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THE NATIONAL ACADEMIES

Advisers to the Nation on Science, Engineering, and Medicine

National Academy of Sciences

National Academy of Engineering

Institute of Medicine

National Research Council

Board on Army Science and Technology

Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program

December 21, 2001

Mr. James Bacon

Program Manager for Chemical Demilitarization

PMCD SFAE-CD-CO-O Building E4585 Aberdeen Proving Ground, MD 21010–4005

Re: Review of Proposed Process Changes for Expedited Disposal of the Newport Stockpile of Bulk VX Nerve Agent

Dear Mr. Bacon:

On November 14, 2001, the Project Manager for Alternative Technologies and Approaches (PMATA) asked the National Research Council’s (NRC’s) Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) to assess proposed modifications of the neutralization-based alternative technology planned for and under construction at Newport, Indiana, for disposal of the stockpile of bulk VX nerve agent located there. The proposed modifications are intended to expedite disposal of the stockpile. The objective of proposed changes to the alternative disposal technology planned for Newport is to shorten to the fall of 2002 the end date for destruction of its stockpile of bulk VX nerve agent. This new end date represents approximately a two to three year reduction in the previously estimated schedule for destruction of the entire Newport stockpile. A report was requested by the end of the first week in December 2001. To tackle the project, the NRC established a small ad hoc panel drawn from the current Stockpile Committee.

The Stockpile Committee and the NRC Panel on Review and Evaluation of Alternative Chemical Disposal Technologies, in their respective reports, Integrated Design of Alternative Technologies for Bulk-Only Chemical Agent Disposal Facilities (NRC, 2000) and Review and Evaluation of Alternative Chemical Disposal Technologies (NRC, 1996), reported in some detail on the design, development, and progress by PMATA in implementing an alternative to incineration at Newport to dispose of the VX nerve agent stockpile. The alternative process included removal of the agent from the ton containers, neutralization using a caustic solution in a stirred tank reactor, followed by treatment of the resulting organics in the hydrolysate in a supercritical water oxidation reactor, and the evaporation of the water in an evaporator/crystallizer.



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THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine National Academy of Sciences National Academy of Engineering Institute of Medicine National Research Council Board on Army Science and Technology Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program December 21, 2001 Mr. James Bacon Program Manager for Chemical Demilitarization PMCD SFAE-CD-CO-O Building E4585 Aberdeen Proving Ground, MD 21010–4005 Re: Review of Proposed Process Changes for Expedited Disposal of the Newport Stockpile of Bulk VX Nerve Agent Dear Mr. Bacon: On November 14, 2001, the Project Manager for Alternative Technologies and Approaches (PMATA) asked the National Research Council’s (NRC’s) Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) to assess proposed modifications of the neutralization-based alternative technology planned for and under construction at Newport, Indiana, for disposal of the stockpile of bulk VX nerve agent located there. The proposed modifications are intended to expedite disposal of the stockpile. The objective of proposed changes to the alternative disposal technology planned for Newport is to shorten to the fall of 2002 the end date for destruction of its stockpile of bulk VX nerve agent. This new end date represents approximately a two to three year reduction in the previously estimated schedule for destruction of the entire Newport stockpile. A report was requested by the end of the first week in December 2001. To tackle the project, the NRC established a small ad hoc panel drawn from the current Stockpile Committee. The Stockpile Committee and the NRC Panel on Review and Evaluation of Alternative Chemical Disposal Technologies, in their respective reports, Integrated Design of Alternative Technologies for Bulk-Only Chemical Agent Disposal Facilities (NRC, 2000) and Review and Evaluation of Alternative Chemical Disposal Technologies (NRC, 1996), reported in some detail on the design, development, and progress by PMATA in implementing an alternative to incineration at Newport to dispose of the VX nerve agent stockpile. The alternative process included removal of the agent from the ton containers, neutralization using a caustic solution in a stirred tank reactor, followed by treatment of the resulting organics in the hydrolysate in a supercritical water oxidation reactor, and the evaporation of the water in an evaporator/crystallizer.

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From a PMATA briefing on November 26, 2001, the ad hoc panel learned that the Army has two proposals to modify its alternative process at Newport in order to expedite the destruction of the VX agent stored there. The Army believes that either of these revised approaches, discussed below, will enable it to destroy the VX stockpile by the fall of 2002. The presentation was limited to a discussion of general process conditions and a general description of the physical facilities that are envisioned. The ad hoc panel’s work on this matter was constrained by the (probably necessarily limited) amount of data and information provided by the Army as it prepares to rapidly implement changes to expedite the alternative disposal technology program at Newport. Although other possibilities and opportunities for modification of the program likely exist, they were not presented to or discussed with the panel, and the panel was not asked to suggest other options. Hence, this report considers only the data and information presented by the Army in the November 26 briefing by Mr. Kevin Flamm, who described proposed changes to planned process operations for the destruction of almost 1700 ton containers of VX nerve agent at Newport. The judgments made by the panel members are based on this information, as well as their individual expertise and experience. The section below describes some of the specifics of the proposed process modifications that the ad hoc panel was asked to review and evaluate. Description of Modified Process To expedite the destruction of the bulk VX stored at Newport, the Army presented two concepts for evaluation by the ad hoc panel. The first entails in situ neutralization in the ton containers, followed by disposal at a commercial posttreatment facility or a treatment, storage, and disposal facility (TSDF). The second entails a modification of the current process design and includes a modification to the draining of the containers, followed by neutralization in stirred tank reactors and then disposal of the hydrolysate at a TSDF or other hazardous waste disposal facility. The objective of either of these changes is to destroy the agent approximately three to four years faster than was planned, using aspects of the original facility-design currently under construction. The process that was to be used at Newport, and that is currently under construction, provided for emptying the ton containers using a vacuum siphon, neutralizing the VX agent using a caustic solution in stirred tank reactors, and then oxidizing the stirred tank, neutralized hydrolysate in a supercritical water oxidation reactor to remove any residual organics, followed by disposal of the waste stream as a dry material in a commercial disposal facility. The ton containers would be taken to a clean (5X) condition in the ton container cleanup unit. In situ neutralization was evaluated in 1996 by the AltTech Panel (NRC, 1996), which identified a number of problems with the approach. Temperature control was a problem in tests conducted in 1995 because of uneven addition of water and poor mixing that led to the creation of hot spots and the formation of gel (NRC, 1996; Flamm, 2001). The proposed approach includes adding water at a controlled rate (about 1/8 gallon per hour over five days) to the VX in a ton container and providing mixing energy by sparging nitrogen into the container. A metering pump will be used to add water at a constant rate. To add the required amount of water for neutralization, it may be necessary to remove some agent from the ton containers. In 1996, the formation of EA-2192, a toxic by-product of the water hydrolysis, was another problem that was

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resolved by use of a caustic solution. The proposed in situ neutralization uses only water, which can be expected to produce EA-2192. The neutralized hydrolysate will be stored and tested to characterize the material before shipment to a commercial TSDF. Specific testing protocols were not discussed (Flamm, 2001). It will be necessary to agree on these protocols with any TSDF that might accept the neutralized hydrolysate. The ton container will be cleaned of residual agent by triple rinsing to meet Resource Conservation and Recovery Act (RCRA) requirements. No evidence was presented that this rinse will remove any gel that is formed. The rinsate will be fed to the hydrolysate storage tank for testing and shipment. The empty ton containers will then be stored for further processing, either in a metal parts treater or in the ton container cleanout (TCC) unit, and then shipped to Rock Island Depot. A system for checking that the ton containers are clean after the triple rinse must be developed and is critical to either technology approach. This step is necessary so that the containers can be stored for further treatment and disposal. The second proposed approach utilizes the more traditional design of neutralization in a stirred tank reactor. This approach provides for draining the ton containers by using a vacuum system followed by a triple rinse. This system consists of a glove box into which the ton container will be placed. The ton container head, through which the contents will be accessed, is in the glove box and is sealed from the containment room by a set of double bladders that fit tightly against the container wall. Using the gloves in the glove box, an operator will manually insert a vacuum siphon into the ton container. The container content and rinsate will be stored in an agent tank and then fed to one of the two batch-stirred reactors where neutralization takes place. The hydrolysate will be stored in tanks and characterized prior to being sent to an off-site TSDF. If the hydrolysate does not meet the specifications for release, it will be recycled through the neutralization step. The release specifications and testing protocols will depend on criteria established by the TSDF as well as the regulatory community. Such criteria have not been set, a step awaiting the identification of one or more suitable TSDFs. As recently as May 2000, the Stockpile Committee, in its Integrated Design report, recommended that the Army “evaluate off-site management of hydrolysates both for potential cost and schedule benefits and as a contingency plan in case difficulties arise during start-up and pilot testing of the on-site (postneutralization) process steps” (NRC, 2000, p. 18). Both systems depend on significant manual labor to ensure proper placement of the containers and their insertion into the drain systems. While they are in the process areas and airlocks, the workers will be dressed in the traditional demilitarization protective ensemble (DPE) or, if approved, commercial personal protective equipment (CASHPAC). The proposed operations are different from operations previously undertaken or planned. The Chemical Stockpile Disposal Program has, until now, operated with the philosophy that operations on open containers will be done remotely. Health and safety considerations were not discussed in detail during the November 26 briefing. It is expected that the Newport quantitative risk assessment will be modified to reflect the new operations. No hazard analysis taking into account the increased manual operations was discussed; no plans were presented, and none were shown on the schedule for hazards analyses. Facilities for both of these proposed approaches for neutralization of the bulk VX are considerably simplified compared with those currently under construction. In the case of in situ neutralization, it is expected that 8 to 9 ton containers will be placed in large mustard thaw boxes (MTBs). The boxes will be housed under negative pressure in a “spring-structured” building. If

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the stirred tank reactor option is used, the operations will be housed in a warehouse-type structure that will also be under negative pressure. The proposed structures will not be as robust as the hardened facilities currently under construction. However, the buildings will have a complete air handling and filtration system and will provide for containment of spills. The buildings will protect the public and the environment from any releases of agent. Current proposals call for the structure not to have a fire suppression system because there will be no flames or explosives present (Flamm, 2001). The effects of these changes (building location, lighter fabrication, lack of fire suppression) were discussed briefly in qualitative terms, but no data as to the possible effects on the public and environment were presented with the exception that the one percent lethality radius is 18 meters from the process building. Monitoring of the work areas will be by the traditional method of using MINICAMS, automatic continuous air monitoring systems (ACAMS), and depot area air monitoring systems (DAAMS) units. MINICAMS will be used at each drain station in the MTB, the airlocks, and the air filter units. DAAMS will be located in the process bay and at the solid waste area. It is expected that mobile DAAMS will be used for perimeter monitoring should there be a release. There is no indication that any of the monitoring units will have redundant units in place. This is in contrast to permanent monitoring at the site boundary, a feature implemented at other sites and planned for Newport originally. Monitoring and testing of liquids and solids that require disposal were not discussed at the November 26 briefing. The current VX control limits for work areas (1 E-05 mg/m3), allowable stack concentration, and general population limit (3 E-06 mg/m3) (50CFR50, March 15, 1988) will be used (Flamm, 2001). The Army has proposed a very tight schedule to complete by the fall of 2002 the destruction of the VX stored in the bulk containers at Newport. A simplified gant chart was presented. Based on the chart, the schedule has already slipped at least one month. Achieving this schedule requires commercial treatment, storage, and disposal facility acceptance. The schedule does not show a time frame for gaining disposal facility acceptance. Also, modifications are required in the regulatory approval process, including obtaining a National Environmental Policy Act (NEPA) exemption, a RCRA emergency permit, and an expedited Clean Air Act (CAA) permit modification. None of these have been obtained to date, and the schedule indicated that RCRA and NEPA relief were required by the end of November 2001. The Army also believes that the delisting of VX hydrolysate will be desirable so that the “derived from rule” will not apply; the material will still be handled as a hazardous material. Obtaining a delisting for a material can be a very time-consuming and labor-intensive process. The Army is using contractor and Army personnel to design modifications and run pilot tests. Health and safety personnel will work with the design team as the design proceeds rather then wait for a finished design. The Army is developing a new public involvement program but did not present any details of the program. It does recognize that such a program will be required (Flamm, 2001). Findings and Recommendations Finding 1. The ad hoc panel supports the concept of expediting the disposal of VX nerve agent stored in ton containers at Newport, Indiana. Recommendation 1. The Army should complete as quickly as possible its experimental program to evaluate proposed modifications for expedited disposal of the Newport stockpile.

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Finding 2a. There are two proposed concepts in development for expediting the destruction of bulk VX stored at the Newport site. Each uses previously studied processes. In situ neutralization using water has been studied and evaluated by the AltTech Panel. The work that was evaluated showed that there were fundamental problems, including the formation of gel and EA-2192. No new experimental evidence was presented in the November 26 briefing that would change the AltTech Panel’s earlier observations (NRC, 1996, pp. 148–149). Additional tests are being conducted at present on in situ neutralization to optimize process conditions. Neutralization in a stirred tank reactor is well established in the disposal process currently being implemented. Container draining operations have been tested at an Aberdeen chemical treatment facility pilot plant. Recommendation 2a. The Army should work on only one of the two proposed concepts for expedited neutralization. The decision to select one process to carry forward should be made as quickly as possible utilizing information at hand and developed during the CAMDS in situ tests. Recommendation 2b. Based on the information available, the ad hoc panel believes that the Army’s efforts should be devoted to the stirred tank reactor option in view of fundamental problems previously observed with the in situ neutralization approach. Recommendation 2c. Should the Army decide to continue with in situ neutralization, additional testing to determine optimal cleaning/rinsing conditions will be required. Finding 3. The use of a modified container-draining technique is a viable concept but remains to be proven. There is no procedure for ensuring that the containers are completely empty after the triple-rinse operation. Recommendation 3. The use of the vacuum siphoning technique for draining the ton containers requires further demonstration, with emphasis on material handling and confirmation that the containers, once triple-rinsed, are empty. Finding 4. Preliminary hazard analyses, including a hazards operations analysis and a quantitative risk assessment, have not been carried out for the proposed modifications at Newport. The Army proposes to do these analyses in parallel with the designing of the proposed treatment process. There is a potential for increased exposure of workers because of the increase in manual operations. There may also be increased effects related to operating in less robust structures. Recommendation 4. A hazard analysis, a hazard operations analysis, and preparation of modified focused quantitative risk assessment (QRA) evaluations should be completed at the earliest opportunity and before design of the selected process are completed. These assessments are particularly important for the container draining operations because of the potential for increased worker exposure. The analyses should also consider the effects of less robust structures. The focused QRA evaluations should take into account existing risk analyses and

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focus on potential operating risks. These studies should be made part of an ongoing risk management process that would span the design and operational phases of the facility. Finding 5. The options for disposal at TSDFs have been identified in general, but no specific TSDFs have been identified or approached. No presentation was made to the ad hoc panel concerning analytical protocols to characterize the VX hydolysate that is to be sent to a TSDF. Recommendation 5a. Identification of the TSDF of choice and one or more alternates should receive high priority on the schedule so that the final hydrolysate product can be defined and the process design completed. Recommendation 5b. Before a new approach is implemented, the analytical protocol for characterizing hydrolysate should be established. Finding 6. Monitoring within the operations building depends on single MINICAMS or DAAMS units with no redundancy. Perimeter monitoring will be done by mobile units only, as now proposed by the Army. Recommendation 6. The Army should reexamine its monitoring philosophy and consider redundant monitoring stations in critical areas such as the process bay, filter units, and drain station. Permanent monitoring stations for perimeter monitoring should be considered in light of potential public concerns. Finding 7. No order of magnitude estimation has been made of the risk trade-offs between the proposed rapid, but less robust, agent disposal program and longer storage of the VX agent. Recommendation 7. An analysis of the risk to workers and the public of longer-term storage of the VX agent in ton containers and of the potential added risks of processing using the more rapid, worker-intensive disposal process in less robust structures should be undertaken rapidly. Finding 8. The Army has recognized that a change in the disposal process will have to involve communications with the various stakeholders and apparently has developed a plan to carry out these communications. Recommendation 8. To ensure that public interaction remains positive, the Army should keep all stakeholders, especially the Newport community, fully informed prior to final decisions about disposal of the VX agent stored at Newport. Finding 9. The Army has proposed a very ambitious schedule to complete disposal of the Newport stockpile. It will require tight coordination of all elements of the plan. Such coordination may be difficult under the Federal Acquisition Regulations. Obtaining regulatory relief is important for the Army to meet any schedule. This is probably beyond the Army’s control. Also, obtaining a delisting can be a very long process.

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Recommendation 9a. The Army should form a single, seamless team of contractor and Army personnel involved in design, operations, pilot plant performance, and health and safety, to ensure that appropriate experiments are quickly conducted to demonstrate the proposed concepts for a new approach for bulk VX disposal and to obtain critical data in a timely manner for rapid completion of the design and its implementation. This may be done best by having a single team lead and by locating the team in one set of offices to encourage close communications and the lowering of organizational barriers. Where this is not possible, frequent (weekly) face-to-face meetings (at least initially) may be a reasonable approach. Recommendation 9b. The Army should expedite discussions with the regulatory community to ensure full cooperation in obtaining regulatory relief. Recommendation 9c. The Army should consider not obtaining a RCRA delisting for VX hydrolysate, but rather ensure that the product hydrolysate, when fully characterized, is acceptable to a treatment, storage, and disposal facility. Respectfully yours, Peter B.Lederman, Ph.D., Lead Ad Hoc Panel on Review of Proposed Process Changes for Expedited Disposal of the Newport Stockpile of Bulk VX Nerve Agent References Flamm, 2001. Briefing to the ad hoc panel of the Stockpile Committee on November 26, 2001 by Kevin Flamm, Project Manager for Alternative Technologies and Approaches. National Research Council (NRC). 1996. Review and Evaluation of Alternative Chemical Disposal Technologies. Panel on Review and Evaluation of Alternative Chemical Disposal Technologies. Washington, DC: National Academy Press. NRC. 2000. Integrated Design of alternative Technologies for Bulk-Only Chemical Agent Disposal Facilities. Committee on Review and Evaluation of the Army Chemical Stockpile Diposal Program. Washington, DC:National Academy Press.