed Public Law 99-145 directing the Army to
Background   destroy the U.S. stockpile of obsolete chemical agents and munitions. The
             stockpile consists of rockets, bombs, projectiles, spray tanks, and bulk
             containers, which contain nerve and mustard agents. It is stored at eight
             sites in the continental United States and on Johnston Atoll in the Pacific
             Ocean. To comply with congressional direction, the Army established the
             Chemical Stockpile Disposal Program and developed a plan to incinerate
             the agents and munitions on site in specially designed facilities.
             Recognizing that the stockpile program did not include all chemical
             warfare materiel requiring disposal, the Congress directed the Army in
             1992 to plan for the disposal of materiel not included in the stockpile. This
             materiel, some of which dates back as far as World War I, consists of
             binary chemical weapons, miscellaneous chemical warfare materiel,
             recovered chemical weapons, former production facilities, and buried
             chemical warfare materiel.2 In 1992, the Army established the
             Nonstockpile Chemical Materiel Program to dispose of the materiel.

             In 1993, the United States signed the U.N.-sponsored Chemical Weapons
             Convention. In October 1996, the 65th nation ratified the convention
             making the treaty effective on April 29, 1997.3 If the U.S. Senate approves


             1
              The programs’ combined life-cycle cost estimate is $27.6 billion. This amount includes $12.4 billion for
             the Chemical Stockpile Disposal Program and $15.2 billion for the Nonstockpile Chemical Materiel
             Program.
             2
              Binary weapons are formed from two nonlethal elements through a chemical reaction after the
             munitions are fired or launched. The weapons were manufactured, stored, and transported with only
             one of the chemical elements in the weapon. The second element was to be loaded into the weapon at
             the battlefield.
             3
              The convention becomes effective 180 days after the 65th nation ratified the treaty.



             Page 4                                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
                   Executive Summary




                   the convention, it could affect implementation of the disposal programs.4
                   Through ratification, the United States will agree to dispose of its
                   (1) unitary chemical weapons stockpile, binary chemical weapons,
                   recovered chemical weapons, and former chemical weapon production
                   facilities by April 29, 2007, and (2) miscellaneous chemical warfare
                   materiel by April 29, 2002. If a country is unable to maintain the
                   convention’s disposal schedule, the convention’s Organization for the
                   Prohibition of Chemical Weapons may grant a one-time extension of up to
                   5 years. Under the terms of the convention, chemical warfare materiel
                   buried before 1977 is exempt from disposal as long as it remains buried.
                   Should the United States choose to excavate the sites and remove the
                   chemical materiel, the provisions of the convention would apply. As of
                   December 1996, the Senate has not approved the convention. However,
                   the United States is still committed by public law to destroying its
                   chemical stockpile and related warfare materiel.

                   In prior reports, GAO expressed concern about the Army’s lack of progress
                   and the rising cost of the disposal programs. (See Related GAO Products.)
                   In 1991, GAO reported that continued problems in the program indicated
                   that increased costs and additional time to destroy the chemical stockpile
                   should be expected. GAO recommended that the Army determine whether
                   faster and less costly technologies were available to destroy the stockpile.5
                   In a 1995 report on the nonstockpile program, GAO concluded that the
                   Army’s plans for disposing of nonstockpile chemical warfare materiel
                   were not final and, as a result, its cost estimate was likely to change.6 On
                   July 13, 1995, GAO testified that the Army had experienced significant cost
                   growth and delays in executing its stockpile disposal program and that
                   further cost growth and schedule slippages could occur.7


                   While there is general agreement about the need to destroy the chemical
Results in Brief   stockpile and related materiel, progress has slowed due to the lack of
                   consensus among the Department of Defense (DOD) and affected states
                   and localities about the destruction method that should be used. As a
                   result, the cost and schedule for the disposal programs are uncertain.

                   4
                    Under the U.S. Constitution, treaties must be approved by a two-thirds majority of the Senate.
                   5
                   Chemical Weapons: Stockpile Destruction Cost Growth and Schedule Slippages Are Likely to
                   Continue (GAO/NSIAD-92-18, Nov. 20, 1991).
                   6
                    Chemical Weapons Disposal: Plans for Nonstockpile Chemical Warfare Materiel Can Be Improved
                   (GAO/NSIAD-95-55, Dec. 20, 1994).
                   7
                    Chemical Weapons Disposal: Issues Related to DOD’s Management (GAO/T-NSIAD-95-185, July 13,
                   1995).



                   Page 5                                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
Executive Summary




However, they will cost more than the estimated $24.4 billion above
current expenditures and take longer than currently planned. The key
factors impacting the programs include public concerns over the safety of
incineration, compliance with environmental laws and regulations,
legislative requirements, and the introduction of alternative disposal
technologies.

The Chemical Stockpile Disposal Program cost and schedule are largely
driven by the degree to which states and local communities are in
agreement with the proposed disposal method at the remaining stockpile
sites. Based on program experience, reaching agreement has consistently
taken longer than the Army anticipated. For example, the Army has
consistently underestimated the time required to obtain environmental
permits for the disposal facilities. Furthermore, congressional direction in
the 1997 Authorization and Appropriations Acts to research and develop
alternative technologies to destroy assembled chemical munitions
indicates that there are continued public concerns about the proposed
disposal method. Until DOD and the affected states and localities reach
agreement on a disposal method for the remaining stockpile sites, the
Army will not be able to predict the Chemical Stockpile Disposal Program
cost and schedule with any degree of accuracy. Moreover, many of the
problems experienced in the stockpile program are also likely to affect the
Army’s ability to implement the Nonstockpile Chemical Materiel Program.
For example, efforts to dispose of nonstockpile materiel are likely to be
driven by the need to obtain state and local approvals for destruction
methods. In addition, more time is needed for the Army to prove that its
proposed disposal method for the nonstockpile program will be safe and
effective and accepted by the affected states and localities.

Recognizing the difficulty of satisfactorily resolving the public concerns
associated with each individual disposal location, suggestions have been
made by members of the Congress, DOD officials, and others to change the
programs’ basic approach to destruction. However, the suggestions create
trade-offs for decisionmakers and would require changes in existing legal
requirements. These suggestions have included deferring plans for
additional disposal facilities until an acceptable alternative technology to
incineration is developed, consolidating disposal operations at a national
or regional sites, destroying selected nonstockpile chemical warfare
materiel in stockpile disposal facilities, establishing a centralized disposal
facility for nonstockpile materiel, and modifying existing laws and
regulations to standardize environmental requirements.




Page 6                             GAO/NSIAD-97-18 Chemical Weapons and Materiel
                             Executive Summary




                             Notwithstanding these overarching issues, DOD and the Army have taken
                             actions in response to congressional direction and GAO recommendations
                             to improve program management. In December 1994, DOD designated the
                             Army’s chemical demilitarization program, consisting of both stockpile
                             and nonstockpile munitions and materiel, as a major defense acquisition
                             program. The objectives of the designation were to stabilize the disposal
                             schedules, control costs, and provide more discipline and higher levels of
                             program oversight. In addition, the Army initiated actions to identify
                             options for reducing costs. Army officials have identified cost-reduction
                             initiatives, which are in various stages of assessment, that could
                             potentially reduce program costs by $673 million. However, the Army
                             cannot implement some of the more significant initiatives without the
                             cooperation and approval of state regulatory agencies.



Principal Findings

The Stockpile Program’s      The stockpile program will likely exceed its $12.4 billion estimate and take
Cost and Schedule Are        longer than the legislative completion date of December 2004.8 This is
Uncertain, but Will Exceed   because reaching agreement on site specific disposal methods has
                             consistently taken longer than the Army anticipated. Public concerns
Current Estimates            about the safety of incineration have (1) resulted in additional
                             environmental requirements, (2) slowed the permitting of new
                             incinerators, and (3) required the Army to research disposal alternatives.

                             Since 1985, the Army’s cost estimate for the stockpile disposal program
                             has increased seven-fold, from an initial estimate of $1.7 billion to
                             $12.4 billion, and the planned completion date has been delayed from 1994
                             to 2004. Although the Army is committed to destroying the stockpile by the
                             legislatively imposed deadline of December 31, 2004, it is unlikely to meet
                             that date. Only two of the nine planned disposal facilities are built and
                             operating, 4 percent of the stockpile has been destroyed, and
                             environmental permitting issues at the individual sites continue to delay
                             construction of the remaining facilities. For example, since the Army
                             developed the most recent cost and schedule estimate in February 1996,
                             the plant construction schedule has slipped at Anniston, Alabama; Blue
                             Grass, Kentucky; Pine Bluff, Arkansas; Pueblo, Colorado; and Umatilla,
                             Oregon.


                             8
                             Approximately $1 billion of the estimated $12.4 billion is associated with the Chemical Stockpile
                             Emergency Preparedness Program.



                             Page 7                                        GAO/NSIAD-97-18 Chemical Weapons and Materiel
Executive Summary




Predicting the disposal schedule for the various sites is difficult. According
to Army officials, this is partly due to the uncertainty of the time required
to satisfy changing environmental requirements. For example, although
based on federal requirements, individual state environmental
requirements differ and are occasionally changed. In addition, according
to the Army, the original scope of the health risk assessment to operate the
disposal facilities was not completely defined, the health assessment
requirements have changed, and the requirements currently vary from
state to state. According to DOD officials, states have modified the
requirements of their health risk assessments well into the process,
delaying the development of the final assessment document. According to
Environmental Protection Agency officials, the agency has issued several
guidance documents concerning health risk assessments and has tried to
keep the Army informed of the changes and updates in the guidance. In
addition, the Environmental Protection Agency has advised the Army to
meet with state officials early in the process to agree on the methodology
and standards to use in the development of the assessments.

Based on program experience, the Army’s 1996 schedule does not provide
sufficient time for the Army to complete the environmental approval
process.9 For example, the schedule for the Anniston disposal facility
includes a grace period of a month for any slippage in the construction,
systemization, or operation to meet the legislative completion date of
December 31, 2004. Although the Army estimated that the permit would
have been issued by the end of September 1996, Alabama regulatory
officials expect the permit to be issued in June or July 1997—a slippage of
approximately 8 months in the schedule. The Army’s revised schedule
shows Alabama issuing the permit at the end of March 1997. Based on
current expectations, disposal operations at Anniston would extend to
mid-2005.

In the 1997 National Defense Authorization Act, the Congress directed DOD
to conduct an assessment of alternative technologies for the disposal of
assembled chemical munitions.10 The act also directed the Secretary of
Defense to report on the assessment by December 31, 1997. Similarly, the
1997 DOD Appropriations Act provided $40 million to conduct a pilot

9
 Department of Defense’s Interim Status Assessment for the Chemical Demilitarization Program, DOD
(Apr. 15, 1996).
10
  In the 1993 National Defense Authorization Act, the Congress directed the Army to report on
potential technological alternatives to incineration. Consequently, in August 1994, the Army initiated a
program to investigate, develop, and support testing of alternative disposal technologies for the two
bulk-only stockpile sites—Aberdeen Proving Ground, Maryland, and Newport Chemical Activity,
Indiana. This program is still in the development and testing phase.



Page 8                                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
                     Executive Summary




                     program to identify and demonstrate two or more alternatives to the
                     baseline incineration process for the disposal of assembled chemical
                     munitions. The act also prohibited DOD from obligating any funds for
                     constructing disposal facilities at Blue Grass, Kentucky, and Pueblo,
                     Colorado, until 180 days after the Secretary reports on the alternatives.
                     Although the prohibition applies only to Blue Grass and Pueblo, public
                     concerns about incineration may prompt state regulators at other
                     locations to delay their final decisions to permit incinerators until the
                     Secretary reports his findings.

                     According to Army officials, alternative technologies may not reduce costs
                     or shorten disposal operations but are likely to be acceptable to a larger
                     segment of the public than incineration. The Army is currently researching
                     technological alternatives to dispose of chemical agents at the two
                     bulk-only stockpile sites. It is also planning to develop a program to
                     respond to recent congressional direction to research alternative
                     technologies to dispose of assembled chemical munitions. According to
                     the National Research Council, the Army has successfully involved the
                     state and the public in its alternative technology project for the two
                     bulk-only stockpile sites, demonstrating the importance of public
                     involvement to the progress of a program.11 The development of
                     alternative disposal technologies for assembled chemical munitions
                     provides the Army the mechanism for encouraging public involvement and
                     establishing common objectives for the remaining disposal sites.


The Nonstockpile     The Army has spent $105.9 million and estimates that the nonstockpile
Program’s Cost and   program could cost another $15.1 billion and take nearly 40 years to
Schedule Are Also    complete. However, given the factors driving the program, it is uncertain
                     how long the program will take or cost. The program is driven by the
Uncertain            uncertainties surrounding buried chemical warfare materiel and unproven
                     disposal methods. Although Army officials are confident that the proposed
                     disposal systems will function as planned, the Army needs more time to
                     prove that the systems will safely and effectively destroy all nonstockpile
                     materiel and be accepted by the affected states and communities.
                     Environmental issues similar to those experienced in the stockpile
                     program are also likely to affect the Army’s ability to obtain the
                     environmental approvals and permits that virtually all nonstockpile
                     activities require.



                     11
                        Public Involvement and the Army Chemical Stockpile Disposal Program, National Research Council
                     (Oct. 25, 1996).



                     Page 9                                      GAO/NSIAD-97-18 Chemical Weapons and Materiel
                           Executive Summary




                           The Army estimates that it can dispose of binary weapons, recovered
                           chemical weapons, former production facilities, and miscellaneous
                           chemical warfare materiel within the time frames established by the
                           Chemical Weapons Convention. Under the terms of the convention,
                           chemical warfare materiel buried before 1977 is exempt from disposal as
                           long as it remains buried. Although the Army estimates that buried
                           chemical materiel accounts for $14.5 billion (95 percent) of the
                           nonstockpile program cost, the Army is still exploring potential sites and
                           has little and often imprecise information about the type and amount of
                           materiel buried. The Army estimated that it will take until 2033 to identify,
                           recover, and dispose of buried nonstockpile materiel.

                           Also, additional time is needed for the Army to demonstrate that its mobile
                           disposal systems are safe and effective and will meet state environmental
                           requirements. The Army’s disposal concept is based on developing mobile
                           systems capable of moving from one location to the next where the
                           munitions are remotely detoxified and the waste is transported to a
                           commercial hazardous waste facility. Although the systems may operate in
                           a semi-fixed mode, they are scheduled to be available for mobile use at
                           recovered and burial sites after 1998. Whether the systems are allowed to
                           operate at a particular location will depend on the state regulatory agency
                           with authority over the disposal operations. In addition, public acceptance
                           or rejection of the mobile systems will affect their transportation plans
                           and disposal operations.


Alternatives to the        Recognizing the difficulty of resolving the public concerns associated with
Programs’ Basic Approach   each individual disposal location, suggestions have been made to change
to Destruction             the programs’ basic approach to destruction. For example, Members of the
                           Congress and officials from environmental groups and affected states and
                           counties have suggested deferring plans for additional disposal facilities
                           until an acceptable alternative technology to incineration is developed.
                           Congressional members have also suggested consolidating disposal
                           operations at a national or regional sites. In addition, officials of various
                           DOD organizations have suggested destroying selected nonstockpile
                           chemical warfare materiel in stockpile disposal facilities, establishing a
                           centralized disposal facility for nonstockpile materiel, and modifying
                           existing laws and regulations to standardize environmental requirements.

                           Deferring disposal operations may eliminate much of the public concern
                           that has influenced the current approach to destroying the chemical
                           stockpile because alternative technologies are likely to be acceptable to a



                           Page 10                            GAO/NSIAD-97-18 Chemical Weapons and Materiel
Executive Summary




larger segment of the affected states and local communities than
incineration. However, given the current status of alternative technologies,
the cost and schedule would remain uncertain, and there would be a
corresponding increase in the risk of an accident from continued storage
of the munitions. Although the Army has been researching technological
alternatives to incineration for chemical agents stored in bulk containers,
only recently have research and testing demonstrated potentially effective
alternatives. Currently, there is no proven alternative technology to
incineration capable of safely and effectively destroying assembled
chemical munitions.

Consolidating disposal operations could reduce construction and
procurement costs, but the required transportation of chemical munitions
could be an insurmountable barrier. This option would extend the disposal
schedule and result in increased risk not only from storage but also from
handling and transportation. Although consolidating disposal operations
could reduce estimated facility construction and operation costs by as
much as $2.6 billion, the savings would be reduced by uncertain but
potentially significant transportation and emergency preparedness costs.
To help reduce costs, the Army would have to consolidate three or more
stockpile sites, develop less expensive transportation containers, and
control emergency response costs. In 1988, the Army and many in the
Congress rejected transporting the chemical stockpile weapons to a
national or regional disposal sites because of the increased risk to the
public and the environment from moving the munitions. DOD and Army
officials continue to be concerned about the safety of moving chemical
weapons and public opposition to transportation of the munitions has
grown since 1988.

Similarly, using the chemical stockpile facilities or a national disposal
facility to destroy nonstockpile chemical materiel has the potential for
reducing costs. Although selected nonstockpile items could be destroyed
in stockpile disposal facilities, the 1986 DOD Authorization Act, and
subsequent legislation, specifies that the chemical stockpile disposal
facilities may not be used for any purpose other than the disposal of
stockpile weapons. This legislative provision, in some cases, necessitates
that the Army implement separate disposal operations for nonstockpile
materiel along side of the stockpile facilities. In its 1995 implementation
plan, the Army suggested that the stockpile disposal facilities could be
used to process some nonstockpile weapons, depending on the location,




Page 11                           GAO/NSIAD-97-18 Chemical Weapons and Materiel
                         Executive Summary




                         the type of chemical weapon or materiel, and condition.12 Another method
                         for destroying nonstockpile chemical materiel could be based on the use
                         of a central disposal facility with equipment designed specifically for
                         destroying nonstockpile materiel. Although a national disposal facility
                         could reduce program costs, the legislative restrictions on the
                         transportation of nonstockpile chemical material and the prevalent public
                         attitude that such a disposal facility should not be located in their vicinity
                         would be significant obstacles that would have to be resolved.

                         Modifying existing laws and regulations to standardize environmental
                         requirements could enhance both the stockpile and nonstockpile
                         programs’ stability and control costs. The current process of individual
                         states establishing their own environmental laws and requirements and the
                         prevalent public attitude that the Army’s disposal facilities should not be
                         located in their vicinity have been obstacles to the stockpile disposal
                         program and are also likely to affect the nonstockpile program. For
                         example, individual state environmental requirements differ and are
                         occasionally changed. As a result, there is no standard environmental
                         protocol and requirements for stockpile and nonstockpile disposal sites.
                         According to the Army, establishing standardized environmental
                         requirements for all disposal sites would enhance the programs’ stability.
                         However, efforts to modify existing laws and regulations to standardize
                         the environmental requirements for chemical weapons disposal would
                         likely be resisted by the affected states and localities, and environmental
                         organizations.


Steps Taken to Improve   DOD and the Army have taken encouraging steps, some in response to GAO’s
the Disposal Programs    recommendations, to improve their management and oversight of the
                         stockpile and nonstockpile programs. In December 1994, DOD designated
                         the Army’s chemical demilitarization program, consisting of both stockpile
                         and nonstockpile munitions and materiel, as a major defense acquisition
                         program. The objectives of the designation were to stabilize the disposal
                         schedules, control costs, and provide more discipline and higher levels of
                         program oversight. In response to recommendations by the National
                         Research Council and GAO, the Army initiated the Enhanced Stockpile
                         Surveillance Program in 1995 to improve its monitoring and inspection of
                         chemical munitions. On the basis of those activities, the Army estimates
                         that the stockpile will be reasonably stable through 2013.



                         12
                          Non-Stockpile Chemical Materiel Program Implementation Plan, U.S. Army Program Manager for
                         Chemical Demilitarization (Aug. 1995).



                         Page 12                                    GAO/NSIAD-97-18 Chemical Weapons and Materiel
                  Executive Summary




                  The Army’s review of the stockpile disposal program has identified several
                  promising cost-reduction initiatives, but the Army cannot implement some
                  of the more significant initiatives without the cooperation and approval of
                  state regulatory agencies. Army officials estimated that the initial
                  cost-reduction initiatives, which are in various stages of assessment, could
                  potentially reduce program costs by $673 million. The Army plans to
                  submit its assessment of the initiatives to the Congress with its fiscal
                  year 1998 budget request. It also plans to identify additional cost
                  reductions as the stockpile program progresses.


                  As the Congress continues its oversight of the chemical stockpile and
Matters for       nonstockpile disposal programs and considers modifications or
Congressional     alternatives to the current approach, it may wish to include consideration
Consideration     of the suggestions discussed in this report relating to the creation of
                  alternative technologies, consolidation of stockpile disposal operations,
                  utilization of stockpile facilities for nonstockpile items, centralization of
                  nonstockpile destruction, and standardization of environmental laws and
                  requirements.


                  DOD provided written comments on a draft of this report and they are
Agency Comments   presented in appendix V. DOD stated that the draft accurately and fairly
                  characterized the current status of the disposal programs and generally
                  concurred with the suggestions of the draft report that changes in existing
                  legal requirements would be necessary to change the current path of the
                  disposal programs. DOD also concurred with GAO’s suggestions that should
                  the Congress decide to consider modifications or alternatives to the
                  current approach, it could consider the ones to establish a centralized
                  disposal facility for nonstockpile materiel and to modify existing laws and
                  regulations to standardize environmental requirements for chemical
                  weapons disposal. DOD recommended against consideration of the options
                  to defer incineration plans, consolidate disposal operations, and to use
                  stockpile facilities for destroying nonstockpile items.




                  Page 13                            GAO/NSIAD-97-18 Chemical Weapons and Materiel
Contents



Executive Summary                                                                                  4


Chapter 1                                                                                         16
                        The U.S. Chemical Warfare Materiel                                        16
Introduction            Evolution of the Disposal Process                                         18
                        Management Structure of the Disposal Programs                             21
                        International Efforts to Eliminate Chemical Agents and Weapons            22
                        Our Prior Concerns With the Army’s Disposal Programs                      24

Chapter 2                                                                                         25
                        The Army’s Chemical Stockpile Disposal Program                            25
The Chemical            Program Delays Past 2004 Are Likely                                       28
Stockpile Disposal      Program Costs Will Likely Exceed                                          33
                          $12.4 Billion
Program Will Require    The Stockpile Should Be Stable Through 2013                               33
More Time and Funds     Program Alternatives Generate Trade-offs                                  34
Than Currently
Planned
Chapter 3                                                                                         40
                        The Army Is Far From Accomplishing Its Objectives                         40
The Nonstockpile        Recovery and Disposal of Buried Chemical Warfare Materiel Will            42
Program Is Likely to      Be Problematic
                        Environmental Laws and Requirements Govern Most                           45
Be Affected by Issues     Nonstockpile Activities
Similar to Those in     The Army’s Mobile Disposal Systems Are Not Fully Developed                47
the Stockpile Program   Opportunities for Cost and Schedule Reductions Are Limited                52

Chapter 4                                                                                         55
                        Conclusions                                                               55
Conclusions, Matters    Matters for Congressional Consideration                                   56
for Congressional       Agency Comments                                                           56
Consideration, and
Agency Comments
Appendixes              Appendix I: Objectives, Scope, and Methodology                            58
                        Appendix II: Appropriated, Obligated, and Disbursement Data for           60
                          Fiscal Years 1988 Through 1997




                        Page 14                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
                       Contents




                       Appendix III: Summary of Major Federal Environmental Laws                  62
                         Affecting the Army’s Disposal Programs
                       Appendix IV: Chronology of the U.S. Chemical Demilitarization              63
                         Program
                       Appendix V: Comments From the Department of Defense                        66
                       Appendix VI: Major Contributors to This Report                             69

Related GAO Products                                                                              71


Tables                 Table 2.1: Slippage in the Army’s Estimated Dates for                      31
                         Construction Permits at the Remaining Seven Disposal Sites
                       Table 2.2: The Army’s Initial Cost-Reduction Initiatives as of             38
                         August 1996
                       Table 3.1: Summary of Nonstockpile Program Activities                      41
                       Table 3.2: Summary of the Nonstockpile Disposal Systems and                47
                         Estimated Operational Dates
                       Table II.1: Chemical Stockpile Disposal Program                            60
                       Table II.2: Alternative Technologies and Approaches Project                60
                       Table II.3: Chemical Stockpile Emergency Preparedness Project              60
                       Table II.4: Nonstockpile Chemical Materiel Program                         61

Figures                Figure 1.1: Percent of Appropriated Funds by Category for Fiscal           17
                         Years 1988 through 1996
                       Figure 1.2: The Baseline Disassembly and High-Temperature                  20
                         Incineration Process
                       Figure 2.1: The U.S. Stockpile of Chemical Agents and Munitions            26
                       Figure 2.2: Key Dates for the Chemical Stockpile Disposal                  27
                         Program After January 2004
                       Figure 3.1: Potential Locations With Buried Chemical Warfare               43
                         Materiel
                       Figure 3.2: Conceptual Drawing of the Rapid Response System                49
                       Figure 3.3: Conceptual Drawing of the Munitions Management                 51
                         Device-1




                       Abbreviations

                       DOD        Department of Defense


                       Page 15                          GAO/NSIAD-97-18 Chemical Weapons and Materiel
Chapter 1

Introduction


                    For nearly 80 years, the United States produced and stored chemical
                    weapons to deter other countries from using them against U.S. military
                    personnel. In 1985, the Congress directed the Department of Defense
                    (DOD) to destroy the U.S. stockpile of chemical munitions and establish a
                    management organization within the Army to be responsible for the
                    disposal programs. In 1992, the Congress directed the Army to plan for the
                    disposal of chemical warfare materiel not included in the stockpile. The
                    Army has spent nearly $3.2 billion on its efforts and estimates that it will
                    cost $24.4 billion and take nearly 40 years to dispose of the remaining
                    chemical stockpile weapons and nonstockpile chemical warfare materiel.
                    Although the Army is committed to destroying the chemical stockpile by
                    the legislatively imposed deadline of December 31, 2004, only two of the
                    nine planned disposal facilities are built and operating, 4 percent of the
                    stockpile and little of the nonstockpile materiel have been destroyed, and
                    environmental issues continue to delay the remaining facilities. Currently,
                    the Army has more than 30,000 tons of chemical agent stored at 9 sites and
                    an unknown amount potentially buried at 64 locations in the United States
                    and its territories.


                    U.S. chemical warfare materiel is classified as either chemical stockpile or
The U.S. Chemical   nonstockpile materiel. Since World War I, the United States has
Warfare Materiel    maintained a stockpile of chemical weapons and agents to deter the use of
                    chemical weapons against its troops. The stockpile consists of rockets,
                    bombs, projectiles, spray tanks, and bulk containers. Some munitions
                    contain nerve agents, which can disrupt the nervous system and lead to
                    loss of muscular control and death. Others contain a series of mustard
                    agents that blister the skin and can be lethal in large amounts.
                    Nonstockpile materiel consists of all other chemical warfare items,
                    including binary chemical weapons, miscellaneous chemical warfare
                    materiel, recovered chemical weapons, former production facilities, and
                    buried chemical warfare materiel.

                    Historically, DOD has placed a higher priority on the destruction of the
                    chemical stockpile because most nonstockpile items did not pose an
                    immediate hazard to the environment or public health. Potential threats to
                    the chemical stockpile include external events such as earthquakes,
                    airplane crashes, and tornadoes; and internal events such as spontaneous
                    leakage of chemical agents, accidents during normal handling and
                    maintenance activities, and self-ignition of propellant. Nonstockpile items,
                    such as binary weapons’ components, miscellaneous warfare materiel, and
                    recovered chemical weapons, were placed in storage and old chemical



                    Page 16                           GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                      Chapter 1
                                      Introduction




                                      production facilities were closed years ago. Although documentation
                                      surveys, interviews, and site visits have been conducted, much of the
                                      information concerning burial sites remains unknown. The priority for
                                      destroying nonstockpile materiel has increased because of recent
                                      accidental discoveries of buried materiel, congressional interest, and
                                      international efforts to destroy chemical weapons.

                                      The Army has spent nearly $3.2 billion on its efforts to destroy its chemical
                                      stockpile weapons and nonstockpile chemical warfare materiel. (See
                                      app. II.) As shown in figure 1.1, more than half of the funds has been
                                      appropriated for operations and maintenance activities, such as operating
                                      salaries and utilities, and systems engineering and program management.
                                      The balance has funded procurement of equipment, construction of
                                      facilities, and research and development activities.


Figure 1.1: Percent of Appropriated
Funds by Category for Fiscal Years                                                      Procurement
1988 through 1996
                                                                                        4%
                                                                                        Research and development


                                                        •



                                           • 31%
                                                                    52% •               Operations and maintenance




                                                13%
                                                  •



                                                                                        Construction



                                      Source: Based on data from DOD’s Selected Acquisition Report dated December 31, 1995.




                                      Page 17                                   GAO/NSIAD-97-18 Chemical Weapons and Materiel
                          Chapter 1
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                          From 1917 through the 1960s, obsolete or unserviceable chemical warfare
Evolution of the          agents and munitions were disposed of by open pit burning, land burial,
Disposal Process          and ocean dumping. In 1969, an Army plan to dispose of chemical agents
                          and munitions at sea raised public concerns about the safety of
                          transporting chemical weapons from their storage sites to a port of
                          embarkation and about the potential effects of ocean dumping on the
                          environment. In June 1969, the National Academy of Sciences
                          recommended that ocean dumping be avoided and that public health and
                          environmental protection be emphasized. It suggested two alternatives to
                          ocean disposal: incineration of mustard agents and chemical neutralization
                          of nerve agents. In response, the Army stopped ocean dumping operations.1
                          (See chronology in app. IV.)


Use of Incineration and   During the 1970s, the Army destroyed obsolete chemical weapons
Chemical Neutralization   primarily by high-temperature incineration or by chemical neutralization.
                          The neutralization process involves altering the chemical, physical, and
                          toxicological properties of a chemical warfare agent to render it
                          ineffective for use as intended. In 1984, the National Research Council,
                          under the auspices of the National Academy of Sciences, decided that
                          incineration was the more desirable disposal method. It concluded that the
                          neutralization process was more costly and produced larger quantities of
                          waste than incineration. In 1986, the Army submitted to the Congress a
                          plan to dispose of the chemical stockpile. Its plan considered the costs and
                          potential problems associated with three options: (1) transferring the
                          entire stockpile to one site for disposal, (2) transferring it to two regional
                          disposal sites, and (3) operating separate disposal facilities at each of the
                          storage locations. In 1988, the Army formally announced that on-site
                          incineration was its preferred disposal method. The Army and many in the
                          Congress rejected transporting the chemical stockpile weapons to a
                          national or regional disposal sites because of the increased risk to the
                          public and the environment from moving the munitions.


The Army’s Baseline       A baseline incineration process uses a reverse-assembly procedure that
Incineration Process      drains the chemical agent from the weapons and containers and takes
                          apart the weapons in the reverse order of assembly. (See fig. 1.2.) Once
                          disassembled, the chemical agent and weapon parts are incinerated in
                          separate furnaces and the gaseous and solid waste is treated. Liquid brine
                          resulting from the treatment of exhaust gases in the pollution abatement


                          1
                           The last chemical munitions ocean dump occurred in August 1970.



                          Page 18                                     GAO/NSIAD-97-18 Chemical Weapons and Materiel
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Introduction




system is dried to reduce the volume and transported to a commercial
hazardous waste management facility.




Page 19                          GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                         Chapter 1
                                         Introduction




Figure 1.2: The Baseline Disassembly and High-Temperature Incineration Process




                           Dunnage


                                                                                  The dunnage incinerator
       Projectile                                                                 burns packing materials
                                                                                  and wooden pallets.




                                                                                                              The pollution-abatement
                                                                                  Explosives and              system cools and
                                                                                  propellants are             "scrubs" exhaust gases,
                                                                                  incinerated in the          chemically neutralizes
                                Burster and                                       deactivation furnace.       components, and
                               Supplementary                                                                  removes pollutants.
                                  Charge
  Chemical
  weapons such as
  this projectile are
  taken apart by
  machines in the
  reverse order of
  assembly.
                                Chemical Agent



                                                                                     The liquid incinerator
                                                                                     destroys the chemical
                                                                                     agent and
                                                                                     decontamination
                                                                                     solutions.


                                                                                                     The metal parts furnace
                                                                                                     decontaminates the
                                  Metal Body
                                                                                                     metals, which may be
                                                                                                     sold as scrap.
                                                                                                     Other residual materials
                                                                                                     are shipped to a
                                                                                                     hazardous-waste
                                                                                                     landfill.


                                         Source: Based on data provided by the Army’s Program Manager for Chemical Demilitarization.




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Potential Alternatives to   In November 1991, because of public concern about the safety of
Incineration                incineration, the Army requested the National Research Council to
                            evaluate potential technological alternatives to the baseline incineration
                            process. In the 1993 National Defense Authorization Act (P.L. 102-484), the
                            Congress directed the Army to use the National Research Council’s
                            evaluation and report on potential technological alternatives to
                            incineration.2 The Congress also directed the Army to consider safety,
                            environmental protection, and cost-effectiveness when evaluating
                            alternative technologies. Consequently, in August 1994, the Army initiated
                            a more aggressive research and development program, called the
                            Alternative Technologies and Approaches Project, to investigate, develop,
                            and support testing of two technologies based on chemical neutralization
                            of chemical agents at the bulk-only stockpile sites—Aberdeen Proving
                            Ground, Maryland, and Newport Chemical Activity, Indiana. In addition,
                            three other technologies—molten metal pyrolysis, high-temperature
                            hydrogenation, and electrochemical oxidation—have been tested and are
                            undergoing further development by the commercial firms promoting them.
                            This research and development effort is conducted in conjunction with
                            activities to implement the baseline incineration program.

                            In the 1997 National Defense Authorization Act (P.L. 104-201), the
                            Congress directed DOD to conduct an assessment of alternative
                            technologies for the disposal of assembled chemical munitions. The
                            authorization act also directed the Secretary of Defense to report on this
                            assessment by December 31, 1997. Similarly, the 1997 DOD Appropriations
                            Act (P.L. 104-208) provided $40 million to conduct a pilot program to
                            identify and demonstrate two or more alternatives to the baseline
                            incineration process for the disposal of assembled chemical munitions.
                            The appropriations act also prohibited DOD from obligating any funds for
                            constructing disposal facilities at Blue Grass, Kentucky, and Pueblo,
                            Colorado, until 180 days after the Secretary reports on the alternatives.


                            The Army was assigned responsibility for the chemical weapons stockpile
Management                  in 1981 when DOD designated the Army as its single manager for
Structure of the            ammunition. In March 1991, DOD directed that the Army be accountable for
Disposal Programs           the disposal of all chemical warfare material. The Assistant Secretary of
                            the Army (Research, Development and Acquisition), as the executive agent
                            for the chemical disposal programs, has oversight and policy authority for
                            the destruction of the chemical stockpile weapons and nonstockpile

                            2
                              U.S. Army’s Alternative Demilitarization Technology Report for Congress, Department of the Army
                            (Apr. 11, 1994).



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                            Chapter 1
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                            materiel. The Program Manager for Chemical Demilitarization is
                            responsible for implementing the disposal programs and ensuring the
                            maximum protection to the environment, the public, and personnel.

                            Because of increasing disposal costs and schedule slippage, changing
                            legislative and regulatory requirements, and growing public concern about
                            incineration, DOD designated the Army’s chemical demilitarization
                            program, consisting of both stockpile and nonstockpile munitions and
                            materiel, as a major defense acquisition program in December 1994. The
                            designation was intended to (1) stabilize the disposal schedule, (2) control
                            costs, and (3) provide more discipline and higher levels of program
                            oversight. As such, the Army has been required to

                        •   develop a program cost and schedule baseline;
                        •   prepare quarterly defense acquisition executive summaries, which are
                            intended to provide an early warning that the baseline may be exceeded;
                            and
                        •   submit an annual selected acquisition report to the Congress, which
                            includes variances from the program baseline schedule and cost.

                            Other organizations within and separate from DOD contribute to the
                            programs. For example, at formerly used defense sites, the U.S. Army
                            Corps of Engineers has overall responsibility for site investigations,
                            planning, excavations, and environmental cleanups of burial sites. In
                            addition, the Department of Health and Human Services oversees public
                            health issues, the Department of Transportation advises DOD on
                            transportation issues, and the Environmental Protection Agency oversees
                            the environmental aspects of the programs.


                            The 1925 Geneva Protocol established the international norm against the
International Efforts       use of chemical weapons in combat, but did not prohibit the production or
to Eliminate Chemical       deployment of chemical agents and munitions. In 1989 and 1990, the
Agents and Weapons          United States and Russia entered into two bilateral agreements that
                            required sharing of data on their respective chemical stockpiles, provided
                            for visits to confirm the accuracy of the shared data, and would eliminate
                            chemical weapons production and most of their chemical weapons.

                            In 1993, the United States, Russia, and more than 150 nations signed the
                            U.N.-sponsored Convention on the Prohibition of the Development,
                            Production, Stockpiling and the Use of Chemical Weapons and on Their
                            Destruction, commonly referred to as the Chemical Weapons Convention.



                            Page 22                           GAO/NSIAD-97-18 Chemical Weapons and Materiel
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In October 1996, the 65th nation ratified the Chemical Weapons
Convention, making the convention effective on April 29, 1997.3 However,
as of December 1996, the United States and Russia have not ratified the
convention. The group of ratifiers includes major industrial states such as
Australia, Canada, France, Germany, Italy, Japan, and the United Kingdom
of Great Britain; and a wide geographical range of nations such as Algeria,
Argentina, Armenia, Belarus, Brazil, Czech Republic, Georgia, India,
Ireland, Latvia, Mexico, Morocco, New Zealand, Oman, Poland, Romania,
Slovak Republic, South Africa, Tajikistan, Turkmenistan, and Uruguay.
Egypt, Iraq, Jordan, Libya, North Korea, Syria, and other countries, mainly
small island nations, have not yet signed the convention.

If the U.S. Senate approves the convention, it could affect implementation
of the disposal programs.4 Through ratification, the United States will
agree to dispose of its (1) unitary chemical weapons stockpile, binary
chemical weapons, recovered chemical weapons, and former chemical
weapon production facilities by April 29, 2007, and (2) miscellaneous
chemical warfare materiel by April 29, 2002. If a country is unable to
maintain the convention’s disposal schedule, the convention’s
Organization for the Prohibition of Chemical Weapons may grant a
one-time extension of up to 5 years. Under the terms of the convention,
chemical warfare materiel buried before 1977 is exempt from disposal as
long as it remains buried. Should the United States choose to excavate the
sites and remove the chemical materiel, the provisions of the convention
would apply. On November 30, 1993, the President submitted the
convention to the U.S. Senate for its approval. The Senate held hearings in
1994 and 1996, but has not approved the convention. However, the United
States is still committed by public law to destroying its chemical stockpile
and related warfare materiel.

Once Russia ratifies the convention, it will be committed to destroying its
chemical warfare stockpile by April 29, 2007, with a 5-year extension if
needed. However, Russia does not have an operational capability to
destroy large quantities of chemical weapons and would need to construct
several chemical weapons disposal facilities to meet the convention’s
requirement.5



3
 The convention becomes effective 180 days after the 65th nation ratified the convention.
4
 Under the U.S. Constitution, treaties must be approved by a two-thirds majority of the Senate.
5
 Weapons of Mass Destruction: Status of Cooperative Threat Reduction Program (GAO/NSIAD-96-222,
Sept. 27, 1996).



Page 23                                        GAO/NSIAD-97-18 Chemical Weapons and Materiel
                         Chapter 1
                         Introduction




                         Since 1990, we have issued a number of reports that focused on
Our Prior Concerns       interrelated issues involving cost and schedule estimates, performance,
With the Army’s          environmental compliance, stability of chemical weapons, and alternative
Disposal Programs        disposal technologies. (See Related GAO Products.) For example:

                     •   Chemical Weapons Disposal: Issues Related to DOD’s Management
                         (GAO/T-NSIAD-95-185, July 13, 1995). We reported that there was a possibility
                         of further cost growth and schedule slippage for the Chemical Stockpile
                         Disposal Program.
                     •   Chemical Weapons: Stability of the U.S. Stockpile (GAO/NSIAD-95-67, Dec. 22,
                         1994). We reported that the Army lacked data to conclusively predict the
                         stability of stockpiled chemical weapons.
                     •   Chemical Weapons Disposal: Plans for Nonstockpile Chemical Warfare
                         Materiel Can Be Improved (GAO/NSIAD-95-55, Dec. 20, 1994). We reported that
                         the Army’s plans for disposing of nonstockpile chemical warfare materiel
                         were not final and, as a result, its cost estimate was likely to change.
                     •   Chemical Weapons Destruction: Advantages and Disadvantages of
                         Alternatives to Incineration (GAO/NSIAD-94-123, Mar. 18, 1994). We reported
                         that alternative disposal technologies identified as most likely to be
                         feasible for the chemical stockpile program were in the initial stages of
                         development and over a decade away from operation.
                     •   Chemical Weapons: Stockpile Destruction Cost Growth and Schedule
                         Slippages Are Likely to Continue (GAO/NSIAD-92-18, Nov. 20, 1991). We
                         reported that continued problems in the chemical stockpile program
                         indicated that increased costs and additional time to destroy the chemical
                         stockpile should be expected. We recommended that the Army determine
                         whether faster and less costly technologies were available to destroy the
                         chemical stockpile.

                         Our objectives, scope, and methodology are described in appendix I.




                         Page 24                            GAO/NSIAD-97-18 Chemical Weapons and Materiel
Chapter 2

The Chemical Stockpile Disposal Program
Will Require More Time and Funds Than
Currently Planned
                      In 1985, the Congress directed the Army to destroy the U.S. stockpile of
                      chemical agents and munitions. To comply with congressional direction,
                      the Army established the Chemical Stockpile Disposal Program and
                      developed a plan to incinerate the agents and munitions on site in
                      specially designed facilities. The Army has spent $2.6 billion and estimates
                      that the stockpile program could cost another $9.8 billion and take until
                      December 2004 to complete. However, the program will likely cost more
                      than estimated and continue past the estimated completion date. This is
                      because reaching agreement on site specific disposal methods has
                      consistently taken longer than the Army anticipated. Furthermore, recent
                      congressional direction in the 1997 Authorization and Appropriations Acts
                      to research and develop alternative technologies to destroy assembled
                      chemical munitions indicates that there is continued public concerns
                      about the incineration disposal method. Recognizing the difficulty of
                      satisfactorily resolving the public concerns associated with each
                      individual disposal location, suggestions have been made to change the
                      program’s basic approach to destruction. These have included developing
                      an acceptable alternative disposal technology to incineration and
                      consolidating disposal operations at a national or regional sites. Although
                      many suggestions offer some benefit, no one change is likely to materially
                      reduce costs, shorten the disposal schedule, and increase public
                      acceptance. They also generate other obstacles and issues that need to be
                      resolved to make them viable.


                      In the DOD Authorization Act for Fiscal Year 1986 (P.L. 99-145), the
The Army’s Chemical   Congress mandated that the Army destroy the U.S. stockpile of obsolete
Stockpile Disposal    chemical agents and munitions, which are stored at eight sites in the
Program               continental United States and on Johnston Atoll in the Pacific Ocean. (See
                      fig. 2.1.) As of December 15, 1995, the stockpile consisted of 3.3 million
                      items.1 The objectives of the Chemical Stockpile Disposal Program are to
                      (1) destroy the stockpile of unitary chemical weapons and (2) provide for
                      the maximum protection of the environment, the public, and personnel
                      involved in the storage, handling, and disposal of the stockpile.




                      1
                       The chemical weapons stockpile information was declassified on January 9, 1996.



                      Page 25                                      GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                                         Chapter 2
                                                         The Chemical Stockpile Disposal Program
                                                         Will Require More Time and Funds Than
                                                         Currently Planned




Figure 2.1: The U.S. Stockpile of Chemical Agents and Munitions

   Umatilla Depot Activity,
           Oregon

   Number of items: 220,599
     Tons of agent: 3,717

                                                                                                   Newport Chemical Activity,
                                                                                                            Indiana

                                                                                                     Number of items: 1,690
                                                                                                       Tons of agent: 1,269




                                                                                                                                Aberdeen Proving Ground,
                                                                                                                                       Maryland

                                                                                                                                  Number of items: 1,818
                                                                                                                                    Tons of agent: 1,625


                                                                                                                                Blue Grass Army Depot,
                                                                                                                                       Kentucky
   Tooele Army Depot,
          Utah                                                                                                                   Number of items: 101,764
                                                                                                                                   Tons of agent: 523
Number of items: 1,138,488
  Tons of agent: 13,616                                                                                                 Anniston Army Depot,
                               Pueblo Depot Activity,                                                                         Alabama
                                     Colorado
                                                                                                                       Number of items: 661,529
                              Number of items: 780,078                                                                   Tons of agent: 2,254
                                Tons of agent: 2,611
     Hawaii                                                                          Pine Bluff Arsenal,
                                                                                         Arkansas

                                                                                   Number of items: 123,093
                                                                                     Tons of agent: 3,850
                  Johnston Atoll,
                   Pacific Ocean

              Number of items: 292,121
                Tons of agent: 1,134



                                                         Note: As of December 15, 1995.

                                                         Source: DOD.




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                                           Chapter 2
                                           The Chemical Stockpile Disposal Program
                                           Will Require More Time and Funds Than
                                           Currently Planned




                                           There are several key dates that congressional and defense
                                           decisionmakers will consider as they determine future funding and
                                           program direction for the stockpile program. (See fig. 2.2.) For example,
                                           the National Defense Authorization Act for Fiscal Year 1993
                                           (P.L. 102-484) directed the Army to destroy the stockpile by December 31,
                                           2004. If the United States ratifies the Chemical Weapons Convention, the
                                           United States will agree to dispose of its unitary chemical weapons
                                           stockpile by April 29, 2007, and the convention’s signatories may grant a
                                           one-time extension of up to 5 years. In addition, on the basis of its
                                           stockpile assessment and monitoring activities, the Army estimates that
                                           the stockpile will be reasonably stable through 2013. However, according
                                           to Army officials, most of the risk to chemical munitions in storage result
                                           from external events such as earthquakes, airplane crashes, lightning
                                           strikes, and tornadoes.


Figure 2.2: Key Dates for the Chemical Stockpile Disposal Program After January 2004



                                                                            Chemical Weapons
                                                                          Convention completion
      Legislative                                                       date with a 5-year extension
    completion date




   December 31, 2004             April 29, 2007                                  April 29, 2012               2013




                              Chemical Weapons                                                          Estimated safe
                                 Convention                                                              storage date
                               completion date


                                           Source: Based on data provided by the Army’s Program Manager for Chemical Demilitarization.




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                      Will Require More Time and Funds Than
                      Currently Planned




                      The Army has taken encouraging steps, some in response to our
                      recommendations, to improve its management and oversight of the
                      Chemical Stockpile Disposal Program. In December 1994, DOD designated
                      the Army’s chemical demilitarization program, consisting of both stockpile
                      and nonstockpile munitions and materiel, as a major defense acquisition
                      program. The objectives of the designation were to stabilize the disposal
                      schedules, control costs, and provide more discipline and higher levels of
                      program oversight. In addition, in response to the National Research
                      Council’s and our recommendations, the Army initiated the Enhanced
                      Stockpile Surveillance Program in 1995 to improve its monitoring and
                      inspection of chemical munitions.

                      The Army has also expanded its public outreach activities to promote
                      dialogue between the Army and the public. For example, the Army has
                      established storefront information offices near some of the storage sites,
                      developed public outreach pamphlets and information videos, distributed
                      information to public libraries and locations, provided toll-free telephone
                      numbers, and conducted town meetings. However, the National Research
                      Council recently recommended that the Army increase substantially and
                      institutionalize public involvement throughout the Chemical Stockpile
                      Disposal Program.2 The Council reported that the credibility of the Army
                      was low and that the treatment of public concerns had been inadequate. It
                      concluded that the Army’s public relations and outreach efforts to educate
                      the public about chemical stockpile activities by themselves will not be
                      enough to facilitate the safe and timely disposal of the stockpile. The
                      Council recommended that the Army expand its public affairs program to
                      ensure public involvement in the program, giving the affected
                      communities a participatory role and a sense of ownership in the
                      program’s decision-making process. According to the National Research
                      Council, the Army has successfully involved the state and the public in its
                      alternative technology project for the two bulk-only stockpile sites,
                      demonstrating the importance of public involvement to the progress of the
                      program.


                      Although the Army is committed to destroying the stockpile by the
Program Delays Past   legislatively imposed deadline of December 31, 2004, its ability to meet
2004 Are Likely       that date is questionable. The program cost and schedule are largely
                      driven by the degree to which states and local communities are in
                      agreement with the proposed disposal method. Historically, reaching

                      2
                        Public Involvement and the Army Chemical Stockpile Disposal Program, National Research Council
                      (Oct. 25, 1996).



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                            Chapter 2
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                            Will Require More Time and Funds Than
                            Currently Planned




                            agreement has consistently taken longer than the Army anticipated. Since
                            the Army began planning the destruction of the chemical weapon
                            stockpile in 1985, it has destroyed 4 percent of the stockpile, built and
                            operated two of nine proposed facilities, and the program has been
                            extended more than 10 years—from September 1994 to December 2004.
                            The Army plans to phase in the construction, systemization, and operation
                            of the remaining seven disposal facilities over the next 8 years. However,
                            environmental permits for the remaining facilities have already slipped by
                            3 years or more since April 1992. At the Tooele Chemical Agent Disposal
                            Facility, obtaining Utah’s approval to operate the facility took 17 months
                            longer than the Army estimated it would in 1992.


Obtaining Environmental     Before constructing or operating a chemical weapon destruction facility,
Permits Will Require More   the Army must obtain permits to comply with federal, state, and local
Time Than the Army Has      environmental laws and regulations. The Resource Conservation and
                            Recovery Act, as amended, regulates the storage, treatment, and disposal
Allowed                     of most chemical weapons and materiel. (Environmental laws are
                            summarized in app. III.) The Resource Conservation and Recovery Act
                            controls hazardous waste through a permit process that requires
                            government approval for individuals who generate, transport, store, or
                            dispose of hazardous waste. Under the act, the Environmental Protection
                            Agency may authorize individual states to administer and enforce
                            hazardous waste programs that are as least as stringent as the federal
                            program. The act also allows states to establish requirements more
                            stringent than federal standards. The Clean Air Act, as amended, governs
                            potential sources of air pollutants and establishes emission standards. The
                            Army must obtain permits for air pollution control prior to operating a
                            chemical stockpile disposal facility.

                            According to the Army’s 1994 risk assessment, there was a high possibility
                            states would use their authority under these laws to delay or prevent the
                            construction of incinerators in their states.3 For example, states can place
                            restrictions on hazardous waste generators as well as the disposal of the
                            hazardous waste generated by the chemical agent incinerators, or prohibit
                            disposal of the waste within their jurisdictions. States may also simply
                            delay the permit review process for an inordinate amount of time. These
                            actions could increase the Army’s costs, cause it significant administrative
                            difficulties, or delay operations. To illustrate, before it will issue a permit
                            for a chemical stockpile disposal facility, Kentucky requires that

                            3
                              Programmatic Risk Assessment Final Report, U.S. Chemical Materiel Destruction Agency (Sept. 30,
                            1994).



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Chapter 2
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Will Require More Time and Funds Than
Currently Planned




information showing that no alternative disposal method, including, but
not limited to, neutralization and transportation, exists or could be
developed. Maryland and Indiana have also passed laws or adopted
regulations specific to the disposal of chemical agents within their
jurisdictions.

Although the Army’s 1994 risk assessment acknowledges the potential for
delays due to environmental regulations, its program schedule provides
little leeway for dealing with potential problems at the remaining stockpile
sites. For example, the Army’s 1996 schedule only allows for slippage
ranging from 1 to 6 months for delays in the permitting process,
construction, systemization, and operation of the proposed facilities at
Anniston, Pine Bluff, and Umatilla.4 The schedule for the Anniston
Chemical Agent Disposal Facility shows that to destroy all of the chemical
munitions at Anniston by the end of December 2004, Alabama would have
to issue its permit to start construction no later than October 1996. Army
officials now estimate that the permit will be issued by March 31, 1997,
approximately 6 months later than scheduled. (See table 2.1.) Alabama
regulatory officials expect the permit to be issued in June or July 1997—a
slippage of approximately 8 months. Unless the Army can shorten
construction, systemization, or destruction time frames, disposal
operations at Anniston would extent to mid-2005.




4
 Department of Defense’s Interim Status Assessment for the Chemical Demilitarization Program, DOD
(Apr. 15, 1996).



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                                    The Chemical Stockpile Disposal Program
                                    Will Require More Time and Funds Than
                                    Currently Planned




Table 2.1: Slippage in the Army’s
Estimated Dates for Construction                                         Estimated date of permit to start construction
Permits at the Remaining Seven                                  February 1996              August 1996
Disposal Sites                      Site                        schedulea                  scheduleb                  Slippage
                                    Aberdeen Proving            Before January 1,          November 12, 1998          None
                                    Groundc                     1999
                                    Anniston Army Depot         Before October 1,          March 31, 1997             6 months
                                                                1996
                                    Blue Grass Army             Before January 1,          September 20, 1998         None
                                    Depotd                      1998
                                    Newport Chemical            Before January 1,          August 18, 1999            None
                                    Activityc                   2000
                                    Pine Bluff Arsenal          Before October 1,          June 24, 1997              9 months
                                                                1996
                                    Pueblo Depot Activityd      Before April 1, 1997       February 4, 1998           10 months
                                    Umatilla Depot Activity     Before October 1,          January 30, 1997           4 months
                                                                1996
                                    a
                                      Based on DOD’s interim status assessment for the chemical demilitarization program dated
                                    April 15, 1996.
                                    b
                                     Based on data provided by the Program Manager for Chemical Demilitarization dated
                                    September 27, 1996.
                                    c
                                      Schedules are subject to change pending alternative technology decision for the bulk-only
                                    stockpile sites.
                                    d
                                     Schedules are on hold as the result of the 1997 DOD Appropriations Act requirement to research
                                    alternative technologies.



                                    The February 1996 schedule for the Pine Bluff Chemical Agent Disposal
                                    Facility shows construction starting by the end of fiscal year 1996 and
                                    provides a 6-month leeway to complete disposal operations by the end of
                                    2004. Based on the Army’s current schedule for the environmental permits,
                                    the start of construction in 1996 is no longer possible because the
                                    schedule shows an issuance date of June 24, 1997—a slippage of 9 months.
                                    This delay eliminated the 6-month leeway and operations now are likely to
                                    continue past December 2004. The disposal schedule for the Umatilla
                                    Chemical Agent Disposal Facility provides a leeway of 4 months. The
                                    Army had expected Oregon to issue the Resource Conservation and
                                    Recovery Act and Clean Air Act permits for the facility by the end of
                                    September 1996. However, Army officials had estimated that the permits
                                    would have been issued by January 30, 1997, approximately 4 months later
                                    than scheduled. This delay eliminated the grace period for starting
                                    disposal operations at Umatilla.




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                          According to Army officials, implementation of the health risk assessment
                          requirement has added another layer of uncertainty to the schedule. They
                          said that the original scope of the health risk assessment to operate the
                          disposal facilities was not completely defined, the health assessment
                          requirements have changed, and the requirements currently vary from
                          state to state. According to DOD officials, states have modified the
                          requirements of their health risk assessments well into the process,
                          delaying the development of the final assessment document. According to
                          Environmental Protection Agency officials, the agency has issued several
                          guidance documents concerning the health risk assessments over the last
                          5 years and has tried to keep the Army informed of the changes and
                          updates in the guidance. In addition, the agency has advised the Army to
                          meet with state officials early in the process to agree on the methodology
                          and standards to use in the development of the risk assessment.


Public Support for More   Congressional direction in the 1997 Authorization and Appropriations Acts
Research on Alternative   to research and develop alternative technologies to destroy assembled
Disposal Technologies     chemical munitions indicates that there is continued public concerns
                          about the proposed disposal method. In the 1997 Authorization Act, the
                          Congress directed DOD to conduct an assessment of alternative
                          technologies for the disposal of assembled chemical munitions. The act
                          also directed the Secretary of Defense to report on the assessment by
                          December 31, 1997. Similarly, the 1997 Appropriations Act provided
                          $40 million to conduct a pilot program to identify and demonstrate two or
                          more alternatives to the baseline incineration process for the disposal of
                          assembled chemical munitions. The act also prohibits DOD from obligating
                          any funds for constructing disposal facilities at Blue Grass, Kentucky, and
                          Pueblo, Colorado, until 180 days after the Secretary reports on the
                          alternatives.

                          According to Army officials, the construction and the procurement of
                          equipment for the disposal facilities at Blue Grass and Pueblo has been
                          placed on hold because of the 1997 Appropriations Act’s requirement to
                          research alternative technologies. If the report is not issued before
                          December 31, 1997, the Army cannot obligate construction funds for Blue
                          Grass and Pueblo until June 30, 1998. This would delay the planned award
                          of the construction contract at Blue Grass by 6 months and the planned
                          award of the construction contract at Pueblo by 15 months. According to
                          these officials, the Army and the states will continue to work together to
                          process the environmental permits. However, a recent Army schedule
                          shows Blue Grass disposal operations ending in June 2005, 6 months past



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                       the mandated completion date. Although the prohibition applies only to
                       Blue Grass and Pueblo, public concerns about incineration may prompt
                       state regulators at other locations to delay their final decisions to permit
                       incinerators until the Secretary reports his findings.


                       The Army has spent $2.6 billion and estimates that the stockpile program
Program Costs Will     could cost another $9.8 billion to complete. Since 1985, the Army’s cost
Likely Exceed          estimate for the Chemical Stockpile Disposal Program has increased
$12.4 Billion          seven-fold, from an initial estimate of $1.7 billion to $12.4 billion.5 Reasons
                       for the cost increases include (1) program enhancements to respond to
                       concerns for maximizing the safety of the public and environment,
                       (2) delays in completing the operational verification tests at the Johnston
                       Atoll Chemical Agent Disposal System, (3) technical problems resulting in
                       lower than expected disposal rates, (4) additional legislative requirements,
                       and (5) implementation of the National Research Council’s
                       recommendations.

                       The Chemical Stockpile Disposal Program will likely cost more than the
                       estimated $9.8 billion above current expenditures to complete because of
                       the schedule slippages since February 1996 and the additional costs to
                       research alternative disposal technologies. Schedule delays, such as those
                       previously discussed at Anniston, Blue Grass, Pine Bluff, Pueblo, and
                       Umatilla, will increase program cost at these locations. These delays
                       increase direct costs, including personnel, storage, emergency
                       preparedness, and program management at each disposal site. In addition,
                       the Congress appropriated the Army $40 million in fiscal year 1997 to
                       conduct a pilot program to identify and demonstrate two or more
                       alternatives to the baseline incineration process for the disposal of
                       assembled chemical munitions. This appropriation was not included in the
                       Army’s cost estimate.


                       On the basis of its stockpile assessment and monitoring programs, the
The Stockpile Should   Army estimates that the stockpile will be reasonably stable through 2013.
Be Stable Through      Although continued storage of the M55 rockets is a concern, the Army will
2013                   continue to monitor the stockpile until it is destroyed and has developed a
                       contingency plan to deal with the M55 rockets, which pose a risk.
                       According to Army officials, most of the risk to chemical munitions in



                       5
                       Approximately $1 billion of the estimated $12.4 billion is associated with the Chemical Stockpile
                       Emergency Preparedness Program.



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                       storage result from external events such as earthquakes, airplane crashes,
                       lightning strikes, and tornadoes.

                       In December 1994, we reported that the Army’s assessment that the
                       chemical stockpile could be safely stored until the legislatively imposed
                       deadline of December 31, 2004, was subject to question based on the
                       nature of the supporting information.6 The data on which the Army based
                       its assessment were old and may no longer represent the chemical
                       weapons in storage. For example, at that time, field samples of the M55
                       rocket propellant had not been taken since 1989. Also, the assessment did
                       not include an analysis of leaking munitions. Leaks increase the risk of
                       auto-ignition during handling, which could lead to fires and potential
                       explosions in the stockpile storage area. In addition, a contingency plan
                       for disposal of the rockets was needed because they cannot readily be
                       reconfigured to remove their propellant. Propellant is inherently unstable
                       and must be stabilized to help prevent reactions that could lead to a
                       spontaneous ignition. Manufacturers added stabilizing compounds, but
                       they deteriorate over time.

                       Recent Army initiatives to obtain better information to predict the safe
                       storage life of the stockpile, including the M55 rockets, are encouraging.
                       For example, the Army initiated an Enhanced Stockpile Assessment
                       Program to determine the effects of an agent on a propellant, identify the
                       most appropriate predictive methodology, develop sampling plans, and
                       perform periodic assessments. In 1995, the Army completed a
                       reassessment of the stability of the M55 rockets and concluded that the
                       likelihood of propellent ignition through 2013 was negligible. However,
                       data were obtained from leaker rockets on Johnston Atoll that were
                       consistent with the theory that exposure to agent accelerates the
                       degradation of the propellent stabilizer. Gaining a better understanding of
                       this chemical process and its impact on the rockets’ stability will be a
                       major thrust of the Army’s stockpile assessment activities in 1997.


                       The concern about incineration and the cost and progress of the disposal
Program Alternatives   programs have led to suggestions for alternative technologies, the
Generate Trade-offs    transportation of agents and munitions to a national or regional site, and
                       other measures to improve efficiency and effectiveness. Two widely
                       discussed suggestions are (1) changing the planned disposal technology to
                       something other than incineration or (2) transporting the weapons to a
                       regional or national site rather than building local disposal sites. Although

                       6
                        Chemical Weapons: Stability of the U.S. Stockpile (GAO/NSIAD-95-67, Dec. 22, 1994).



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                           changing the technology could improve public acceptance and using
                           national and regional sites could save money, these changes raise other
                           issues that present trade-offs for decisionmakers. Thus far, these
                           trade-offs have not been acceptable to one or more of the parties involved
                           in the program. In addition, the Army is developing other measures to
                           improve program effectiveness and efficiency.


Alternative Technologies   Since 1994, the Army has been researching five technological alternatives
May Not Reduce Costs or    for destroying chemical agents stored in bulk containers. The results are
Shorten Disposal           promising but, according to the Army, the alternative technologies are not
                           likely to significantly affect the program’s overall cost or duration.
Operations                 Additionally, any alternative, including neutralization, will have its own set
                           of problems such as hazardous waste disposal and the possibility of leaks
                           or accidents.

                           In August 1994, the Army initiated a research and development project to
                           investigate, develop, and support testing of two technologies based on
                           chemical neutralization of chemical agents at the bulk-only stockpile
                           sites—Aberdeen Proving Ground, Maryland, and Newport Chemical
                           Activity, Indiana. A neutralization process involves altering the chemical,
                           physical, and toxicological properties of a chemical warfare agent to
                           render it ineffective for use. In addition, three other technologies—molten
                           metal pyrolysis, high-temperature hydrogenation, and electrochemical
                           oxidation—have been tested and are undergoing further development by
                           the commercial firms promoting them. DOD will decide in 1997 whether to
                           construct pilot facilities to further demonstrate the alternative
                           technologies. The Army also will continue laboratory and bench-scale
                           testing of disposal technologies in support of the program. This research
                           and development effort is conducted in conjunction with activities to
                           implement the baseline incineration program.


Transportation Could       Concerns about the cost and progress of the Chemical Stockpile Disposal
Reduce Costs, but There    Program have generated interest about moving chemical stockpile
Are Some Trade-offs        weapons to a national or regional site to improve the program’s
                           effectiveness and efficiency. However, the Army is prohibited from
                           transporting stockpile weapons to any of the eight storage sites in the
                           continental United States by a general provision in DOD’s annual
                           appropriations act. This provision prohibits the Army from using funds to
                           prepare studies on the feasibility of transporting chemical weapons.
                           Transportation options offer some cost benefits, but they also increase the



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risk to the general public and are likely to be opposed by most affected
states and communities.

Although transporting chemical weapons has the potential to reduce
construction and procurement costs by as much as $2.6 billion, the
reduction could be offset by shipping and emergency preparedness costs.
The potential savings come from reducing the number of disposal facilities
that must be built. According to the Army estimates, construction and
procurement of a disposal facility and related equipment cost from
$243 million for a small facility that will handle only bulk agent such as
Newport, to $471 million for a large facility that will process all types of
explosively configured munitions such as Umatilla. The reduction in costs
is offset by increased storage, emergency preparedness, and program
management costs from extending disposal operations at the consolidated
sites. Using existing disposal rates, a national destruction facility at Tooele
could extend the program to 2017 and add as much as 770 months of
storage, emergency preparedness, and management costs to the program.
Similarly, regional disposal sites at Anniston and Tooele could extend the
program to 2010 and add as much as 320 months of storage, emergency
preparedness, and management costs.

In addition, potential savings would be offset by large transportation costs.
In 1987, an Army transportation panel recommended that, prior to
transporting any agent or munitions, the Army develop a shipping
container that (1) provides redundant protection against agent release
during normal transport, (2) prevents agent release in most transportation
accidents, (3) is compatible with standard cargo handling and transport
equipment, and (4) has the capability for automated agent and
temperature monitoring within the transport container. In 1987, the
Program Manager for Chemical Demilitarization estimated that 400
containers would cost $96.4 million.7 An Army official who developed the
on-site transportation containers estimated that the containers would cost
significantly more and could cost as much as $2 million for each container.
In addition, the Army’s transportation concept plan found that using the
rail system would require 70 to 75 rail shipments to a national disposal
site, each consisting of a convoy of 136 railcars. Shipping by truck to a
national disposal site would require 820 convoys, and airlifting would
require several thousand sorties using C-141 aircraft. According to an
Army study, transporting the Blue Grass stockpile would take 1,200 to
1,500 flights. Further, airfields capable of handling large aircraft would

7
Conceptual Design of a Chemical Munitions Transport Packaging System, Program Manager for
Chemical Demilitarization (Aug. 1987).



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have to be constructed. Costs for these transportation alternatives have
not been estimated. However, we reported that moving more than 100,000
U.S. chemical-filled munitions from West Germany to Johnston Atoll in
1990 cost $61.6 million, including $13.6 million for shipping containers.8
The Army shipped the munitions in sealed steel boxes called secondary
steel containers, which were loaded into shipping containers.

Another significant cost element could be emergency preparedness along
the transportation corridor. Proposed rail routes to a national destruction
center total approximately 13,000 miles and pass through 20 states. Rail
routes to regional destruction sites total approximately 7,100 miles and
pass through 16 states. In its response to the Army’s 1987 Final
Programmatic Environmental Impact Statement, the Department of Health
and Human Services stated that the difficulties in preparing adequate
contingency plans for a transportation alternative are staggering and that
resources to cope with a worst case scenario in a consistent manner could
never be mobilized. The Department reported that while it might be
possible to provide hospitals near the eight existing storage sites with
enough respirator equipment to support a number of casualties, it would
be difficult to supply all communities along a transportation route. Few
communities along the transportation routes would have the necessary
equipment available to them without federal assistance.

Any movement of chemical weapons or material could be opposed by
federal agencies and the affected states and localities. Before the Army
can transport a chemical weapon, it must (1) coordinate efforts with the
Department of Health and Human Services and must adopt any
precautionary measures that it recommends, (2) meet all regulations
imposed by the Department of Transportation, and (3) obtain permits from
the receiving state and potentially from each state traveled through.
Although the departments of Health and Human Services or
Transportation have not formally opposed transportation, both have
expressed strong reservations about transportation alternatives. In 1988,
13 states provided written comments on the Army’s Final Programmatic
Environmental Impact Statement. Twelve of the states opposed
transporting the chemical weapons, including 7 of the 8 states where
chemical weapons are stored, and endorsed an on-site disposal option.
Only Kentucky wanted the Army to transport its agents and munitions
elsewhere. Utah has gone on record opposing receipt of chemical weapons
from other states.


8
 Chemical Warfare: DOD’s Effort to Remove U.S. Chemical Weapons From Germany
(GAO/NSIAD-91-105, Feb. 13, 1991).



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The Army’s Cost-Reduction          Environmental permitting is the most likely area to affect the disposal
Initiatives                        schedule for the stockpile program. According to its 1994 risk assessment,
                                   the Army concluded that high-level involvement, possibly from the
                                   Congress or the White House, was needed in the environmental permitting
                                   process to overcome opposition from state regulators. In 1996, DOD
                                   assembled an environmental management team comprised of federal and
                                   state officials to track new and revised environmental requirements to
                                   maintain the current disposal schedule and ensure compliance. In
                                   addition, the Army is reviewing whether the number of trial burns and
                                   time necessary to gain state approval to initiate disposal operations can be
                                   reduced.

                                   The Army is also reviewing the stockpile program’s contracting structure,
                                   disposal operations, and incineration process to identify potential
                                   cost-reduction initiatives. As a result, Army officials have already
                                   identified some cost-reduction initiatives, which are in various stages of
                                   assessment, that could potentially reduce program costs by $673 million.
                                   (See table 2.2.) They also plan to identify additional cost reductions as the
                                   program progresses.

Table 2.2: The Army’s Initial
Cost-Reduction Initiatives as of   Dollars in millions
August 1996                                                                                                                Estimated
                                   Category                                                    Confidencea                   savings
                                   Reduction in consumables                                    High                             $50
                                   Engineering improvements in the pollution                   High                              55
                                   abatement filter system
                                   Removal of the pollution abatement filter                   High                              95
                                   system at Tooele
                                   Removal of the pollution abatement filter                   Medium to high                    85
                                   system at Aberdeen and Newport
                                   Elimination of the dunnage furnaces                         Medium                            10
                                   Elimination of the pollution abatement filter               Low to medium                    145
                                   system at Anniston and Umatilla
                                   Improved disposal rates for projectiles                     Medium                           160
                                   Elimination of the pollution abatement filter               Low to medium                     73
                                   system at Pine Bluff
                                   Total                                                                                       $673
                                   a
                                       Indicates the Army’s level of confidence that the initiative will be implemented.



                                   The Army cannot implement some of the more significant cost-reduction
                                   initiatives without the cooperation and approval of state regulatory



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agencies. Regulatory requirements connect the initiatives to the National
Environmental Policy Act process and the Resource Conservation and
Recovery Act and Clean Air Act permitting processes. The Army plans to
submit its assessment of the initiatives to the Congress with its fiscal
year 1998 budget request.




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Affected by Issues Similar to Those in the
Stockpile Program
                       Recognizing that the stockpile disposal program did not include all
                       chemical warfare materiel that requires destruction, the Congress directed
                       the Army to plan for the disposal of nonstockpile chemical warfare
                       materiel. The Army has spent $105.9 million and estimates that the
                       nonstockpile program could cost another $15.1 billion and take nearly
                       40 years to complete. However, given the factors driving the nonstockpile
                       program, it is uncertain how long the program will take or cost. For
                       example, the program is driven by uncertainties surrounding buried
                       chemical warfare materiel, environmental requirements, and disposal
                       methods. The Army has limited and often imprecise information about the
                       nature and extent of buried chemical materiel, which accounts for
                       $14.5 billion (95 percent) of the program cost. Environmental issues
                       similar to those experienced in the stockpile program are also likely to
                       affect the Army’s ability to obtain the environmental approvals and
                       permits that virtually all nonstockpile activities require. In addition, the
                       Army’s disposal concept is not yet fully developed and the Army has not
                       proven that its proposed process can safely and effectively destroy all
                       nonstockpile materiel and will be accepted by the affected states and
                       localities. The nonstockpile program offers some savings opportunities;
                       however, these opportunities create obstacles and issues that would have
                       to be resolved.


                       Although the Army has made some progress in defining the scope of the
The Army Is Far From   program and removing nonstockpile materiel from some locations, more
Accomplishing Its      work is required. The Army’s objectives for the nonstockpile program are
Objectives             to (1) develop and implement disposal schedules and cost estimates;
                       (2) determine the magnitude of the nonstockpile chemical problem in
                       terms of locations, qualities, and types of agents and materiel; and
                       (3) develop implement transportation and disposal procedures. The Army
                       plans to continue to refine the cost and schedule estimates as the program
                       matures, collect information on the magnitude of nonstockpile materiel,
                       research disposal technologies, and develop disposal plans.

                       The Army has spent $105.9 million and estimates that it will cost another
                       $15.1 billion to dispose of its nonstockpile materiel. The Army’s cost
                       estimate is considered a “rough order of magnitude” estimate, typically
                       used when a program is not fully developed. According to the Army, it will
                       issue a revised cost estimate in 1997. To date, nonstockpile materiel has
                       been disposed of on a limited basis, such as the emergency disposal of
                       dangerous items. (See table 3.1.)




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Table 3.1: Summary of Nonstockpile
Program Activities                   Category                  Activity
                                     Binary chemical           Some of the key chemical components have been destroyed
                                     weapons                   and advance planning has been completed.
                                     Miscellaneous             The Army’s BZ agent, an incapacitating agent, and bomb
                                     chemical warfare          bursters have been destroyed.
                                     materiel
                                                               Empty ton containers at Rocky Mountain Arsenal, Colorado,
                                                               have been shipped to Rock Island Arsenal, Illinois, for smelting.
                                     Recovered chemical        Using isotopic neutron spectroscopy and enhanced X-ray
                                     warfare materiel          systems, the Army has evaluated and inventoried recovered
                                                               chemical materiel.

                                                               The Army discovered that some previously classified recovered
                                                               chemical materiel did not contain chemical agents and
                                                               transferred them to the appropriate agency for use or disposal.

                                                               Some recovered chemical weapons considered dangerous
                                                               were destroyed.
                                     Former chemical           A contract was awarded in 1994 to assess requirements,
                                     weapons production        develop technical alternatives, and prepare a statement of work
                                     facilities                for the disposal of the former production facility in Indiana.

                                                               Rocky Mountain Arsenal facilities are in the process of
                                                               remediation. Lessons learned from this effort form the basis for
                                                               the disposal method and cost estimate for the remaining three
                                                               sites.
                                     Buried chemical           On the basis of documentation surveys, site visits, and
                                     warfare materiel          interviews, the Army has developed a database on potential
                                                               burial sites.

                                                               In June 1995, the Army contracted for the recovery,
                                                               transportation, storage, and disposal of chemical materiel
                                                               discovered at small burial sites.

                                                               The Army has completed remediation of the Spring Valley site,
                                                               Washington, D.C.; Forts Richardson and Wainwright, Alaska;
                                                               Jackson, Mississippi; and Defense Distribution Depot, Ogden,
                                                               Utah.

                                                               Remediation activities at small burial sites at the former Raritan
                                                               Arsenal, New Jersey, and former Fort Segarra, U.S. Virgin
                                                               Islands, are in process.

                                                               The Army has initiated remediation actions at large burial sites
                                                               at Aberdeen Proving Ground and Rocky Mountain Arsenal.




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                          Although the Army has good information about most nonstockpile
Recovery and              materiel, it has limited and often imprecise information about the nature
Disposal of Buried        and extent of buried items. The Army estimates that it can dispose of
Chemical Warfare          binary weapons, recovered chemical weapons, former production
                          facilities, and miscellaneous chemical warfare materiel by the time frames
Materiel Will Be          established by the Chemical Weapons Convention. Under the terms of the
Problematic               convention, chemical warfare materiel buried before 1977 is exempt from
                          disposal as long as it remains buried. The Army is still exploring potential
                          sites and has little and often imprecise information about the type and
                          amount of materiel buried. This lack of data can critically affect the
                          successful implementation of the program, because recovering and
                          disposing of buried materiel accounts for 95 percent of the program cost.


Buried Chemical Warfare   The Army estimates that the disposal of buried chemical materiel will cost
Materiel Accounts for     $14.5 billion and be completed in 2033. Burial was a common disposal
95 Percent of Program     method for chemical warfare materiel until the late 1950s and considered
                          to be the final disposal act. As a result, little record-keeping was done for
Cost                      burial activities and additional chemical burial sites are likely to be
                          discovered. Based on its preliminary analyses, the Army has identified
                          potential buried chemical warfare materiel at 64 locations in 31 states and
                          the U.S. Virgin Islands that may require further investigation or
                          remediation actions. (See fig. 3.1.) Of these locations, 40 are active military
                          installations and 24 are located on formerly used defense sites, which DOD
                          no longer controls. Some locations have multiple sites and include one or
                          more burial pits, weapon ranges, or chemical test sites.




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Figure 3.1: Potential Locations With Buried Chemical Warfare Materiel




                                                                                                     Virgin Islands -six potential locations.



        Locations with potential buried chemical warfare materiel that may require remediation


                                              Source: Based on 1996 data provided by the Army’s Project Manager for Nonstockpile Chemical
                                              Materiel.




                                              Even at well-documented sites, the actual amount, chemical agent,
                                              condition, and type of buried materiel will remain relatively unknown
                                              prior to excavation and visual identification. For example, in 1995 a
                                              chlorine-filled projectile was discovered at Fort Lewis, Washington, and
                                              more than 260 vials of chemical agent were found buried under the
                                              Mississippi State Fairgrounds in Jackson. The Army moved the vials to
                                              Pine Bluff Arsenal, where they remain in storage waiting disposal.

                                              In some locations, chemical materiel was expected to be found but was
                                              not. For example, a 3-day excavation in 1995 at Fort Wainwright, Alaska,



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                                 uncovered no buried chemical materiel, despite evidence of a burial in the
                                 area. The Army’s 1993 Survey and Analysis Report indicated that up to
                                 30 cylinders of mustard agent may have been buried in the area.1
                                 Subsequent ground-penetrating radar also indicated the potential for
                                 buried materiel. Upon excavation, the Army discovered the objects
                                 detected by the radar were pockets of groundwater sitting on bedrock.
                                 The water created an electrical condition that produced the unexplained
                                 reading.


Other Nonstockpile               Over the years, the Army has located and inventoried nonstockpile
Materiel Has Been Easier         materiel that has not been buried. Nevertheless, this materiel, which may
to Locate, but Still Difficult   include energetics and partially deteriorated weapons, will still be difficult
                                 to destroy.2
to Destroy

Binary Chemical Weapons          The locations and quantities of binary chemical weapons are
                                 well-documented. Binary chemical weapons are formed from two
                                 nonlethal elements (called precursors) through a chemical reaction after
                                 the munitions are fired. Binary weapons were manufactured, stored, and
                                 transported with only one of the chemical elements in the weapon. The
                                 second element was to be loaded into the weapon only at the battlefield.
                                 As of October 1996, the precursors for the binary chemical weapons are
                                 stored at Aberdeen, Pine Bluff, Tooele, and Umatilla.

Miscellaneous Chemical           The Army has documented the location, configuration, quantity, and type
Warfare Materiel                 of miscellaneous chemical warfare materiel to be destroyed. The materiel
                                 was designed for use in the employment of chemical weapons and
                                 includes unfilled munitions and components, simulant-filled munitions,
                                 dummy rounds, rocket motors, cartridge containers, and other metal and
                                 plastic parts. Some items contain explosive charges that may need to be
                                 extracted before disposal. According to the Army, miscellaneous materiel
                                 is stored at Aberdeen, Anniston, Blue Grass, Pine Bluff, Pueblo, Tooele,
                                 Umatilla, and Dugway Proving Ground.

Recovered Chemical Weapons       Chemical weapons have been recovered from range-clearing operations,
                                 chemical burial sites, and research and development test areas. According
                                 to the Army, most recovered items are stored at Aberdeen, Dugway,
                                 Johnston Atoll, Pine Bluff, Tooele, and Rocky Mountain Arsenal. The Army

                                 1
                                   Non-Stockpile Chemical Materiel Program Survey and Analysis Report, Program Manager for
                                 Nonstockpile Chemical Materiel (Nov. 1993).
                                 2
                                  Energetics are the explosives and propellants in the munitions.



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                         believes that handling and disposing of recovered chemical weapons will
                         be difficult because they are more likely to have deteriorated than other
                         nonstockpile materiel and the identity of the agent is unknown in some of
                         the items.

                         According to the Army, the most immediate concern of the nonstockpile
                         program is the treatment and disposal of Chemical Agent Identification
                         Sets because of the relative frequency of their recovery and tendency to be
                         found by the general public. The sets consist of chemicals contained in
                         glass ampoules, vials, and bottles that are packed in metal shipping
                         containers and wooden boxes.3 In the late 1930s, approximately 110,000 of
                         the sets were produced in various configurations to train soldiers and
                         sailors how to identify chemical warfare agents. Thousands of the sets are
                         not accounted for and, in some cases, only the glass vials or bottles filled
                         with chemicals have been recovered. A small quantity of sets are stored at
                         Camp Bullis, Texas; Fort Richardson, Alaska; Johnston Atoll, Pacific
                         Ocean; Redstone Arsenal, Alabama; and Tooele Army Depot, Utah.

Former Chemical Weapon   Chemical agent and weapons were produced in various government
Production Facilities    facilities prior to 1968. These facilities are located at Aberdeen, Pine Bluff,
                         Rocky Mountain Arsenal, and Newport Army Ammunition Plant, Indiana,
                         and are in various degrees of deterioration. DOD is reviewing former
                         production facilities at Swannanoa, North Carolina, and Van Nuys,
                         California, to determine whether they require remediation actions.


                         The Army has limited experience destroying nonstockpile materiel and is
Environmental Laws       unfamiliar with what types of environmental problems to expect. Prior to
and Requirements         recovering, storing, moving, or destroying nonstockpile chemical warfare
Govern Most              materiel, the Army must comply with state environmental laws and
                         regulations. These laws and regulations may impose time frames for
Nonstockpile             certain efforts that, in turn, drive other nonstockpile activities and related
Activities               costs. For example, if an operating permit is delayed for one of the
                         nonstockpile disposal systems because of an unanticipated requirement,
                         virtually all disposal activities at the remediation site must stop until the
                         permit is issued.

                         The Resource Conservation and Recovery Act controls hazardous waste
                         through a permit process that requires government approval for
                         individuals who generate, transport, store, or dispose of hazardous waste.

                         3
                          The sets contain sulfur mustard agent, nitrogen mustard agent, lewisite, phosgene, cyanogen chloride,
                         chloroform, chloropicrin, solid chloroacetophenone, solid triphosgene, solid adamsite, and other
                         chemicals.



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Under the act, the Environmental Protection Agency may authorize
individual states to administer and enforce hazardous waste programs that
are as least as stringent as the federal program. Although based on the
Resource Conservation and Recovery Act’s requirements, individual state
hazardous waste laws and requirements differ and are occasionally
changed. According to the Army, changes in the states’ laws and
requirements may affect the nonstockpile disposal program because they
are likely to apply to most aspects of the program on military installations.
According to the Army, state regulatory agencies could add unanticipated
requirements to the permitting process, including extra demonstrations or
tests prior to the start of disposal operations. Depending on the time
involved, disposal activities at follow-on sites could be stalled or
suspended, resulting in additional costs. The Resource Conservation and
Recovery Act requires (1) site-specific operating permits for the Rapid
Response System and munitions management devices; (2) specific
disposal standards for the hazardous waste generated by the program; and
(3) precise permitting, record-keeping, and reporting requirements.

Similarly, changes in the Comprehensive Environmental Response,
Compensation, and Liability Act requirements may affect the nonstockpile
program. The act provides overall cleanup procedures for some
nonstockpile sites and incorporates the standards of other federal and
state statutes if they are applicable or relevant and appropriate to the
cleanup process. A specific sequence of activities, guaranteeing the
participation of federal and state agencies and the public in key decisions,
must be followed before a nonstockpile site can be cleaned up. The act
requires (1) completion of remedial investigation and feasibility studies for
most formerly used defense sites such as the former Raritan Arsenal, New
Jersey; (2) site-specific closure standards; and (3) emergency response
actions, such as those taken in response to the Spring Valley site in
Washington, D.C.

The Hazardous Materials Transportation Act governs the transportation of
most nonstockpile chemical materiel and limits the movement of materiel
without special permits, licenses, and authorizations. The act delegates
regulatory and enforcement responsibilities to the states but limits some
state regulations. Nevertheless, states may still implement routing
restrictions, transportation curfews, notification deadlines, and public
right-to-know requirements. The act requires specialized packaging for
transporting nonstockpile materiel and the treatment residues, and limits
commercial transportation of selected nonstockpile chemical materiel or
neutralized chemical agent. The Army anticipates that every state



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                                    nonstockpile materiel travels through will have some jurisdiction over part
                                    of the move.


                                    The Army’s disposal concept is based on mobile systems capable of
The Army’s Mobile                   moving from location to location where the munitions are characterized
Disposal Systems Are                and the agent is detoxified, the waste is sent to a commercial hazardous
Not Fully Developed                 waste facility, and the system and equipment are detoxified before the
                                    next move. The Army is developing mobile systems to characterize and
                                    destroy Chemical Agent Identification Sets, recovered chemical weapons,
                                    and bulk chemical warfare materiel. (See table 3.2.) Although Army
                                    officials are confident that the proposed mobile remediation systems will
                                    function as planned, the Army needs more time to prove that the systems
                                    will safely and effectively destroy all nonstockpile materiel and be
                                    accepted by the state regulatory agencies and the public.

Table 3.2: Summary of the
Nonstockpile Disposal Systems and   System                    Description                                   Status
Estimated Operational Dates         Portable Isotopic         A portable, gamma ray system used for         Operational
                                    Neutron Spectroscopy      noninvasive characterization of elemental
                                                              components of chemical agents in
                                                              recovered chemical warfare materiel.
                                    Raman                     A portable device used to identify           Operational
                                    Spectrophotometer         chemical agents inside glass containers
                                                              found in Chemical Agent Identification Sets.
                                    Chemical Agent            A fixed system at Aberdeen Proving            Operational
                                    Transfer System           Ground that transfers chemical agents
                                                              from recovered nonexplosive-configured
                                                              materiel to storage containers and
                                                              performs other chemical operations.
                                    Rapid Response            A portable system designed to process         Operational in
                                    System                    small amounts of chemical agents and          fiscal year 1998
                                                              materiel contained in Chemical Agent
                                                              Identification Sets.
                                    Munitions Management A portable system designed to detoxify             Operational in
                                    Device-1             most nonexplosive-configured chemical              fiscal year 1998
                                                         warfare materiel.
                                    Munitions Management A portable system designed to detoxify             Operational in
                                    Device-2             most explosive-configured chemical                 fiscal year 1999
                                                         warfare materiel. The system will be
                                                         designed to fully contain any potential
                                                         explosion resulting from operations.
                                    Munitions Management A portable system designed to detoxify             Operational in
                                    Device-3             nonexplosive-configured bulk chemical              fiscal year 1998
                                                         warfare items larger than a 500-pound
                                                         bomb.




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                         In its 1993 Survey and Analysis Report, the Army concluded that the
                         technical risk for the nonstockpile program was high because the disposal
                         systems were not yet completed. It also reported that if effective processes
                         or procedures were not discovered, it would have to fund “a major
                         research and development program.” In its 1994 risk assessment, the Army
                         reported that the lack of technology for on-site disposal operations could
                         hamper the completion of the nonstockpile program.


Accelerated Program to   According to the Army, the most immediate concern of the nonstockpile
Develop the Rapid        program is the treatment of Chemical Agent Identification Sets because of
Response System          the relative frequency of their discovery. As a result, the Army accelerated
                         the program to develop a system, called the Rapid Response System, to
                         process and destroy the sets. When operational, the two-trailer system will
                         use commercially available technology. (See fig. 3.2.) The chemical
                         detoxification of the agent, as well as packaging of the waste, will occur
                         inside a glovebox housed in the operational trailer. Air circulating through
                         the glovebox is vented through charcoal filters to entrap agent and other
                         hazardous chemicals prior to discharge from the trailer. The utility trailer
                         houses an electrical generator to use mainly at remote sites and a
                         refrigerator for use in monitoring activities. Once treated with neutralizing
                         chemicals, the residue will be sent to a commercial hazardous waste
                         facility. The system will be detoxified before moving to the next location.




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Figure 3.2: Conceptual Drawing of the Rapid Response System




    Utility
    Trailer




                           Operations
                           Trailer




                                        Source: The Army’s Program Manager for Chemical Demilitarization.




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                             The Rapid Response System has been designed and assembled and is
                             scheduled to be tested at Tooele Army Depot in mid-1997. The Army’s
                             slow development of background data for Utah’s environmental permitting
                             process has delayed the start of the system’s concept demonstration by
                             9 months. The Rapid Response System is scheduled for its first use at Fort
                             Richardson, Alaska, in fiscal year 1998. It is expected to process 12 to 15
                             vials of agent each day.


Prototype of the Munitions   The Army is developing mobile munitions management devices to assess,
Management Devices Is        access, and dispose of most nonstockpile chemical warfare materiel on
Scheduled for Operational    site. According to Army officials, the disposal rates are not yet established
                             and could be as low as one or two items per day. The Munitions
Use in Fiscal Year 1998      Management Device-1 consists of two tractor trailers, one for processing
                             nonexplosive configured munitions using chemical neutralization and the
                             other for controlling operations. (See fig. 3.3.) Weapons and materiel will
                             be placed in the treatment vessel, drained of liquid chemical agent, and
                             decontaminated with a neutralizing solution. As a precautionary measure,
                             the process trailer is designed to contain liquid or vapor accidentally
                             released and is surrounded by a tent-like enclosure to provide an
                             additional level of safety. A gas-processing system filters and treats any
                             chemical vapors in the process trailer and the outside is monitored for
                             agent. Neutralized waste is packaged and shipped to a commercial
                             hazardous waste management facility.




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Figure 3.3: Conceptual Drawing of the Munitions Management Device-1

                                                                                      Control Trailer




            Process
            Trailer




               Process
               Trailer
               Enclosure




                                        Source: The Army’s Program Manager for Chemical Demilitarization.




                                        If the Munitions Management Device-1 proves successful, two other
                                        systems will be developed for disposing explosively configured munitions
                                        and bulk munitions and containers. The Army considers the Munitions
                                        Management Device-2, which will process explosively configured
                                        munitions, to be the most technologically challenging of the devices. Its
                                        design, fabrication, and testing are scheduled through mid-1998, with two
                                        follow-on units scheduled for delivery in 2000 and ready for operation in
                                        2001. The Munitions Management Device-3, scheduled for operations in
                                        1998, will process items larger than 500-pound bombs and recovered ton
                                        containers with chemical agent. The Army plans to pack the neutralized
                                        chemical waste and ship it to a commercial hazardous waste facility.




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                                The Army could potentially reduce costs by using (1) chemical stockpile
Opportunities for Cost          disposal facilities for destroying selected nonstockpile materiel or (2) a
and Schedule                    centralized disposal facility designed specifically for destroying
Reductions Are                  nonstockpile materiel. However, according to Army officials, these options
                                create legal and political obstacles and public acceptance issues that
Limited                         would have to be resolved.


Use of Stockpile Disposal       The DOD Authorization Act of 1986 (P.L. 99-145), and subsequent
Facilities                      legislation, specifies that the chemical stockpile disposal facilities may not
                                be used for any purpose other than the disposal of stockpile weapons. The
                                Army interpreted this legislation to mean that the stockpile disposal
                                facilities, with the exception of the Johnston Atoll Chemical Agent
                                Disposal System, may not be used to dispose of other DOD materiel,
                                including nonstockpile chemical materiel. This interpretation necessitates
                                that the Army, in order to comply with the act, implement separate
                                disposal operations for nonstockpile materiel along side of the stockpile
                                facilities.

                                In its 1995 implementation plan, the Army suggested that the stockpile
                                disposal facilities could be used to process some nonstockpile weapons,
                                depending on the location, the type of chemical weapon or materiel, and
                                condition.4 For example:

                            •   The first category of nonstockpile materiel that could be destroyed
                                includes items that are (1) already located at the disposal site requiring no
                                off-base transportation, (2) similarly configured stockpile weapons
                                scheduled to be disposed of in the facility, and (3) the same agent type as
                                those scheduled to be destroyed in the facility. An example is the
                                nonstockpile ton containers previously filled with mustard agent stored at
                                Tooele Army Depot, Utah. The facility is already designed to dispose of
                                stockpile ton containers filled with mustard agent. The containers are
                                exactly the same except that the nonstockpile containers were used in
                                prior sampling and disposal programs and historically recorded as
                                nonstockpile, while the stockpile containers hold production stock.
                            •   A second category of nonstockpile materiel includes items that (1) are
                                already located at the disposal site, (2) are similarly configured to items
                                scheduled for disposal, and (3) contain a different agent type than those
                                scheduled to be destroyed in the facility. An example is the nonstockpile
                                ton containers filled with nerve agent stored at Aberdeen Proving Ground,

                                4
                                  Non-Stockpile Chemical Materiel Program Implementation Plan, U.S. Army Program Manager for
                                Chemical Demilitarization (Aug. 1995).



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    Maryland. With some modifications to a stockpile disposal facility
    designed to incinerate mustard-filled ton containers, the facility could
    destroy the containers filled with nerve agent.
•   A third, and more difficult, category of nonstockpile materiel includes
    items that are (1) already located at the disposal site, (2) configured
    somewhat differently than the stockpile weapons scheduled for disposal,
    and (3) the same or different agent type as those scheduled to be
    destroyed. An example is the nonstockpile bottles of mustard agent
    located at Pueblo Depot Activity, Colorado. Pueblo’s proposed facility will
    be designed to destroy mustard agent and could easily incinerate the
    bottles.5 According to Army officials, some nonstockpile materiel in this
    category would probably be easier processed, and for less money, by one
    of the proposed nonstockpile disposal systems.
•   The last category involves transporting nonstockpile materiel from its
    current storage or burial site to an existing stockpile disposal facility.
    However, the 1995 National Defense Authorization Act
    (P.L. 103-337) allows the transport of only newly discovered nonstockpile
    materiel to the nearest storage site that has the necessary environmental
    permits. The nearest permitted location may not have the appropriate
    facilities to dispose of the materiel.

    The Resource Conservation and Recovery Act also has the potential to
    limit using the stockpile disposal facilities to destroy nonstockpile
    materiel. State regulators, under the act’s comprehensive body of
    requirements, can implement disposal limits and controls for the disposal
    facilities. For example, the state of Utah has established disposal limits for
    the Tooele Chemical Agent Disposal Facility based on the amounts of
    chemical weapons and agent stockpiled at Tooele. To dispose of
    nonstockpile materiel, the Army would have to amend the Resource
    Conservation and Recovery Act permit to increase the facility’s disposal
    limits. The amendment process, controlled by the state, requires time and
    money. In addition, DOD and Army officials expect that any efforts to
    increase the use of the stockpile facilities would likely result in strong
    state and public opposition and potential delays in the state environmental
    permitting process.




    5
     The 1997 DOD Appropriations Act prohibits DOD from obligating any funds for constructing disposal
    facilities at Blue Grass, Kentucky, and Pueblo, Colorado, until 180 days after the Secretary reports on
    disposal alternatives.



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Use of a Centralized          Another method for destroying nonstockpile chemical materiel could be
Facility Designed             the use of a central disposal facility with equipment designed specifically
Specifically for Destroying   for destroying nonstockpile materiel. The facility could operate in
                              cooperation with existing government and commercial facilities—much
Nonstockpile Materiel         the way it will be done in European countries. According to Army officials,
                              a similar program in the United States would reduce the costs of the
                              nonstockpile program. However, the legislative restrictions on the
                              transportation of nonstockpile materiel would have to be lifted to make a
                              central disposal facility a viable option. In addition, the current process of
                              individual states establishing their own environmental requirements and
                              prevalent public attitude that a chemical weapons disposal facility should
                              not be located in their vicinity would be significant obstacles that would
                              have to be resolved to make a centralized disposal facility viable.




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               While there is general agreement about the need to destroy the chemical
Conclusions    stockpile and related nonstockpile materiel, progress has slowed due to
               the lack of consensus among DOD and affected states and localities about
               the destruction method that should be used. As a result, the cost and
               schedule for the disposal programs are uncertain. However, the programs
               are likely to cost more than the estimated $24.4 billion above current
               expenditures and take longer than currently planned. The key factors
               impacting the programs include public concerns about the safety of
               incineration, compliance with environmental laws and regulations,
               legislative requirements, and the introduction of alternative disposal
               technologies.

               The Chemical Stockpile Disposal Program cost and schedule are largely
               driven by the degree to which states and local communities are in
               agreement with the proposed disposal method. Historically reaching
               agreement has consistently taken longer than the Army anticipated.
               Furthermore, the recent congressional direction in the 1997 Authorization
               and Appropriations Acts to research and develop alternative technologies
               to destroy assembled chemical munitions indicates that there is continued
               public concern about the proposed disposal method. Until DOD and the
               affected states and localities reach agreement on a disposal method for
               individual sites, the Army will not be able to predict the Chemical
               Stockpile Disposal Program cost and schedule with any degree of
               accuracy. Moreover, many of the problems experienced in the stockpile
               program are also likely to affect the Army’s ability to implement the
               Nonstockpile Chemical Materiel Program. For example, efforts to dispose
               of nonstockpile materiel are likely to be driven by the need to obtain state
               and local approvals for destruction methods. In addition, more time is
               needed for the Army to prove that its proposed disposal method for the
               nonstockpile program will be safe and effective and accepted by the
               affected states and localities.

               Recognizing the difficulty of satisfactorily resolving the public concerns
               associated with each individual disposal location, suggestions have been
               made by Members of the Congress, DOD officials, and others to change the
               programs’ basic approach to destruction. However, the suggestions create
               tradeoffs for decision makers and would require changes in existing legal
               requirements. These suggestions have included deferring plans for
               additional disposal facilities until an acceptable alternative technology to
               incineration is developed, consolidating disposal operations at a national
               or regional sites, destroying selected nonstockpile chemical warfare
               materiel in stockpile disposal facilities, establishing a centralized disposal



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                  facility for nonstockpile materiel, and modifying existing laws and
                  regulations to standardize environmental requirements.


                  As the Congress continues its oversight of the chemical stockpile and
Matters for       nonstockpile disposal programs and considers modifications or
Congressional     alternatives to the current approach, it may wish to include consideration
Consideration     of the suggestions discussed in this report relating to the creation of
                  alternative technologies, consolidation of stockpile disposal operations,
                  utilization of stockpile facilities for nonstockpile items, centralization of
                  nonstockpile destruction, and standardization of environmental laws and
                  requirements.


                  DOD  provided written comments on a draft of this report and they are
Agency Comments   presented in their entirety in appendix V. DOD stated that the draft
                  accurately and fairly characterized the current status of the disposal
                  programs and generally concurred with the suggestions of the draft report
                  that changes in existing legal requirements would be necessary to change
                  the current path of the disposal programs.

                  While DOD agreed that the Congress could consider options presented by
                  us, it recommended consideration of the ones to establish a centralized
                  disposal facility for nonstockpile materiel and to modify existing laws and
                  regulations to standardize environmental requirements for chemical
                  weapons disposal. DOD does not support consideration of deferring plans
                  for additional stockpile disposal facilities until an acceptable alternative
                  technology is developed because such delays result in substantial
                  increases in public risk from continued storage of the stockpile. DOD does
                  not recommend transportation of the stockpile at this time because
                  transportation of chemical weapons increases the risk to the general
                  public. In addition, DOD recommended against using stockpile disposal
                  facilities to destroy nonstockpile materiel because of the strong public
                  opposition to both the use of stockpile disposal facilities to treat any other
                  waste materiel and the transportation of chemical materiel for disposal in
                  these facilities.

                  Our draft report recognized that some options could increase the risk to
                  the general public and would likely be opposed by some of the affected
                  states and localities and other interested parties. We presented the options
                  in context of their tradeoffs should the Congress wish to address the key
                  factors affecting the programs’ disposal costs and schedule. We did not



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take a position on the options or current approach given the associated
policy and legislative implications.




Page 57                                  GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix I

Objectives, Scope, and Methodology


              Due to continuing congressional and public interest about the progress
              and cost of the programs, we prepared this report under our basic
              legislative responsibilities to provide an overall assessment of the
              (1) programs’ cost and schedule, (2) alternatives for improving program
              effectiveness and efficiency, and (3) actions the Army has and is taking to
              improve the programs. During our review, we interviewed and obtained
              data from officials of the Department of Defense (DOD), the Army, the
              Army Chemical and Biological Defense Agency, the U.S. Army Nuclear and
              Chemical Agency, and the U.S. Army Corps of Engineers. We also met with
              U.S. Environmental Protection Agency officials to discuss and collect data
              on environmental and legal issues related to the disposal programs. We
              visited Aberdeen Proving Ground, Maryland; Anniston Army Depot,
              Alabama; Pine Bluff Arsenal, Arkansas; Pueblo Depot Activity, Colorado;
              Tooele Army Depot, Utah; and Umatilla Depot Activity, Oregon. We also
              visited state and county officials in Alabama, Arkansas, Colorado,
              Maryland, Oregon, and Utah. We did not include the Chemical Stockpile
              Emergency Preparedness Program and overseas U.S. chemical warfare
              material in our review. We plan to issue a report later this year on the
              status and the management of the Chemical Stockpile Emergency
              Preparedness Program in the ten states participating in the program.

              To assess the programs’ cost and schedule, we reviewed the Army’s
              implementation plans, disposal data, status reports, and data on
              environmental and legal issues. We reviewed the Army’s estimation
              methodology, potential problems that may affect current cost and
              schedule estimates, and the causes of previous schedule slippages and
              cost increases. We analyzed (1) the reasons for the public concerns about
              incineration of chemical agents, (2) the Army’s efforts to obtain
              environmental permits and current issues, (3) obstacles in the
              environmental compliance and permitting process, (4) the status of the
              environmental permits at each of the disposal sites, and (5) federal and
              state environmental laws and regulations that apply to the disposal
              programs. We also obtained federal and state officials’ views on the
              accuracy of the Army’s estimated schedule to determine how current or
              proposed state laws or regulations could affect the disposal programs.

              To assess alternatives for improving program effectiveness and efficiency,
              we analyzed the Army’s current cost position and initiatives for reducing
              costs and shortening the disposal schedules. We also examined data on
              the Army’s management approach to contracting, disposal experience at
              Johnston Atoll and Tooele, the baseline incineration process, and
              approaches for addressing environmental permitting issues. To assess



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Appendix I
Objectives, Scope, and Methodology




technological alternatives, we analyzed data on disposal technologies, the
advantages and disadvantages of the baseline incineration process, the
advantages and disadvantages of selected alternatives, and public
concerns and issues related to the baseline and alternative technologies.
We also analyzed plans and methodologies for developing alternative
technologies, costs and schedule data related to the alternatives,
acquisition strategies and responsibilities, and test and evaluation results.
To assess transportation options, we analyzed transportation studies and
concepts, packaging methods, and the risk associated with transportation.
We reviewed data on chemical weapon movements, chemical munitions
transport packaging systems, transportation containers for hazardous
material, potential transportation routes, emergency response plans, and
transportation modes. In addition, we collected information concerning
the public opposition to transportation of chemical weapons, obstacles in
the environmental compliance and permitting process for transportation
options, and environmental laws and regulations applicable to
transportation.

To assess the actions the Army has and is taking to improve the programs,
we reviewed DOD’s 1994 designation of the Army’s chemical
demilitarization program as a major defense acquisition program. We
documented and analyzed data on lessons learned from disposal
operations at Johnston Atoll Chemical Agent Disposal System and Tooele
Chemical Agent Disposal System and their effects on the stockpile and
nonstockpile programs. Lastly, we reviewed the Army’s actions to
strengthen its public outreach efforts and improve its monitoring and
inspection of chemical munitions.

DOD provided written comments on a draft of this report. These comments
are presented in their entirety in appendix V.

We performed our review from August 1995 to November 1996 in
accordance with generally accepted government auditing standards.




Page 59                              GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix II

Appropriated, Obligated, and Disbursement
Data for Fiscal Years 1988 Through 1997

Table II.1: Chemical Stockpile Disposal
Program                                   Dollars in millions
                                          Fiscal year           Appropriated          Obligated          Expended
                                          1988                        $195.8             $194.3             $192.9
                                          1989                         168.0              165.5              165.4
                                          1990                         210.4              208.2              205.9
                                          1991                         255.0              252.3              251.5
                                          1992                         331.3              330.1              326.8
                                          1993                         419.1              417.9              316.0
                                          1994                         249.1              246.7              234.9
                                          1995                         486.5              472.2              279.2
                                          1996                         484.2              346.0              130.5
                                          1997                         534.7
                                          Total                     $3,334.1           $2,633.2           $2,103.1

Table II.2: Alternative Technologies
and Approaches Project                    Dollars in millions
                                          Fiscal year           Appropriated          Obligated          Expended
                                          1994                         $22.4              $22.2              $10.2
                                          1995                           9.4                9.4                 6.8
                                          1996                          22.2               19.6               12.2
                                          1997                          56.0
                                          Total                       $110.0              $51.2              $29.2

Table II.3: Chemical Stockpile
Emergency Preparedness Project            Dollars in millions
                                          Fiscal year           Appropriated          Obligated          Expended
                                          1988                          $2.5               $2.5               $2.5
                                          1989                          11.3               11.3               11.1
                                          1990                          43.8               43.7               43.3
                                          1991                          37.7               37.6               37.5
                                          1992                          40.9               40.5               40.0
                                          1993                          88.2               87.5               62.1
                                          1994                          71.9               71.6               65.5
                                          1995                          56.5               56.4               27.6
                                          1996                          80.0               65.2               27.3
                                          1997                          82.4
                                          Total                       $515.2             $416.3             $316.9




                                          Page 60                     GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                    Appendix II
                                    Appropriated, Obligated, and Disbursement
                                    Data for Fiscal Years 1988 Through 1997




Table II.4: Nonstockpile Chemical
Materiel Program                    Dollars in millions
                                    Fiscal year                         Appropriated              Obligated       Expended
                                    1992                                          $2.2                    $2.2         $2.2
                                    1993                                           6.3                     6.3           6.0
                                    1994                                          31.5                    31.2         26.4
                                    1995                                          26.0                    25.8         18.5
                                    1996                                          69.7                    40.4         14.6
                                    1997                                          85.3
                                    Total                                      $221.0                   $105.9        $67.7
                                    Source: The Army’s Program Manager for Chemical Demilitarization.




                                    Page 61                                    GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix III

Summary of Major Federal Environmental
Laws Affecting the Army’s Disposal
Programs

Date    Title                                        Provisions
1969    The National Environmental Policy Act        Requires the Army to develop an environmental impact statement or
        (42 U.S.C. 4321 et seq.)                     assessment about the potential environmental effects of destroying chemical
                                                     weapons and materiel.
1970    The Clean Air Act, as amended (42 U.S.C.     Governs potential sources of air pollutants and establishes emission standards.
        7401 et seq.)                                The Army must obtain permits for air pollution control prior to constructing and
                                                     operating any disposal facility.
1972    The Marine Protection, Search, and           Restricts ocean dumping of chemical weapons.
        Sanctuaries Act (33 U.S.C. 1411 et seq.)
1974    The Hazardous Materials Transportation       Regulates the packaging, marking, loading, and transporting of hazardous
        Act (49 U.S.C. 5101 et seq.)                 materials by road or rail.
1976    The Toxic Substances Control Act, as         Regulates the disposal of items containing polychlorinated biphenyls and
        amended (15 U.S.C. 2601 et seq.)             asbestos. The fiberglass matrices of the shipping and firing tubes for stockpiled
                                                     M55 rockets contain polychlorinated biphenyls, and some former production
                                                     facilities contain asbestos.
1976    The Resource Conservation and Recovery       Regulates the treatment, storage, and disposal of hazardous waste. The Army
        Act, as amended (42 U.S.C. 6901 et seq.)     must obtain state permits prior to constructing and operating any disposal
                                                     facility or system where stockpile and nonstockpile items are classified as
                                                     hazardous waste.
1977    The Clean Water Act, as amended              Governs potential sources of water pollution and specifically prohibits the
        (33 U.S.C. 1251 et seq.)                     discharge of any chemical agent into U.S. navigable waters.
1980    The Comprehensive Environmental           Addresses hazardous substance releases into the soil, air, surface water, and
        Response, Compensation, and Liability Act groundwater and regulates the cleanup of these releases. A specific sequence
        (42 U.S.C. 9620 et seq.)                  of activities guaranteeing the participation of federal and state agencies and the
                                                  public in key decisions must be followed before cleanup of some nonstockpile
                                                  sites.




                                           Page 62                                   GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix IV

Chronology of the U.S. Chemical
Demilitarization Program


Time frame    Activity
1917-1960s    Obsolete or unserviceable chemical warfare agents and munitions were disposed of by open pit burning, land
              burial, and ocean dumping.
1969          The National Academy of Sciences recommended that ocean dumping be avoided and that public health and
              environmental protection be emphasized. It suggested two alternatives to ocean disposal: chemical
              neutralization of nerve agents and incineration of mustard agents.
1970          The Armed Forces Authorization Act (P.L. 91-441) required a Department of Health and Human Services review
              of any disposal plans and detoxification of weapons prior to disposal. It also limited the movement of chemical
              weapons.
1971          The Foreign Military Sales Act prohibited the transportation of U.S. chemical weapons from Okinawa, Japan, to
              the continental United States. The weapons were moved to Johnston Atoll in the Pacific Ocean.
1971-1973     The Army tested and developed an incineration process and disposed of several thousand tons of mustard
              agent stored in ton containers at Rocky Mountain Arsenal.
1973-1976     The Army disposed of nearly 4,200 tons of nerve agent by chemical neutralization at Tooele Army Depot and
              Rocky Mountain Arsenal. The process was problematic and not very reproducible, making automation difficult.
1979          The Army opened the Chemical Agent Munitions Disposal System at Tooele to test and evaluate disposal
              equipment and processes for chemical agents and munitions on a pilot scale.
1981          The Army decided to build the Johnston Atoll Chemical Agent Disposal System to dispose of its chemical M55
              rocket stockpile.
1981-1986     The Army used the Chemical Agent Munitions Disposal System to test and evaluate incineration of chemical
              agents and energetic materiel, and decontamination of metal parts and ton containers.
1982          An Arthur D. Little Corporation study for the Army concluded that using incineration, rather than neutralization, to
              dispose of the stockpile would reduce costs.
1982          The Army declared its stockpile of M55 rockets obsolete.
1983          The Army expanded its chemical disposal program to include the M55 rocket stockpile at Anniston Army Depot,
              Umatilla Depot Activity, and Blue Grass Depot Activity.
1984          The Army expanded its chemical disposal program to include the M55 rocket stockpile at Pine Bluff Arsenal and
              Tooele Army Depot.
1984          The National Research Council endorsed the Army’s disassembly and high-temperature incineration process for
              disposing of chemical agents and munitions. It also recommended that the Army continue to store most of the
              chemical stockpile, dispose of the M55 rockets, and analyze alternative methods for disposing of the remaining
              chemical stockpile.
1985          The Army began construction of the Johnston Atoll Chemical Agent Disposal System.
1985          The DOD Authorization Act for Fiscal Year 1986 (P.L. 99-145) mandated the destruction of the U.S. stockpile of
              lethal chemical agents and munitions. It also required that the disposal facilities be cleaned, dismantled, and
              disposed of according to applicable laws and regulations.
1986          The DOD Appropriations Act for Fiscal Year 1987 (P.L. 99-500) prohibited shipments of chemical weapons,
              components, or agents to the Blue Grass Depot Activity for any purpose.
1987          Chemical Agent Munitions Disposal System operations were suspended as a result of a low-level nerve agent
              release.
1988          The Army issued the Final Programmatic Environmental Impact Statement for the Chemical Stockpile Disposal
              Program. The Army selected on-site disposal of the chemical stockpile because it posed fewer potential risks
              than transportation and off-site disposal.
1988          The National Defense Act of Fiscal Year 1989 (P.L. 100-456) required the Army to complete operational
              verification testing at Johnston Atoll before beginning to systematize similar disposal facilities in the continental
              United States.
                                                                                                                         (continued)


                                       Page 63                                    GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                     Appendix IV
                                     Chronology of the U.S. Chemical
                                     Demilitarization Program




Time frame   Activity
1989         The Army started construction of the chemical demilitarization facility at Tooele Army Depot.
1990         The Army completed the successful retrograde of all chemical munitions stored in Germany to storage facilities
             at Johnston Atoll.
1990         The Army initiated disposal of M55 rockets at Johnston Atoll.
1990         A very small amount of nerve agent leaked through the common stack during maintenance activities at Johnston
             Atoll. The agent release was below allowable stack concentration.
1990-1993    The Army completed four operational verification tests of the Johnston Atoll Chemical Agent Disposal System.
             During the tests, the Army destroyed more than 40,000 munitions containing nerve and mustard agents. In
             August 1993, the Secretary of Defense certified to the Congress that the Army had successfully completed the
             operational verification tests at Johnston Atoll.
1991         The National Defense Authorization Act for Fiscal Year 1991 (P.L. 101-510) restricted the use of funds to transport
             chemical weapons to Johnston Atoll except for U.S. munitions discovered in the Pacific, prohibited the Army from
             studying the movement of chemical munitions, and established the emergency preparedness program.
1991         The Army moved 109 World War II mustard-filled projectiles from the Solomon Islands to Johnston Atoll for
             storage and disposal.
1991         The National Defense Authorization Act for Fiscal Years 1992 and 1993 (P.L. 102-190) required the Secretary of
             Defense to develop a chemical weapons stockpile safety contingency plan.
1992         The U.S. Army Chemical Materiel Destruction Agency was established to consolidate operational responsibility
             for the destruction of chemical warfare capabilities into one office.
1992         The National Defense Authorization Act for Fiscal Year 1993 (P.L. 102-484) directed the Army to establish
             citizens’ commissions for states with storage sites, if the state’s governor requested one. It also required the
             Army to report on (1) disposal alternatives to the baseline incineration method and (2) plans for destroying U.S.
             nonstockpile chemical weapons and materiel identified in the Chemical Weapons Convention.
1993         The Johnston Atoll Chemical Agent Disposal System was shut down during operation and verification tests when
             residue explosive material generated during the processing of M60 105mm projectiles caught fire, causing
             damage to a conveyor belt and other equipment in the explosive containment room.
1993         The Army completed construction and started systemization of the Tooele Chemical Agent Disposal Facility.
1993         The Army issued its report on the physical and chemical integrity of the chemical stockpile to the Congress.
1993         A mustard leak from a ton container was discovered at Tooele Army Depot.
1993         The Army issued an interim survey and analysis report on the Nonstockpile Chemical Materiel Program to the
             Congress.
1994         Approximately 11.6 milligrams of nerve agent were released into the atmosphere at the Johnston Atoll facility
             during a maintenance activity on the liquid incinerator.
1994         The National Research Council issued its recommendations for the disposal of chemical agents and munitions to
             the Army.
1994         The Army issued its alternative demilitarization technology report to the Congress. The Army recommended the
             continuation of the chemical demilitarization program without deliberate delay and the implementation of a
             two-technology research and development program.
1994         The Army issued its M55 rocket stability report to the Congress. The report recommended that an enhanced
             stockpile assessment program be initiated to better characterize the state of the M55 rocket in the stockpile.
1994         The Army initiated the Alternative Technologies Project to develop an alternative disposal technology to the
             baseline incineration process for the bulk-only stockpile locations in Maryland and Indiana. This research and
             development effort is conducted in conjunction with activities to implement the baseline program.
                                                                                                                    (continued)




                                     Page 64                                  GAO/NSIAD-97-18 Chemical Weapons and Materiel
                                     Appendix IV
                                     Chronology of the U.S. Chemical
                                     Demilitarization Program




Time frame   Activity
1994         The U.S. Army Chemical Materiel Destruction Agency was redesignated the U.S. Army Chemical Demilitarization
             and Remediation Activity after a merger with the U.S. Army Chemical and Biological Defense Command. In
             addition, the Army restructured and centralized its chemical stockpile emergency preparedness program to
             streamline procedures, enhance responsiveness of operations, and improve the budgeting process.
1994         The Assistant Secretary of the Army for Research, Development and Acquisition became the DOD Executive
             Agent for the Chemical Demilitarization Program, replacing the Assistant Secretary of the Army for Installations,
             Logistics, and Environment. The Chemical Demilitarization Program was designated a DOD Acquisition Category
             1D Program.
1995         The Army initiated the Enhanced Stockpile Surveillance Program to investigate, develop, and support methods to
             improve monitoring and inspection of chemical munitions.
1995         The U.S. Army Chemical Demilitarization and Remediation Activity was renamed the Program Manager for
             Chemical Demilitarization.
1995         The Johnston Atoll Chemical Agent Disposal System surpassed the 1-million pounds target and completed the
             disposal of all M55 rockets stored on Johnston Atoll. Disposal rates exceeded established goals.
1995         A perimeter monitor located about 100 yards from the demilitarization building at Johnston Atoll detected a trace
             level of nerve agent. The source of the leak was identified as a door gasket in the air filtration system. Temporary
             air locks were erected and the gasket replaced. No one was harmed from this event.
1995         The Army awarded the contract for small burial sites and issued its implementation plan for the nonstockpile
             program.
1995         The Tooele Chemical Agent Disposal Facility completed equipment systemization testing.
1995         The Army certified to the Congress that all Browder Amendment requirements for the award of the Anniston
             construction contract were met.
1996         The National Defense Authorization Act for Fiscal Year 1996 (P.L. 104-106) directed DOD to conduct an
             assessment of the Chemical Stockpile Disposal Program and options that could be taken to reduce program
             costs.
1996         The Army completed disposal of all Air Force and Navy bombs stored on Johnston Atoll ahead of schedule.
1996         The Army awarded the systems contract for the construction, operation, and closure of the proposed Anniston
             Chemical Agent Disposal Facility. Construction of the facility is scheduled to began after the state of Alabama
             issues the environmental permits.
1996         The Army started disposal operations at the Tooele Chemical Agent Disposal Facility. Shortly after the start,
             operations were shut down for a week after a small amount of agent was detected in a sealed vestibule attached
             to the air filtration system. No agent was released to the environment and no one was harmed.
1996         Several hair line cracks were discovered in the concrete floor of the Tooele disposal facility’s decontamination
             area. The cracks caused a small amount of decontamination solution to leak to an electrical room below. No
             agent was detected and the cracks were sealed.
1996         The 1997 National Defense Authorization Act (P.L. 104-201) directed DOD to conduct an assessment of
             alternative technologies for the disposal of assembled chemical munitions. The act also directed the Secretary of
             Defense to report on this assessment by December 31, 1997.
1996         The 1997 DOD Appropriations Act (P.L. 104-208) provided the Army $40 million to conduct a pilot program to
             identify and demonstrate two or more alternatives to the baseline incineration process for the disposal of
             assembled chemical munitions. The act also prohibited DOD from obligating any funds for constructing disposal
             facilities at Blue Grass and Pueblo until 180 days after the Secretary reports on the alternatives.
1996         The Chemical Weapons Convention was ratified by the 65th country needed to make the convention effective. As
             a result, the convention will go into effect April 29, 1997. Through ratification, the United States will agree to
             dispose of its (1) unitary chemical weapons stockpile, binary chemical weapons, recovered chemical weapons,
             and former chemical weapon production facilities by April 29, 2007, and (2) miscellaneous chemical warfare
             materiel by April 29, 2002.




                                     Page 65                                   GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix V

Comments From the Department of Defense




             Page 66      GAO/NSIAD-97-18 Chemical Weapons and Materiel
                        Appendix V
                        Comments From the Department of Defense




Now on pp. 55 and 56.




Now on pp. 55 and 56.




Now on pp. 55 and 56.




                        Page 67                              GAO/NSIAD-97-18 Chemical Weapons and Materiel
                        Appendix V
                        Comments From the Department of Defense




Now on pp. 55 and 56.




Now on pp. 55 and 56.




                        Page 68                              GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix VI

Major Contributors to This Report


                        Thomas J. Howard, Assistant Director
National Security and   Glenn D. Furbish, Senior Evaluator
International Affairs   Mark A. Little, Senior Evaluator
Division, Washington,   Bonita J. Page, Evaluator

D.C.




                        Page 69                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
Appendix VI
Major Contributors to This Report




Page 70                             GAO/NSIAD-97-18 Chemical Weapons and Materiel
Related GAO Products


              Chemical Weapons Stockpile: Emergency Preparedness in Alabama Is
              Hampered by Management Weaknesses (GAO/NSIAD-96-150, July 23, 1996).

              Chemical Weapons Disposal: Issues Related to DOD’s Management
              (GAO/T-NSIAD-95-185, July 13, 1995).

              Chemical Weapons: Army’s Emergency Preparedness Program Has
              Financial Management Weaknesses (GAO/NSIAD-95-94, Mar. 15, 1995).

              Chemical Stockpile Disposal Program Review (GAO/NSIAD-95-66R, Jan. 12,
              1995).

              Chemical Weapons: Stability of the U.S. Stockpile (GAO/NSIAD-95-67, Dec. 22,
              1994).

              Chemical Weapons Disposal: Plans for Nonstockpile Chemical Warfare
              Materiel Can Be Improved (GAO/NSIAD-95-55, Dec. 20, 1994).

              Chemical Weapons: Issues Involving Destruction Technologies
              (GAO/T-NSIAD-94-159, Apr. 26, 1994).

              Chemical Weapons Destruction: Advantages and Disadvantages of
              Alternatives to Incineration (GAO/NSIAD-94-123, Mar. 18, 1994).

              Arms Control: Status of U.S.-Russian Agreements and the Chemical
              Weapons Convention (GAO/NSIAD-94-136, Mar. 15, 1994).

              Chemical Weapon Stockpile: Army’s Emergency Preparedness Program
              Has Been Slow to Achieve Results (GAO/NSIAD-94-91, Feb. 22, 1994).

              Chemical Weapons Storage: Communities Are Not Prepared to Respond to
              Emergencies (GAO/T-NSIAD-93-18, July 16, 1993).

              Chemical Weapons Destruction: Issues Affecting Program Cost, Schedule,
              and Performance (GAO/NSIAD-93-50, Jan. 21, 1993).

              Chemical Weapons Destruction: Issues Related to Environmental
              Permitting and Testing Experience (GAO/T-NSIAD-92-43, June 16, 1992).

              Chemical Weapons Disposal (GAO/NSIAD-92-219R, May 14, 1992).




              Page 71                            GAO/NSIAD-97-18 Chemical Weapons and Materiel
           Related GAO Products




           Chemical Weapons: Stockpile Destruction Cost Growth and Schedule
           Slippages Are Likely to Continue (GAO/NSIAD-92-18, Nov. 20, 1991).

           Chemical Warfare: DOD’s Effort to Remove U.S. Chemical Weapons From
           Germany (GAO/NSIAD-91-105, Feb. 13, 1991).




(709134)   Page 72                         GAO/NSIAD-97-18 Chemical Weapons and Materiel
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