Pine Bluff Chemical Agent Disposal Facility (PBCDF)

Background

The Pine Bluff Chemical Agent Disposal Facility (PBCDF), located in Southeast Arkansas, 35 miles Southeast of Little Rock and 8 miles Northwest of the City of Pine Bluff, is one of several chemical demilitarization sites in the United States dedicated to the most comprehensive worldwide disarmament initiative ever negotiated. With its ratification of the Chemical Weapons Convention (CWC), the United States joined 176 other nations in a commitment to eliminate the prospect of chemical weapon warfare. The security implications of chemical weapon disarmament assure that chemical weapon demilitarization sites attract a great deal of scrutiny focused to a large extent on environmental performance.

In 1985, the U.S. Congress passed Public Law 99-145, requiring the Department of Defense to dispose of its chemical weapons stockpiles. As a result, the Army's Chemical Materials Agency (CMA), formerly known as the Office of the Program Manager for Chemical Demilitarization, was formed with the sole task of safely eliminating the entire U.S. stockpile.

The PBCDF, part of the CMA, sits on 26 acres on the Pine Bluff Arsenal (PBA) and is supported by two prime contractors, Washington Demilitarization Company (WDC) (Systems Contractor) and Science Applications International (SAIC) (government oversight and government staff augmentation) and one major subcontractor, Southwest Research Institute (SwRI) (provides on-site laboratory analytical assistance). The on-site staff number varies between 600 and 2,000 personnel depending on the current phase of the project. PBCDF's mission is "to safely and effectively dispose of the stockpiled chemical warfare materiél located at the Pine Bluff Arsenal, while ensuring maximum protection of the public, the workers, and the environment."

On October 11, 2002, Mr. Delbert Bunch, Deputy Program Manager for the Chemical Materials Agency, presented the PBCDF and WDC an Army award for successfully completing self-certification requirements to establish an ISO 14001 Environmental Management System (EMS). According to a PBCDF press release from Ms. Ann Gallegos, PBCDF Public Affairs Officer, during the award ceremony, Mr. Bunch explained, "…the efforts are exceptional, especially because the conformance is not subjective. It is testimony to the excellent leadership of Randy Long (PBCDF Site Program Manager) and Dan Swaim (then Project General Manager for WDC) and the overall performance of the PBCDF team."

The "fenceline" for the EMS program consists of all PBCDF operations including contractor and temporary personnel.

The Systems Contractor (WDC) and its on-site subcontractors and suppliers are the only PBCDF entities audited under the EMS. The on-site CMA (Prov.) government offices, while they actively support and endorse the EMS effort, are not included in the audit program.

EMS Drivers

Aside from a proactive environmental management philosophy, the two major drivers for implementing the PBCDF EMS include first, Executive Order (EO) 13148, "Greening the Government Through Leadership in Environmental Management," and second, Washington Demilitarization Company's own Best Practices Initiative. The promulgation of EO 13148 encouraged additional and very active support from senior staff at CMA (PMCD).

Support from local management was a result of the many obvious advantages of the ISO 14001 EMS program. These advantages have manifested as savings to date approaching $60,000 from a white paper recycling initiative and a program to reduce on-site inventory of oils and lubricants from more than 470 different products to possibly fewer than 10 by using multipurpose synthetics which meet the manufacturer's specifications with annual cost savings anticipated to exceed $250,000. These environmental improvement projects stemmed directly a series of brainstorming sessions conducted to identify and analyze the aspects and impacts central to an ISO 14001 EMS.

As the advantages of the EMS continue to manifest, support continues to grow. Changes in management (command) at both PMCD and WDC have not affected support as much as have the changes in management priorities. As PBCDF moves through the various phases of its lifecycle, from construction (completed in November 2002), to systemization (prove-out), operations, and finally closure, the focus of management necessarily changes; resulting in priorities competing for management attention and support. With the EMS becoming more ingrained in the PBCDF culture every day, it naturally requires less management attention than other emerging or rapidly changing activities; this is as it should be. Management support for the EMS at PBCDF has never waned.

Staffing and Training

PBCDF's ambitious six-month EMS development and implementation schedule required approximately two local personnel full-time and assistance from the CMA EMS visiting team. The cost of developing an EMS was over and above normal costs - in the case of PBCDF, in-house resources were used. Although required to have an EMS, PBCDF is not provided a separate budget line item for its development, implementation, or maintenance. Active support at both the local and program levels facilitated overcoming this obstacle. The ongoing EMS program requires one full-time person responsible for document maintenance and the preparation and conduct of periodic internal audits. Support from CMA EMS visiting teams is available for the surveillance audits.

At PBCDF, "EMS Initial Awareness Training" is conducted by the WDC Training Department as part of its Annual Refresher Training (ART) Program. Training programs are based on information and lesson plans provided by the WDC Environmental Department. All personnel including temporary and subcontractors are trained when they arrive on site.

Job-specific training is based on the training and refresher requirements of the employee's specific job description and the training path as developed by the WDC Training Department. The department has environmental professionals on staff. A program of instruction tailored specifically to each job or position defines the initial and refresher training requirements.

Significant Impacts

PBCDF identified the Deactivation Furnace System (DFS) Operations, Liquid Incinerator (LIC) Operations, and the on-site, subcontractor operated, laboratory as known potential impacts. The DFS, LIC, and Laboratory were not yet fully operational at the time of EMS Objective and Target development. When known potential impacts of their operation were identified and objectively scored during the aforementioned brainstorming sessions, their Aspect and Impact scores put them in the significant category. At this writing, DFS and LIC are in cure and shakeout operations, but are not yet operationally stable enough for the valid assessment necessary to identify possible areas for improvement.

Under the provisions of ISO 14001, it is permissible not to set Objectives and Targets from a significant area if it is in control and if the significant area is "considered." PBCDF thus developed other proactive Objectives and Targets with commitments to pollution prevention (P2) activities and environmental stewardship.

Current Goals and Objectives

PBCDF targeted its paper recycling program (Attach file pinebluff_aspect_whitepaperpdf) and its oil/lubricant reduction program (Attach file: pinebluff_appect_hydraulics.pdf) as part of its EMS program. These were incorporated into the EMS and ISO 14001 Environmental Management Programs (EMPs). Additional EMPs in the initial implementation of the EMS included Old Corrugated Cardboard (OCC) and white paper reduction (see attachments)

Metrics and Continuous Improvement

To date, as PBCDF enters the systemization phase of its lifecycle, there have been no noncompliances and only one (administrative) Notice of Violation. PBCDF has realized quantifiable savings approaching $60,000 to date from the recycling of white paper alone. Other recycling programs include OCC , and consumer aluminum. Contracts were recently issued for recycling scrap metals and other recyclable industrial scrap.

Cost Savings

PBCDF saved nearly $30,000 in the first year of its white paper recycling program. A monthly breakdown (Link to pinebluff_paper_savings.doc) provides further information on the costs and benefits of this recycling program's first full year.

Significant Challenges

The ambitious development and implementation schedule was the most significant challenge at PBCDF. The challenge was met through the use of an electronic EMS implementation tool-prism esolutions' equationASP-(underwritten through the good offices of CMA) which helped streamline the implementation and auditing process and kept the EMS development and implementation on schedule. All departments willingly pitched in and provided technical experts, materials, and time from their respective budgets as it was required. When this was impossible, the WDC Project General Manager's discretionary budget provided funds, as in the case of the White Paper Recycling Initiative, and WDC "Corporate" expressed a willingness to provide funds if necessary.

WDC has a slogan, "The Washington Way" meaning one Company, one Team, whatever it takes to get the job done. PBCDF, CMA, and WDC certainly formed one team with a common vision and a cooperative willingness to get the job done. It worked.

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