The US did such a fine job destroying it's chemical stockpiles, after all.
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November 21, 2000
Mr. Charles Scharmann
Office of the Program Manager
AMXRM-PM, Bldg. 111
Commerce City, Colorado 80022-1748
Dear Mr. Scharmann:
With the recent discovery of several additional bomblets at the Rocky Mountain Arsenal (RMA), the Environmental Protection Agency (EPA) is concerned about the health and safety of on-site workers, visitors, and nearby residents. While one such bomblet in a non-suspected area could be considered an anomaly;
discovery of several more of these bomblets causes us to reconsider as to how much is really known about the disposal and destruction practices for these chemical munitions, and how many more are waiting to be found.The military is the expert in addressing munitions and is the lead agency when remediating a Federal Facility site such as RMA. Current safety procedures for onsite workers and visitor tours have been based upon an understanding that the Army has always had a ‘healthy respect' for chemical weapons and had carefully managed all aspects of their handling from production through final disposition. However, recent statements made by the Army reflect an escalating concern related to finding additional bomblets. "At no time during this discovery and subsequent evaluation was employee, visitor, or neighborhood safety jeopardized <10/26/00>;" "National and local munitions and explosive experts have advised us that this bomblet is unstable and therefore, unsafe. Prolonging the decision to destroy this bomblet increases the risk to human life and heightens community fears in an already stressful situation <10/27/00>;" and "While discoveries like this bomblet are rare, there is the potential for more devices to be found <11/1/00>."
Relatively little information regarding Sarin munitions is discussed in the 1996 On Post Record of Decision. Section 2.1 states:
From 1950 to 1952, the Army designed and constructed the North Plants complex in Section 25 to manufacture the nerve agent GB, also called Sarin. GB was manufactured in the North Plants from 1953 to 1957, the major site for the free world's production of GB during this period. GB munitions were demilitarized in the early 1970s. One-ton containers of bulk GB, bulk VX agent, GB-filled bomb clusters, and GB-filled Weteye bombs were stored in toxic storage yards in Sections 5, 6, and 31.
The GB munitions which most likely were destroyed are those known to be stored in the toxic storage yards. EPA does not know what methods or equipment may have been used to identify munitions, such as bomblets, which had strayed from their appointed destination. Even if such a search had been conducted, it is likely to have used Schonstedt magnetometers mounted on a platform which does not have the same degree of accuracy as more recent technologies. The Army has stated that removal of metal found on the surface of Basin A after it was drained is the source of the bomblets discovered to date. Presumably, an UXO observer would have been present, as is currently required during remedial activities, and would have taken appropriate actions if UXO had been observed. It is unclear if a thorough assessment of potential UXO along the transportation routes between North Plants, Basin A, or the scrap metal yard was ever conducted. The ROD has identified small portions of section 5, 6, 19, 20, 25, 29, 30, and 32 as potential UXO (unexploded ordnance) or agent (Sarin/Mustard) areas based upon historic records. The scrap metal yard where the bomblets were found was never designated in the ROD as an UXO area and is located in an area with a high amount of traffic associated with remediation of the site.
While state-of-the-art in its day, the Schonstedt magnetometer has been evaluated to be no more than 40 percent effective at identifying munitions in the field and is most reliable in the first 1-2 feet below ground surface. This is especially disconcerting because much of RMA will be transferred to new owners. Since the time of the Schonstedt, more reliable technologies have been developed such as MTADS (Multi-Towed Array Detector System). A comparison of the Schonstedt magnetometer against the Multi-Towed Array Detector System (MTADS) technologies was conducted about a year ago at Badlands Bombing Range confirming the difference in detection capabilities between these two technologies. It would seem prudent to evaluate if munitions exist in the upper four feet of soil since Colorado's freeze-thaw cycles can push buried munitions/UXO at that depth to the surface. In areas where excavation is to occur, the evaluation must be as definitive as possible. MTADS uses several different technologies including a magnetometer, gradiometer, and electromagnetic sensors to detect anomalies. In addition to being a more effective tool for identifying munitions, an MTADS search can be performed relatively quickly and is cost-effective, ranging from $500 to $800 per acre. Although we are not wedded to using MTADS, we believe that in order to adequately address new concerns resulting from the discovery of the bomblets, the Army needs to consider reassessing parts of the site for UXO using the best available technology.
EPA credits the Army for quickly securing the first bomblet once it was discovered to contain sarin. Its placement in a protective steel canister within a Kevlar tent structure all within a tuff shed to limit the extent of exposure from a potential self-detonation has greatly reduced concerns regarding potential exposure of on-site personnel. Cancellation of visitor tours has eliminated concerns about potentially exposing this group of community members to an unnecessary risk. It is EPA's understanding that similar precautions are being put into place for the most recent bomblet finds. While EPA remains concerned about the potential risk presented by these bomblets and wishes to see an appropriate disposal resolution reached as quickly as possible, EPA is just as concerned about additional bomblets which have not yet been found and for which no protective measures have been taken. To continue remedial activities without a comprehensive reevaluation of UXO would seem to diminish the seriousness of this matter. To contemplate resuming the visitor tours, as described in the Remediation Venture Office's fact sheet, and on-site public meetings without first fully characterizing the location and extent of UXO, as well as taking appropriate precautionary measures, would potentially place members of the community in an imminently hazardous situation.
The Army's statements of their concern about the discovery of the bomblets; a lack of procedures to protect workers and on-site visitors if random chemical weapons or other UXO is found; the Army's incomplete assessment at sufficient depths or areas to determine there is not a potential chemical weapon or other UXO problem; and the potential risk from the unintended detonation of even one undiscovered bomblet requires the Parties to address this matter immediately and carefully. For these reasons, EPA recommends that all remediation activities be substantially modified or suspended until an UXO Interim Response Action (IRA) or other plan of action is completed. EPA expects that implementation of this recommendation will be coordinated with CDPHE and will be consistent with the requirements of their order. The IRA/Plan of Action should specifically evaluate the presence of munitions/UXO using the best technology available, such as MTADS, in 1) all areas for which excavation for any purpose is anticipated, 2) any property which is envisioned to be transferred to another property owner/manager, and 3) all locations in and around where munitions were handled or disposed. The IRA/Plan of Action should also include an approved disposal method for any and all munitions/UXO which are found. EPA expects that special consideration will be given for using the Explosive Destruction System (EDS) which has been demonstrated to be effective for mustard-filled munitions and which EPA understands has recently been tested with Sarin. The conduct of an UXO IRA/Plan of Action must ensure that no one, including onsite workers, visitors, and nearby community residents, are unnecessarily endangered (or potentially endangered as defined by CERCLA) by the presence of UXO.
Clearly, a comprehensive arsenal-wide assessment and response is needed. I would recommend that a meeting to discuss the development and implementation of a UXO IRA/Plan of Action be scheduled as soon as possible. While I consider this to be a Council-level topic of discussion, I recommend that the Remediation Venture Office and all regulatory parties provide technical staff at the meeting in order to expedite development of the UXO IRA/Plan of Action. Please coordinate scheduling of this meeting with Ms. Laura Williams, Team Leader for the RMA project. Her telephone number is (303) 312-6660.
Sincerely,
/signed/
Max H. Dodson
Assistant Regional Administrator
Office of Ecosystems Protection and Remediation
http://www.epa.gov/region8/superfund/sites/rma/rmasarinblt.html
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