'•&       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SUBJECT:  Draft  Guidance on CT Equipment  Purchase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     To provide  draft guidance to the Regions on making decisions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formed to develop  draft Guidance on CT  Equipment Purchase.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draft guidance is  the result  of the workgroup's effort.

     When referring to CT equipment in  the  context  of  this draft
guidance,  it is meant in terms of its dual-purpose use in emergency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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                              - 4 -

       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

                               -  2  -

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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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