Tooele: First CONUS chemical demilitarization facility gears up to meet operational requirements

Abstract

AbstractAmid growing concerns about weapons of mass destruction and the crisis with Iraq, the safe destruction of the U.S. chemical weapons stockpile in accordance with the Chemical Weapons Conventions is a high national priority program. Environmental requirements loom large in the successful accomplishment of this critical task. This article discusses the environmental regulatory challenges that the Army and its contractor, EG&G, had to overcome to construct and begin operations at the Tooele Chemical Demilitarization Facility (TOCDF). The first challenge was to secure the necessary Clean Air Act (CAA) and Resource Conservation and Recovery Act (RCRA) permits issued by the Utah Department of Solid and Hazardous Waste (DSHW). Another challenge was the DSHW requirement that all Class I Engineering Change Proposals (ECPs) were considered as permit changes requiring state approval. To date, this requirement resulted in 198 Class I permit modifications and the processing of more than 2,000 ECPs. Another challenge was the level of continuous regulatory and public oversight. Since TOCDF began operations, it has been subject to 42 inspections or reviews by various agencies with outside agency inspection teams on site during the first 23 weeks of 1997. The success of the Army and EG&G in reconciling environmental and treaty requirements at Tooele underscores the need for strong partnerships with state regulators and vigorous outreach efforts involving all relevant stakeholders at other chemical demilitarization facilities.