'& UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
1 WASHINGTON, D.C. 20460
April 22, 1998
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Draft Guidance on CT Equipment Purchase
FROM: Mark L. Mjoness, Senior Process Manager
Office of Emergency and Remedial Response
TO: Removal Managers, Regions I-X
Regional CT Program POC
Director, ERTC
PURPOSE:
To provide draft guidance to the Regions on making decisions
for selecting and purchasing counter-terrorism (CT) equipment for
their use. As stated in the Memorandum of March 27, 1998, from the
Director, Chemical Emergency Preparedness Office, each Region and
the Environmental Response Team Center (ERTC) were given an
allocation of funds for FY 98 CT initiatives. One recommended use
of the allocated funds is the acquisition of equipment to enhance
Regional CT response capabilities.
DISCUSSION:
A workgroup of Regional, Environmental Protection Agency (EPA)
Headquarters (HQ), ERTC, National Enforcement Investigations Center
(NEIC), and other Federal agency personnel, in consultation with
EPA's Counter-Terrorism Program Coordination Team (CTPCT), was
formed to develop draft Guidance on CT Equipment Purchase. This
draft guidance is the result of the workgroup's effort.
When referring to CT equipment in the context of this draft
guidance, it is meant in terms of its dual-purpose use in emergency
response, as well as in response to a terrorist incident. The
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following three steps are recommended for prioritizing, selecting
and purchasing Regional CT equipment:
Step # 1; Regional Equipment Assessment. For a definition of
CT equipment, please refer to Attachment 1, Recommended
Regional CT Equipment List. As a first step, the Region
should assess its current inventory of CT equipment and other
emergency-response related equipment. Such an assessment
includes the immediate availability of CT equipment either
through our EPA in-house assets or through our Regional
support contractors. Completing the equipment assessment will
provide the Region with a Regional CT equipment inventory
list, which should be used as the basis for making decisions
on the acquisition of additional CT equipment by the Region.
Please be advised that the equipment assessment should be
performed in conjunction with assessing- the readiness of
Regional emergency response personnel in meeting requirements"-
for physical health, safety and equipment training, and clear-
ances for CT response. Guidance on personnel qualifications
and EPA's role in CT response fall outside the scope of this
draft Guidance on CT Equipment Purchase.
Also factored into this Regional equipment assessment
should be response resources that may be provided by other EPA
or non-EPA resources which are available to the Region within
a reasonable response time for responding to a CT event, i.e.,
local, State, ERTC, NEIC, U.S. Coast Guard Strike Teams,
Office of Radiation Programs resources, Office of Research and
Development laboratories or other Federal resources (i.e.,
DOD, or other Federal Agencies). If those other resources
outside the Region's emergency response program are not truly
available within a reasonable amount of time, they should not
be 'relied upon in an actual CT event.
Step # 2: Equipment Priority and Selection. Before beginning
the process of selecting CT equipment, it is essential that
the Region has access to a sufficient number of Level-A
Personal Protective Equipment f?PE) for its cadre of emergency
response personnel either through in-house (EPA or non-EPA as
discussed above) or contractor assets.
If the Region does not have access to Level-A PPE, the
first priority should be to purchase or assure the
availability of adequate quantities of Level-A PPE for
Regional or contractor emergency response personnel. If the
Region has sufficient quantities of Level-A PPE, it may chose
CT equipment it deems essential for its use from the
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Recommended Regional CT Equipment List (see Attachment 1) or
other CT-related equipment for which adequate justification
exists.- Such justification for CT equipment, which is outside
the scope of Attachment 1, should be maintained in Regional
files and does not require consultation with HQ.
As described in Attachment 1, the Recommended Regional CT
Equipment List consists of three categories of equipment as
follows: (1) Personnel Protection; (2) Monitoring Instru-
ments; and (3) Additional Equipment. Due to the expense of
most of the items listed in the Additional Equipment category,
we recommend that the Regions communicate with their neigh-
boring Regions, ERTC, and other Federal agencies to determine
whether such equipment is already available or accessible. If
the Regions maximize their equipment needs by assessing
available sources beyond their own equipment inventory, we
will be more successful in using the small amount of CT
i
equipment funds in the most cost effective and efficient
manner,
Step # 3: Procurement. CT equipment procurement options in-
clude the following:
Small purchase at Regional level
« Purchase by Regional START or ERRS contracts (special
justification for contractor equipment purchase should be
coordinated with OERR's Contracts Management Center and
the Office of Acquisition Management)
HQ procurement, i.e., small purchase or IAG with another
Federal Agency (FEMA, GSA)
HQ-coordinated military purchase through CBDCOM
IMPLEMENTATION:
Due to the short time remaining for obligating CT funds in
FY 98, it appears that the only viable options will be for the
Regions to either purchase their CT equipment via small purchase or
to make it available through their Regional support contractors.
Please note that the Regions should take actions to ensure
obligation of their allocated PY 98 funds for CT initiatives before
the end of the fiscal year. We also would like to stress that it
is essential that the Region has a mechanism for providing periodic
maintenance, as necessary, for equipment which needs to be
maintained, upgraded and calibrated.
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In FY 99, HQ will explore the option of purchasing bulk
quantities of CT equipment through an appropriate HQ procurement
mechanism. This option will be more time consuming because infor-
mation on bulk CT equipment will need to be collected firsr from
the Regions prior to transferring the Regional CT allocation. By
purchasing CT equipment in bulk, i.e, PPE suits, gloves, boots,
etc., rather than via individual small purchases, we believe the
Agency will incur greater savings in the cost of CT equipment:.
Please provide your comments or suggestions on the draft
guidance to me no later than May 15, 1998. We will consider your
input before we issue it as interim guidance. For more information
or questions regarding the draft Guidance on CT Equipment Purchase,
please contact me at 603-8727 or Hans Crump at(703)603-8821 or by
E-mail.
Attachment
cc: Steve Luftig, OERR
Elaine Davies, OERR
Jim Makris, CEPPO
Ken Stroech, CTPCT Chair
Superfund Directors
Regional CEPP Coordinators
Regional Radiation Program Managers
OERR Center Directors
Craig Conklin, OIRA
CTPCT Members
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ATTACHMENT 1
PERSONNEL PROTECTION
LEVEL "A" RESPONSE PERSONAL PROTECTIVE EQUIPMENT - MSA Inc.,
Pittsburgh, _PA £800) MSA-2222, cost $4,000.00. MSA CHEMPRUFF II
TOTAL-ENCAPSULATING SUIT (Betex) - This suit permits the wearer to
use breathing air from either an SCBA or from an air-line system up
to 300 feet long. The Betex suit is constructed using a three-
layered fabric, beginning with a supporting subscrate fabric made
from polyester. The inside is coated with black neoprene and the
outer layer is coated with orange butyl rubber. Permeation testing
results for this suit are available for 598 compounds, as provided
in a chemical resistance guide. In general, butyl rubber resists
degradation by many contaminants, except halogenated hydrocarbons
and petroleum compounds.' Neoprene resists degradation by caustics,
acids and alcohols. GEOMET RESPONDER CSM COMPLETELY ENCAPSULATING
CHEMICAL SUIT - GEOMET Technologies Inc., cost $1,000,00. The suit
is constructed of a patented material designed to provide a high
degree of permeation resistance to a wide range of chemicals. It
affords protection against petroleum products and halogenated*
hydrocarbons, as well as against nerve and blister agents. These
suits are designated as limited use, therefore they are not
decontaminated following exposure to a hazardous environment but
are discarded. It has an expanded back to accommodate an SCBA, but
does not have a pass through to allow for use with a supplied-air
respirator.
LEVEL "B" PERSONAL PROTECTIVE EQUIPMENT - TYVEK/SARANEX 23-P HAZMAT
RESPONSE SUIT - GEOMET Technologies, cost $125.00. This is a fully
encapsulating Level-B suit which provides for additional splash
protection. The garment has an expanded back and rear zipper to
accommodate an SCBA. The use of a chemically resistant film on
Tyvek provides a high level of permeation resistance to many
chemical substances. The suit construction includes elastic wrists,
attached booties, a PVC face shield and exhaust pores.
MONITORING INSTRUMENTS
CHEMICAL AGENT MONITOR - ETG., Baltimore, MD (410) 321-5270, cost
$5,000.00. The CAM is a portable, hand-held instrument designed to
determine and indicate the hazard from nerve or mustard agent vapor
in the air. The. CAM can be used to search cut clean areas,
identify contaminated materials and monitor the effectiveness of
decontamination. The CAM responds to nerve and mustard agent
vapors down to the lowest concentrations that could affect
personnel over a short period.
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DRAEGER TUBES - National Draeger Inc., Pittsburgh, PA (412) 787-
8383, cost $80.CO/box. Draeger tubes are colorimeteric tubes used
to detect chemical warfare agent. Draeger tubes are designed to
monitor for various type of nerve agent, blister agents, lung
agents, blood agents, and nose and throat irritating agents.
CHEMICAL AGENT DETECTOR KIT H256A1 - GEOMET Technologies Inc. ,
Germantown, MD (301) 428-0898 cost $250.00. The chemical agent
detector kit can detect nerve agents (G and V) , blood agents (AC
and CK}, blister agents (H, HD, and CX), and Lewisite.
CHEMICAL AGENT DETECTOR PAPER VGH, ABC-M8 - GEOMET Technologies
Inc., cost $520.00. This paper detects liquids only, nerve agents
(G and V) and blister agents (H).
MINIRAE PLUS - Gen-el Industries, Denville, NJ (201) 627-8300, cost
$4,000.00. The MiniRAE is a portable, hand-held, microprocessor
controlled instrument designed for measuring the presence of photo
ionizable chemicals in air at part per million levels. The MiniRAE
can detect thousands of different type of airborne gases and
vapors. Its response depends on the chemical type as well as the
concentration. The MiniRAE does not distinguish one type of
chemical from another, but displays a number indicating the total
concentration of all photo ionizable compounds in the sample.
PhD ULTRA MULTI GAS DETECTOR - Biosystems Inc., Middlefield, CT
(203)344-1079, cost $2,500.00. The PhD Ultra is a portable, hand-
held, microprocessor controlled instrument designed for monitoring
up to four atmospheric gas hazards simultaneously. The PhD Ultra
can be operated in either a "Diffusion" or "Sample-Draw" mode. The
PhD Ultra uses highly specific, electrochemical toxic sensors that
have been designed to minimize the effects of common interfering
gases. Toxic sensors available for use in the PhD Ultra include
hydrogen sulfide (H2S), carbon monoxide (CO), sulfur dioxide (S02) ,
chlorine (C12) , hydrogen cyanide (HCN), ammonia (NH3) , nitric oxide
(NO), and nitrogen dioxide (N02) .
RADIOLOGICAL SURVEY METERS - Ludlum Measurements Inc., Sweetwater,
TX (915) 235-5494 , cost $2,500.00. Ludlum 19 /iR/hr meters measure
gamma radiation. An alternative to the Ludlum Model 19 is the
Bicron Micro-Rem instrument. We recommend that every Region should
have, at a minimum, a Ludlum Model 19 or Bicron equivalent. For
more information on trade-offs and precautions between these
instruments, please see contact provided below.
Eberline and Ludlum make fine mid-range instruments which are
capable of supporting multiple probes, such as the Eberline E-520
and Ludlum Model 14c. The recommended gamma probe is the Eberline
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HP-270 "Energy Compensated GM Probe" and the recommended pancake
probes are the KP-21Q and HP-260 or a similar one made by Ludlutn.
Ludlum 12 count rate meter measures alpha, beta, or gamma
radiation, depending on probe. Eberline and Bicron also make good
count rate meters. Recommended probes include the above GM and
pancake probes and either an Eberline or Ludlum alpah scintillation
probe.
Recommended high range instruments include the Eberline RO-2A, and
Ludlum makes a similar instrument.
For weapon accidents, the Regions should consider the FIDLER probe
(Field Instrument for Detection of Low Energy Radiation) to measure
low energy gamma radiation. We recommend the FIDLER probe from
Bicron, coupled with an Eberline ESP-2 which is a larger
radiological instrument (calibrated according to HOTSPOT computer
code).
*
The Radiation and Indoor Environments National Laboratory, Las
Vegas, NV, Office of Radiation and Indoor Air, has offered free
calibration services to the Region radiation programs. However,
it does not perform calibration for EPA contractors. At a minimum,
probes and instruments should be calibrated at one year intervals,
records must be kept, and only alkaline batteries should be used in
the instruments. Eberline, Ludlum and Bicron have on-line catalogs
that can be accessed via Internet at the following web sites:
» Eberline at http://www.eberlineinst.com;
Ludlum at http://www/ludlums.com; and
* Bicron at http://www.bicron.com.
The on-line catalogs have detailed descriptions and pictures. All
three companies are on GSA schedule. The Regions should avoid
cheap quality equipment and not use old, unreliable Civil Defense
equipment (CDV-700 and CDV-715) because it may be free. For more
information regarding the radiological survey meters, please
contact your Regional Radiation Program Manager or Gregg Dempsey,
Director, 'Center for Environmental Restoration, Monitoring and
Emergency Response, Radiation and Indoor Environments National
Laboratory, Las Vegas, NV, (702) 798-2461,
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ADDITIONAL EQUIPMENT
PORTABLE ISOTOPIC NEUTRON-SPECTROSCOPY CHEMICAL ASSAY SYSTEM (PINS)
- EG&G ORTEC, Oak Ridge, TN (800)251-9750, cost $100,000,00. The
PINS uses neutrons from a small moderated source. The neutrons
pass through the wall of the container and collide with the atomic
nuclei of the contents. The ensuing nuclear reactions produce
gamma rays, which when appropriately detected and recorded, produce
a gamma spectrum. The gamma-ray spectrum peaks are found at
channel numbers corresponding to energies associated with specific
nuclear deexcitations characteristic of the chemical element
concerned. The relative heights of the peaks are related to the
ratios of the elements inside the container. These energies are in
themselves uniquely characteristic of the contents of the con-
tainer, whether high explosive, nerve gas, or other.
MINICAMS MODEL FM-30QO- CMS Research Corporation, Birmingham, AL
(205)733-6900, cost $26,000.00. The MINICAMs is- a gas chromato-
graph fitted with a flame ionization detector (FID), flame photo-
metric detector (FPD), or a photo ionization detector (PID). The
FPD is very selective for phosphorus and sulfur containing com-
pounds, such as chemical warfare agents.
ZELLWEGER ANALYTICS SPM - Zellweger Analytics, West Chester, PA
(800)323-2000, cost $5,000,00. The SPM TAPEMETER uses a chem-
cassette detection system to monitor for specific toxic airborne
gases. There are a wide variety of compounds which can be detec-
ted. Detection limits and sample time vary depending on the com-
pound .
GAS CHROMATOGRAPH/MASS SPECTROMETER (GC/MS) - Viking Instruments,
Chantilly, VA (703) 968-0101, cost $155,000.00. The Viking
SpectraTrak 620 is a transportable, multicomponent system consis-
ting GC/MS and a data system housed in a rugged case. The Viking
is based on the Hewlett-Packard 5971A mass selective detector.
Tekmar model 4000 Dynamic Headspace Concentrator, a purge and
trap unit with a Supelco* VOCarb 3000 adsorption trap, and an
adapter allows air or soil gas samples to be introduced and
analyzed for VOCs with typical detection limits of 2-10 ppbv.
For information or technical advice on other than radiological
survey meters, please contact Dave Mickunas, Environmental Response
Team Center, Edison New Jersey, (732) 906-6913, or by E-mail.
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