Background
This report is the second in a series of reports that discuss the acquisition of the Chemical Demilitarization Program [the Demilitarization Program]. The first report discussed the need for the Army to revise its acquisition program baseline agreement and to obtain a documented threat assessment for the Demilitarization Program. In May 2001, the Under Secretary of Defense for Acquisition, Technology, and Logistics [AT&L] designated the Demilitarization Program as a major Defense acquisition program and assigned the Army as the Executive Agent. The Office of the Secretary of Defense approved a life-cycle cost estimate of $24 billion for the Demilitarization Program in September 2001. Through December 2002, the Army awarded contracts totaling $5.8 billion for the construction, systemization, operations, and closure of seven chemical agent disposal facilities and planned two additional disposal facilities.
Results:
The Program Manager for the Demilitarization Program [the Program Manager] had made substantial progress in developing and operating chemical agent disposal facilities; however, program acquisition managers need to improve the program’s baseline performance by making better use of acquisition management policy and guidance in the areas of cost estimating, earned value management, preventive maintenance, failure reviews, and spare parts planning. Specifically:
The Under Secretary of Defense [AT&L] needs to conduct program cost reviews to enable him to have up-to-date cost information needed to revise program cost baselines and funding requirements and for the Program Manager to more accurately report the estimated liability for disposal of chemical agents in DoD financial statements [finding A].
The facility project managers at Tooele, Utah; Anniston, Alabama; and Umatilla, Oregon need to correct cost and schedule information that is incomplete or inaccurate in contractor cost performance reports to enable them to effectively monitor and manage contract execution and the Program Manager to provide complete and accurate cost and schedule information in status reports to the Under Secretary of Defense [AT&L] [finding B]. The project manager at the Tooele Chemical Agent Disposal Facility needs to ensure that the contractor performs timely preventive maintenance to decrease equipment failures, avoid potential fines, eliminate safety hazards, and reduce facility operating costs [finding C].
The Program Manager needs to ensure that facility project managers conduct effective operational failure reviews to prevent schedule delays, reduce program costs, and avoid potentially life-threatening injuries to workers from exposure to nerve agent vapor [finding D].
The Program Manager needs to identify initial and replenishment spares early in facility development, assign national stock numbers to replenishment spares needed at multiple facilities, and establish an obsolescence program to identify replenishment spares to help resolve difficulties that facility project managers encounter when replenishing common spares [finding E].
In May 2002, the Office of the Director, Accounting Policy, Office of the Under Secretary of Defense [Comptroller]/Chief Financial Officer requested that the audit review the methodologies that the Program Manager used for computing the chemical stockpile inventory and life-cycle cost estimate for the Demilitarization Program. In response to that request, we determined that the methodologies used to develop the lifecycle estimate and compute the stockpile inventory were adequate. Appendixes E and F provide the details on the cost estimating and inventory methodologies. See Appendix A for the details of the review of the management controls relating to the above findings. The Findings section of the report provides detailed recommendations.
Military personnel deployed in areas of conflict run the risk of exposure to a variety of chemicals and biological toxins used as weapons of mass destruction. In response to such threats, the Department of Defense [DoD] has developed a wide range of specially designed chemical and biological defense equipment for use by U.S. armed forces, including protective masks, filters, clothing, decontamination agents, and detectors/warning systems. Because they may contain hazardous substances, chemical defense items require proper management as they are demilitarized and/or turned in for disposal.
The purpose of this fact sheet is to outline the general regulatory framework governing the demilitarization and disposal of chemical defense equipment and provide references and points of contact for specific demilitarization and disposal information. [Unless otherwise specified in the text, the term "chemical defense equipment" as used in this Fact Sheet will denote both chemical and biological defense equipment that is unopened, uncontaminated, and expired.]
Applicable Policies and GuidelinesThe Defense Materiel Disposition Manual
The Defense Materiel Disposition Manual [DMDM], DoD 4160.21-M, is issued under the authority of DoD 4140.1-R, "Department of Defense Materiel Management Regulation." The DMDM sets forth DoD policy and prescribes uniform procedures for the disposition of DoD personal property. [NOTE: The DMDM was totally revised and reissued 18 August 1997, and supersedes DoD 4160.21-M, March 1990, Change 1 and numbered letters through 96-01.]
Chapter 10, Attachment 1, "Special Turn-in Requirements," provides guidance governing additional turn-in requirements as well as special handling and processing requirements for hazardous property, which would include some chemical defense equipment items.
The Defense Demilitarization Manual
The Defense Demilitarization Manual, DoD 4160.21-M-1, 21 October 1991, was issued under the authority of DoD Directive 4160.21, "DoD Personal Property Utilization and Disposal Program," 5 December 1980 and
DoD Instruction 4160.27, "Demilitarization of Materiel," 14 December 1988.
DoD 4160.21-M-1 implements the policy and procedures relating to military items, including chemical defense equipment owned or procured by, or under the control of, U.S. Military Services and Defense Agencies. The manual specifies the items to be demilitarized, designates key points to be destroyed, and prescribes methods for accomplishment of demilitarization.
The Defense Demilitarization Manual is undergoing
revision and, upon finalization, will be called the Demilitarization and Trade Security Controls Manual. Copies of both the new Defense Materiel Disposition Manual and the DRAFT Demilitarization and Trade Security Controls Manual can be downloaded from Demilitarization Requirements for Chemical Defense Equipment
Chemical defense equipment may contain hazardous substances, and therefore requires proper management during and after demilitarization. The management of hazardous substances is strictly regulated and penalties for noncompliance can be severe. Examples of hazardous substances contained in some pieces of chemical defense equipment include: 1] chromium in filters containing ASC impregnated activated carbon; 2] mercury cyanide in the M272 Water Test Kit; 3] chlorobenzene in red dye test solutions;
and 4] the DS2 [caustic alkali liquid] decon agent.
Chapter 10 of the DoD DMDM states, in accordance with DoD Instruction 471.6 "Environmental Compliance," the DRMO is responsible for the disposal of excess and hazardous property for the DoD and that use of DRMO services is the preferred method of disposal.
The DoD DMDM further states that DoD installations are responsible for identifying known hazards contained in returned property, especially property requiring demilitarization. With certain exceptions, DoD installations are generally not required to demilitarize chemical defense items before turn-in to a DRMO. The exceptions would be certain items of chemical defense equipment assigned demilitarization codes requiring the installation to demilitarize the item before its transfer to a DRMO. What remains of chemical defense items demilitarized by Air Force installations or activities, as well as non-demilitarized items, are transferred to a DRMO. The Air Force installation or activity is responsible for clearly identifying any hazardous components contained in chemical defense equipment transferred to a DRMO, whether or not the equipment has already been demilitarized.
Appendix 4 of the DoD Defense Demilitarization Manual outlines demilitarization procedures for chemical defense items by their Munitions List category. Chemical defense items used by U.S. Military Services, including the Air Force, are found in Munitions List categories X[c], X[d], X[e], XIV[c], and XIV[e] and XIV[f] [see Figure 1].
NOTE: PRO-ACT recommends that Air Force personnel responsible for the demilitarization and turn-in of chemical defense equipment contact their local DRMO, supply officials, item/technical managers, and environmental staff for specific instructions and confirmation that correct procedures are being followed.
DRMS Demilitarization Program
The
Defense Reutilization and Marketing Service [DRMS] is a Defense Logistics Agency [DLA] field activity that administers the disposal mission for the Department of Defense. Located at most major military installations, DRMOs receive, temporarily store, and dispose of personal property, such as vehicles, equipment, hand tools, clothing items, and furniture, that the military services no longer need or can use. The DRMO is the final link in the DoD supply chain. Excess DoD property is turned in for
disposal at 151 DRMOs worldwide.
The demilitarization program is a major part of the DRMO's mission. It prevents offensive and defensive military equipment, including chemical defense equipment, from being released to the public. It also prevents battlefield-related property from being unnecessarily rendered useless. Many items once purchased to support combat readiness can be reused and in many cases, partially demilitarized property can be reused without endangering the public. Demilitarized equipment turned in to the DRMS is sold only as scrap.
The DRMS World Wide Web site can be visited at //www.drms.dla.mil/index.html. A listing of DRMO locations worldwide is available at //www.drms.dla.mil/drmo/site/drmo.html. The Defense Reutilization and Marketing Manual, DoD 4160.21-M ["Fat Book"] is available at //www.drms.dla.mil/pubs/toc.htm. DoD 4160.21-M-1, "Defense Demilitarization Manual," is available at //www.dlaps.hq.dla.mil/dynaweb/dlaps/dodman/.
U.S. Army Chemical and Biological Defense CommandThe Environmental Quality Office of the U.S. Army Chemical and Biological Defense Command [CBDCOM] develops specialized demilitarization and disposal procedures for fielded chemical and biological defense equipment controlled by the U.S. Armed Forces. The Environmental Quality Office is one of several Offices within CBDCOM's Risk Management Division of Operations, which operates in support of the Edgewood Research, Development, and Engineering Center [ERDEC].
The CBDCOM's Environmental Quality Office develops detailed procedures for demilitarization of chemical defense equipment that ensure military items do not get into the wrong hands and environmental laws are not violated upon item disposal. All of the Environmental Quality Office's demilitarization and disposal procedures follow the United States Munitions List regulations in Title 22 Code of Federal Regulations [CFR] Section 121, as implemented in the Department of Defense Demilitarization Manual DoD 4160.21-M-1, and are in compliance with the Resource Conservation and Recovery Act [RCRA], Title 40 CFR 261.
CBDCOM's Environmental Quality Office has developed a Demilitarization Computer Disk that allows the user to look up chemical defense items listed in the Army Master Data File or other service catalogs, including detector kits, decon kits, decon equipment, protective masks/filters, alarms, and chemicals like Super Tropical Bleach, DS2, and impregnite. Once the item is located in the database, the disk allows the user to print an item-specific demilitarization procedure, instructions, and pertinent Material Safety Data Sheets for constituent chemicals. The disk is designed primarily for field troops; however, Air Force staff involved in the proper disposition of obsolete or expired chemical defense equipment may find the disk useful. Most chemical defense items supplied to the Air Force can be found in the Demilitarization Computer Disk. To obtain demilitarization procedures for Air Force-specific chemical defense items not found in the Disk, the base supply office or the servicing DRMO should be consulted for specific instructions.
The Demilitarization Computer Disk is available from the CBDCOM Environmental Quality Office, DSN 584-6588 or [410] 612-6588. Figure 2 presents a sample of the type of information available on the Demilitarization Computer Disk.
CBDCOM's Environmental Quality Office also provides demilitarization training programs for chemical defense equipment. The training covers munitions inventory categorization, demilitarization procedures, rationale for each category, and hazardous waste minimization initiatives. In addition, the Environmental Quality Office maintains compositions, specifications, data, pictures/diagrams, and manuals on 20+ year old obsolete equipment that may be found in warehouses during inspection clean-ups, and 40+ year old equipment found in old excavated burial dumps.
The U.S. Army CBDCOM WWW site, including links to ERDEC and newsletters, can be visited at //cbdcom.apgea.army.mil.
FIGURE 2: CBDCOM Demilitarization Computer Disk Sample Information
[Please refer to the actual CBDCOM Computer Disk for complete and detailed instructions and information.]
M9 Chemical Agent Detection Paper NSN 6665-01-049-8982 and NSN 6665-01-226-5589 M9 Chemical Agent Detection Paper may be demilitarized in one of three ways IAW DoD 4160.21-M-1: 1] turn in to DRMO with a demil code E; 2] demilitarize locally by chopping the rolls of paper in half with an ax; or 3] place large quantities of outdated rolls in a sanitary landfill with proper government supervision/certification.
M9 paper NSN 6665-01-226-5589 is made with a chromium-containing dye. A Toxicity Characteristic Leaching Procedure [TCLP] test was performed on 21 March 1990 by CBDCOM, the results of which determined the paper does not leach chromium in excess of acceptable levels and therefore is not a hazardous waste.
MSDS Sheets for both types of M9 Chemical Agent Detector Paper are attached to the demilitarization procedures.
M18A2 Detector Kit NSN 6665-00-903-4767
The M18A2 Detector Kit contains mercury compounds. The Item Manager must be contacted before demilitarization of the kit. Review this demilitarization procedure with your DRMO and environmental office to determine the desirability of separating the components of the kit. Before breaking or emptying any vial, ampoule, or tube, personnel should wear protective gloves and avoid breathing the chemical contents.
- Open kit and remove rubber aspirator bulb, remove Lucite adapter, mutilate the adapter and discard in trash. Replace rubber bulb.
- Remove the white dispenser with the red dot [the substrate dispenser] and place separately in an appropriate hazardous waste disposal drum. Report to the DRMO as hazardous waste D001. This component contains a flammable liquid.
- Remove the blue band tubes; break in half, and place separately in an appropriate hazardous waste disposal drum. Report the drum of blue band tubes to the DRMO as hazardous waste D009. This component contains mercury cyanide, a toxic waste.
- Remove the blue top bottle and place separately in an appropriate hazardous waste disposal drum. Report to the DRMO as hazardous waste D002. This component contains sodium hydroxide, a corrosive.
- Remove the balance of the kit contents, which is RCRA non-hazardous, and place separately in an appropriate waste disposal drum. Report to the DRMO.
- Turn in the empty kit container to DRMO with a certificate of demilitarization.
Mr. Leonard P. Fisher, SBCCOM's Environmental Quality Office Hotline for Demil and Disposal Guidance of Chemical Defense Equipment, DSN 584-6588, [410] 436-6588, .
MSgt Salvey, Contingency Support Directorate, Readiness Division [HQ AFCESA/CEXR], DSN 523-6161.
Document References- "Risk Management at Edgewood In 1995," Mr. Richard B. Belmonte, Edgewood Quarterly, Issue No. 5, March 1995.
- "Demilitarization/Disposal Program," Mr. Leonard P. Fisher, Edgewood Quarterly, Issue No. 7, December 1995.
- "Disposal Instructions for Gas Mask Filters," PRO-ACT Technical Inquiry [TI] 12336, 10 April 1997.
- "Chemical Warfare Gear Disposal," PRO-ACT TI 7718, 22 December 1995.
- Demilitarization Computer Disk, Environmental Quality Office, CBDCOM.
- Defense Materiel Disposition Manual, DoD 4160.21-M.
- DoD Demilitarization Manual, DoD 4160.21-M-1.
- "USAF Operations in a Chemical and Biological [CB] Warfare Environment, Defense Equipment," Air Force Handbook 32-4014, Volume 3, 1 February 1998.
- "U.S. Munitions List," Title 22 Code of Federal Regulations [CFR] Section 121.
- Title 40 CFR 261, "Identification and Listing of Hazardous Waste."