In October 2001, scarcely one month after the attacks of September 11, the United States faced another unprecedented act of terrorism. This time, multiple letters laced with anthrax were mailed across the country. By the time the first days of the incident ended, several people lay dead and numerous others had sustained serious injuries. To this day, the culprit(s) remain at large and law enforcement officials seem no closer to solving this crime as they did when it was perpetrated.
To the Department of State, however, catching the responsible parties behind the nation’s worst bioterrorism event was not a priority; repairing the damage it caused was. One of the hardest-hit mail-handling facilities was State Annex 32 in Sterling, Virginia, a sorting, collection and distribution point for U.S. mail and parcels destined for and sent from U.S. embassies abroad. It was through this facility that an anthrax-tainted letter was sent to then-Senate Majority Leader Tom Daschle, contaminating State Annex 32 in the process.
The facility consisted of a leased, 70,000-square-foot warehouse, which contained flat sorters, parcel sorters, rolling stock, cabinets and large quantities of other electronic equipment. It took 80 employees to keep the facility running, but once the presence of anthrax was detected, the annex was immediately closed and secured, and alternate mail operations were established at another facility.
As the agency responsible for the safe clean-up of State Annex 32, the Department of State gave the job of overseeing and planning for the decontamination and rehabilitation of the building to its Office of Real Property Management and Project Manager Tom Sgroi.
Getting Organized
Cleaning up the facility would require an intensive effort by a large, cross-functional, cross-organizational team. To that end, Sgroi established a project management structure to plan and implement the cleaning of the facility. A Technical Working Group (TWG) of public health experts was established to serve in an advisory capacity to Sgroi. The TWG spanned a number of organizations, including the Environmental Protection Agency (EPA), the Centers for Disease Control, the U.S. Army, the Occupational Safety and Health Administration, several private companies and local and state government agencies, such as the Virginia Department of Environmental Quality, Loudoun County Fire and Rescue and the Loudoun County Board of Supervisors. At the beginning of the project, Sgroi and his team met with the Board of Supervisors to discuss its plans. As the project progressed, the team updated the board at various town hall meetings and board meetings.
In addition, subcommittees of the TWG were established to guide the project in matters of waste disposal, fumigation, air monitoring, environmental sampling, emergency preparedness, equipment disposal and salvage and communication.
Finally, an Environmental Clearance Committee (ECC) comprised of public health experts was established to review the overall process and make a recommendation to the Department of State on the suitability of the building for re-occupancy. To avoid conflicts of interest, ECC members were not involved in the planning and decision-making of the clean-up efforts.
Cleaning House
Early in the project, Sgroi’s team decided to remove and dispose of all porous (i.e., carpets, cleaning tiles, etc.) and noncleanable items and to fumigate the building. During the waste disposal process, the team compared the cost of cleaning the annex’s equipment—with special consideration paid to sampling and refurbishing costs—to the cost of equipment replacement.
Ultimately, Sgroi decided to dispose of the building’s contents rather than to salvage them because the annex’s electronic and mail-handling equipment proved extremely difficult to clean. The electronics equipment had casings that needed to be opened and many small parts with cracks and crevasses. Mail-handling equipment often uses exposed ball bearings that are difficult to clean. As a result, the cost of cleaning this gear outweighed the cost of simply replacing it, so the decision was made to discard the building’s contents. More than 400 tons of materials, supplies and machinery were removed from the facility and incinerated, steam-sterilized or cleaned by ethylene oxide.
According to Sgroi, the amount of materials that had to be thrown away was a lot more than initially planned. “You try to save everything you can,” Sgroi says, “especially if the numbers for clean-up and replacement are close.” Despite these initially ambitious salvage plans, Sgroi says that he learned a valuable lesson to keep one’s eyes open for unexpected developments, costs and potential impediments to achieving the project’s ultimate goal of making the facility safe for re-occupation.
The next step was fumigating the facility. Upon completion of the waste disposal efforts in May 2003, Sgroi’s team mobilized the fumigation equipment to the site. Partitions were constructed inside the building to divide it into seven smaller zones. Fumigation occurred in June and July of 2003. Environmental sampling began upon completion of the fumigation and was completed in October.
“During our waste disposal efforts,” we worked with our fumigation subcommittee to establish our fumigation selection factors and select the fumigant best suited for our needs,” Sgroi says. “We considered vaporized hydrogen peroxide (VHP), chlorine dioxide and paraformaldehyde. We determined that vaporized hydrogen peroxide was the best fumigant for our requirements.”
Ultimately, VHP was deemed to be the best fumigant for the project for a number of reasons. Primarily, it has a demonstrated efficacy for killing anthrax, having been used in the past to remediate facilities exposed to anthrax (such as government laboratories). Secondly, the agent posed little risk to the surrounding community. If left to disperse, VHP breaks down into its component parts—water and oxygen. And thirdly, the vendors through which the Department of State would obtain the VHP were experienced with the agent and could independently verify that it was the right agent for the job. “We didn’t want to be a research project,” Sgroi says.
Although VHP was the agent for the job, it had never been approved by the EPA as a fumigant, so Sgroi needed to get special permission to use it. He presented his case to the EPA’s Crisis Exemption program, noting that his clean-up project was unique and that there were no registered fumigants designed to kill anthrax, so he needed to use the best agent at his disposal. And, given the urgency of his mission, something needed to be used immediately.
After Sgroi presented evidence that VHP killed anthrax in lab tests, that it had varying “kill loads” of efficiency (and therefore the quantities used could be varied), and that it posed no serious threat to the surrounding community, the EPA granted him emergency permission to use the agent in the clean-up. But VHP remains officially unregistered by the EPA as an anti-anthrax fumigant, Sgroi notes. Were a similar bioterrorism event to occur, whoever is responsible for facility remediation would have to go through the same crisis exemption process before using VHP.
Fumigating the facility proved to be easier said than done. Since fumigating a 70,000-square-foot warehouse is quite different than fumigating a small laboratory, the scaling up of VHP equipment, compatibility with building materials and fumigant distribution were major challenges. “Our problem-solving consisted of identifying what wasn’t working, understanding why it wasn’t working, and making system changes such as increasing system capacity and improving airflow distribution to overcome the problems,” Sgroi says.
This methodology proved useful when Sgroi’s team tackled the problem of air distribution within the facility. Sgroi needed clean air to be circulating within each enclosure of the facility, but making sure the duct system worked proved troublesome. Because there were variations in air distribution throughout the system, accurately gauging the level of contaminants present was very difficult.
To address the problem, he set up sensors in the ductways so his team could get immediate air quality readings to pinpoint trouble areas on the go, rather than commit to a time-consuming cycle of fumigating, testing and re-fumigating. Using these sensors, Sgroi could determine the nature of differing air densities in the ductwork and evaluate the air quality of the system. Sgroi says that looking back, it was a fairly straightforward problem to solve, but the challenge was to address it while keeping the rest of the clean-up efforts underway, and figuring out the best ways to change the facility’s air distribution, whether that required improving air circulation, layout or the ductwork.
Zero Tolerance
Fortunately for Sgroi, the immediacy of the task at hand caused no organizational problems. “Since we established temporary operations at another location, our efforts were not schedule-driven. They were performance-driven,” Sgroi says. Despite the pressing need to sanitize the facility, Sgroi was committed to a deliberate approach that ensured the health and safety of the annex employees, the surrounding community and those performing the decontamination work.
Since there are no public health standards for acceptable levels of anthrax, the clean-up team set its standard for success at zero growth of anthrax for all environmental samples. Upon completion of environmental sampling and fumigation, reports were provided to the ECC in late October. The ECC would then make its recommendation to the Department of State regarding the suitability of the building for re-occupancy.
Given that all of the post-cleanup environmental samples from the site have come back negative for anthrax presence, Sgroi is confident that the building will be re-opened. In the event that it is not, however, Sgroi is ready to ask the ECC why the building is still considered unsafe and what remediations would have to be undertaken to lower the risks still present. For Sgroi, this project will not be over until State Annex 32 is re-opened for business.
Measures of Success
“Our biggest success was the collaborative efforts of all the federal, state and local government officials and private industry players. Their guidance gave us confidence in our decision-making,” Sgroi says of the clean-up project, now that the main remediation phase has ended.
The teaming of the U.S. Army Corps of Engineers and the EPA also significantly added to the success of the project, according to Sgroi. The Department of State commissioned the U.S. Army Corps of Engineers Rapid Response program to manage the waste disposal and fumigation of the building. The EPA managed the air conditioning during fumigation and the post-decontamination environmental sampling.
The early decision to remove the contents from the building gave Sgroi’s team time to take on a deliberate sort of fumigation selection, equipment fabrication and regulatory approval (such as obtaining the EPA’s Crisis Exemption for using VHP).
“Regarding communication with the employees, local officials and the community, we believe that by communicating project details early in the process and by frequently giving updates through town hall meetings and information meetings, everyone was informed on what we had done and what we were accomplishing,” Sgroi says. That communication, he adds, proved to be a key factor in making the remediation effort speedy and efficient.
Lessons Learned
“As part of the design for the renovated mail facility, we will incorporate mail screening and containment areas with special engineering controls, such as ventilation and exhaust systems, with the intent of providing improved protection to mail-handling employees,” Sgroi says. “Additionally, this should limit the extent of contamination in the event of a future attack.”
Sgroi says that there has been a great deal of technical collaboration between all of the project’s experts, resulting in detailed work plans and health and safety plans. Knowing the responsibilities of the various agencies and having these documents for reference will significantly benefit any similar clean-up operations in the future.
“Even though we might not have taken the lowest-cost approach, I believe that we have taken the best-value approach to cleaning this facility,” Sgroi says. “We had confidence in the people working on the project. We then built confidence into the technical process by making decisions like removing the contents of the building. This allowed us to make timely decisions in a planned manner.”
Thomas J. Sgroi is project manager in the Office of Real Property Management at the Department of State in Washington D.C.
Bill Coffin is editor in chief of Risk Management Magazine.
