Disposal of Neutralent Wastes: Review and Evaluation of the Army Non-Stockpile Chemical Materiel Disposal Program (2001)

Based on the preceding evaluation, site visits, discussion with stakeholders, and information gathered from presentations and other sources, the committee developed a number of findings and recommendations.

Finding. The committee did not find any experimental studies on the destruction of neutralent wastes generated by the RRS or MMD. Therefore, the analyses of candidate technologies are based on their demonstrated performance with chemically similar materials, as well as on fundamental principles of chemistry and chemical engineering.

Finding. Based on the amount of neutralent expected from planned operations at Deseret Chemical Depot and Dugway Proving Ground, the volume of neutralents generated by the RRS and MMD is expected to be relatively small—on the order of 5,000 gallons per year in normal operation. As a point of reference, a standard tanker truck contains 5,000 to 10,000 gallons, and a railcar may contain as much as 30,000 gallons. Because the facility for disposing of neutralent will not have to handle large volumes or have a high throughput, it could be a laboratory or pilot-plant-scale facility. Thus equipment for technologies currently under investigation for stockpile CWM might be used cost effectively for treating nonstockpile neutralents. At this small scale, all of the technologies reviewed by the committee could be adapted to “ semi-fixed, skid-mounted” configurations (see Statement of Task).

Finding. The committee identified some low-temperature, low-pressure, less complex technologies that might be used to treat neutralent waste. The benefits of these technologies over incineration include low worker risk, public acceptance, low risk to the surrounding community, and simplicity of operation.

Finding. The Army's evaluation of alternative technologies must meet the time constraints of the CWC, which requires that all nonstockpile CWM in storage at the time the convention was ratified be destroyed by 2007. Thus far, no alternative incineration technologies have been tested on real, or even simulated, nonstockpile neutralent generated by either the RRS or the MMD. Therefore, bench testing and scale-up demonstrations of candidate technologies with neutralents will be necessary. Because testing the effectiveness of alternatives and determining regulatory limits will take time, the Army may have to fall back on its current incineration strategy for the destruction of neutralent, which includes the use of commercial incinerators, or even the use of the Army' s stockpile incinerators.

Finding. Some of the candidate alternatives to incineration for destroying MMD and RRS neutralents involve hardware that has already been developed, and using them would simply require substituting neutralent for existing feeds. For example, one or more of the demonstration units tested for the chemical disposal programs (e.g., ACWA Program) might be used. Because the volume of nonstockpile neutralents will be small, even if the technology is not rated highly according to the committee 's criteria but is inherently safe, the savings in time and development costs might justify consideration of this alternative. Demonstration units could be used at their present sites or moved, either as needed or to a mutually agreeable location based on a plan developed with the affected communities and regulatory authorities.

Recommendation. The Non-Stockpile Chemical Materiel Program should pursue a two-track strategy similar to the one adopted by the committee during its selection of a technology: (1) an evaluation of the potential of Assembled Chemical Weapons Assessment demonstration technologies and mature commercial technologies; and (2) technologies that would require further development and investment.

Recommendation. As part of the track-one strategy, the Army should take advantage of available equipment that would require little or no investment (i.e., either alternative technologies from the Assembled Chemical Weapons Assessment [ACWA] Program or existing commercial technologies, such as chemical oxidation, wet-air/O₂ oxidation, or PLASMOX^®). The following technologies from the ACWA demonstrations should be considered: electrochemical oxidation Ag(II), gas-phase chemical reduction, solvated-electron technology, and supercritical-water oxidation. If any of these can accomplish the task safely, it might provide a relatively rapid and inexpensive course of action.

Recommendation. If Assembled Chemical Weapons Assessment (ACWA) or the commercial technologies require substantial modifications to processes or permits, the Army should focus first on the most easily adaptable commercial technologies (i.e., chemical oxidation and wet-air/O₂ oxidation). Only if these technologies prove to be unsuitable should the Army consider investing resources in the further development of ACWA technologies (listed below in order of preference):

• electrochemical oxidation with Ag(II) and Ce(IV) ¹

• supercritical-water oxidation

• solvated-electron technology

• gas-phase chemical reduction

• plasma-arc technology

Recommendation. The Army should not invest in further development of biodegradation, which was judged least likely to be effective.

The recent experience of federal agencies has shown that the involvement of diverse public groups (including state and federal regulators) is crucial to timely decision making. Stakeholder involvement is particularly important for decisions involving analytical, engineering, or other scientific uncertainties about the protection of human health and the environment. The Army's implementation of an alternative technology or technologies to incineration could be delayed unless regulatory requirements have been developed and the public has been involved in the decision-making and selection process.

The NSCMP could improve its existing public involvement program by (1) exploring ways to ensure representation of diverse public groups in assessments of disposal technologies and associated regulatory issues; and by (2) working closely with potential host communities to identify and address their concerns.

A comprehensive regulatory compliance plan that involves all stakeholders could be essential to the timely implementation of an alternative technology. An environmental criteria working group, with representatives of the Army, EPA regulators, state regulators, officials of the U.S. Department Health and Human Services, public interest groups, and citizens at large, could be formed to undertake advanced planning with the goals of (1) ensuring that substantive regulatory requirements can be met and (2) determining if additional testing or evaluations will be necessary to satisfy public or regulatory concerns.

Finding. Citizens groups that met with the committee strongly urged that the Army consider the long-term storage (i.e., longer than one year) of neutralents rather than incineration. Storage, they argued, would ensure that the Army would have sufficient time to develop, test, and obtain regulatory approval of alternatives to incineration. The committee believes that the Army's mission could be affected by the manner in which it responds to these public concerns.

Finding. The Army provided several reasons for not storing neutralent. First, storage might make it impossible to meet the treaty deadlines for the destruction of the non-stockpile chemical weapons. Second, the Army might be required to meet rigorous, long-term environmental requirements. Third, long-term storage would be inconsistent with regulatory requirements limiting storage time for hazardous wastes. Finally, the cost of storage might be disproportionately high.

Recommendation. To solicit public understanding, and perhaps acceptance, in its decision on whether or not to store neutralent, the Army should issue a detailed white paper explaining the legal, scientific, regulatory, and institutional issues involved. The paper should explicitly describe how risk to the public and workers would be affected by the long-term storage of neutralent prior to its disposal.

Finding. The committee's discussions with citizen groups indicated a need for, and the value of, public involvement in the Army's decisions conceming the selection, deployment, and employment of technologies for disposing of non-stockpile chemical materials.

Recommendation. The committee recommends that the Army expand its public involvement program regarding disposal of nonstockpile chemical materiel. Enough time should be scheduled and enough resources allocated to ensure that the decision-making process is open and that members of the public are involved in determining trade-offs related to the selection, siting, deployment, and employment of disposal technologies.