2
The Toolbox of Non-Stockpile Treatment Options

The Army has a number of options available for the treatment of NSCWM. They include the use of facilities designed to treat both non-stockpile and stockpile CWM, the use of mobile systems that can be incorporated into a facility or transported to the site of a find, and individual treatment technologies. Like mobile systems, individual treatment technologies may be incorporated into a larger entity such as a facility or mobile system or transported to the site of a find. This chapter examines these options, or tools, and, where appropriate, presents the committee’s findings and recommendations related to their use. Each facility, mobile system, and individual technology is examined from the standpoint of its current status, as well as technical, RAP, and public involvement issues. An overview of the options for treating NSCWM considered in this chapter appears in Table 2-1.

The discussion in this chapter is based on information the committee was able to gather on available test results or operational plans for use of the tools as presented by the Army. However, equipment does not always function as designed, and unexpected events—even catastrophic failures—may occur. The Army has conducted preliminary accident risk assessments of treatment systems (see, for example, U.S. Army, 2001a, Appendix D, “Summary of Accident Risk Assessment”) but does not appear to have conducted an integrated site-specific risk assessment of its systems, including the risks of catastrophic failures.

As discussed in Chapter 1, non-stockpile sites span a considerable range—from sites at which large numbers of non-stockpile munitions are buried or stored, to sites containing only a few chemical agent identification set (CAIS) vials or bottles. In some instances, the non-stockpile sites are at current military facilities, where the Army has full control and consequently has several treatment options from which to choose; in other cases, the sites are at former defense facilities that are now commercial or residential properties, where treatment options may be more limited.

Some treatment options, such as the use of stockpile incinerators, would destroy the non-stockpile item directly. Others, especially those involving chemical neutralization, generate liquid secondary waste streams that require further treatment before disposal. This secondary waste treatment could take place in a commercial treatment, storage, and disposal facility (TSDF) or could employ one or more of the individual alternative technologies, such as chemical oxidation, either at the site where chemical neutralization takes place or at an off-site location. If secondary waste is defined as hazardous waste, such treatment would need to be conducted at a commercial TSDF permitted or approved by the appropriate regulatory authority under the Resource Conservation and Recovery Act (RCRA).

NON-STOCKPILE FACILITIES

The Army has at its disposition four principle types of facilities for treating non-stockpile chemical materiel: non-stockpile facilities, designed to destroy large quantities of dissimilar CWM; stockpile facilities, constructed to destroy large quantities of similar CWM; research and development facilities; and commercial treatment, storage, and disposal facilities (TSDFs).



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2 The Toolbox of Non-Stockpile Treatment Options The Army has a number of options available for the treatment of NSCWM. They include the use of facilities designed to treat both non-stockpile and stockpile CWM, the use of mobile systems that can be incorporated into a facility or transported to the site of a find, and individual treatment technologies. Like mobile systems, individual treatment technologies may be incorporated into a larger entity such as a facility or mobile system or transported to the site of a find. This chapter examines these options, or tools, and, where appropriate, presents the committee’s findings and recommendations related to their use. Each facility, mobile system, and individual technology is examined from the standpoint of its current status, as well as technical, RAP, and public involvement issues. An overview of the options for treating NSCWM considered in this chapter appears in Table 2-1. The discussion in this chapter is based on information the committee was able to gather on available test results or operational plans for use of the tools as presented by the Army. However, equipment does not always function as designed, and unexpected events—even catastrophic failures—may occur. The Army has conducted preliminary accident risk assessments of treatment systems (see, for example, U.S. Army, 2001a, Appendix D, “Summary of Accident Risk Assessment”) but does not appear to have conducted an integrated site-specific risk assessment of its systems, including the risks of catastrophic failures. As discussed in Chapter 1, non-stockpile sites span a considerable range—from sites at which large numbers of non-stockpile munitions are buried or stored, to sites containing only a few chemical agent identification set (CAIS) vials or bottles. In some instances, the non-stockpile sites are at current military facilities, where the Army has full control and consequently has several treatment options from which to choose; in other cases, the sites are at former defense facilities that are now commercial or residential properties, where treatment options may be more limited. Some treatment options, such as the use of stockpile incinerators, would destroy the non-stockpile item directly. Others, especially those involving chemical neutralization, generate liquid secondary waste streams that require further treatment before disposal. This secondary waste treatment could take place in a commercial treatment, storage, and disposal facility (TSDF) or could employ one or more of the individual alternative technologies, such as chemical oxidation, either at the site where chemical neutralization takes place or at an off-site location. If secondary waste is defined as hazardous waste, such treatment would need to be conducted at a commercial TSDF permitted or approved by the appropriate regulatory authority under the Resource Conservation and Recovery Act (RCRA). NON-STOCKPILE FACILITIES The Army has at its disposition four principle types of facilities for treating non-stockpile chemical materiel: non-stockpile facilities, designed to destroy large quantities of dissimilar CWM; stockpile facilities, constructed to destroy large quantities of similar CWM; research and development facilities; and commercial treatment, storage, and disposal facilities (TSDFs).

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TABLE 2-1 Overview of Non-Stockpile Treatment Options Treatment Option Description Facilities   Non-stockpile facilities   Pine Bluff Non-Stockpile Facility (PBNSF) (in final design) Designed to use chemical neutralization and associated technologies to address the recovered non-stockpile items stored at Pine Bluff Arsenal, Arkansas Munitions Assessment and Processing System (MAPS) (under construction) Designed to use chemical neutralization and associated technologies to address the recovered non-stockpile items found at Aberdeen Proving Ground, Maryland Use of stockpile destruction facilities for disposal of non-stockpile materiel Equipped to open stockpile chemical munitions, drain and incinerate agent, and destroy energetics Research and development facilities   Chemical Transfer Facility (CTF) Research facility at Aberdeen Proving Ground, Maryland, capable of destroying stockpile and non-stockpile agents Chemical Agent Munitions Disposal System (CAMDS) Research facility at Tooele, Utah, capable of destroying non-stockpile munitions containing agent fills not easily accommodated at other facilities, e.g., lewisite Treatment, storage and disposal facilities (TSDFs) Capable of high-temperature incineration of secondary waste streams produced by the RRS, EDS, and other systems Mobile Treatment Systems   Rapid Response System (RRS) Mobile trailer system to handle numerous CAIS vials and/or PIGs found in one location Single CAIS Accessing and Neutralization System (SCANS) (in design) Small reactor in which individual CAIS vials or bottles can be crushed and neutralized Explosive Destruction System (EDS) Mobile trailer system in which explosively configured munitions are explosively accessed and their chemical contents are neutralized Donovan blast chamber (DBC) (in testing for use with CWM) Mobile system potentially usable for the destruction of explosively configured munitions without neutralization of their chemical contents Individual Treatment Technologies   Plasma arc High-temperature technology for direct destruction of agent or for destruction of secondary waste streams produced by the RRS, EDS, and other systems Chemical oxidation Low-temperature technology potentially applicable to destruction of liquid secondary waste streams produced by the RRS, EDS, and other systems Wet air oxidation Moderate-temperature technology potentially applicable to the destruction of liquid secondary waste streams produced by the RRS, EDS, and other systems Batch supercritical water oxidation (SCWO) High-temperature technology still at the R&D stage that is potentially applicable to destruction of neat agent and CAIS vials Neutralization (chemical hydrolysis) Low-temperature technology for hydrolysis of neat chemical agents and binary precursors Open burning/open detonation (OB/OD) Historic blow-in-place method for destroying dangerous munitions Tent and foam Partially contained blow-in-place method for destroying dangerous munitions

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MAPS and PBNSF Unlike stockpile facilities, discussed next, no dedicated non-stockpile facilities have yet been completed. The PMNSCM plans to construct such facilities at two sites where large quantities of recovered chemical warfare material (RCWM) are stored: the Munitions Assessment and Processing System (MAPS) at Aberdeen Proving Ground (APG), Maryland, and the Pine Bluff Non-Stockpile Facility (PBNSF) at Pine Bluff Arsenal (PBA), Arkansas. Both MAPS and PBNSF are designed to treat non-stockpile chemical agents by an array of neutralization technologies, although future facilities might be based on other treatment methods. The neutralization processes to be used at MAPS and PBNSF are based on those developed for the now-defunct Munitions Management Device (MMD) systems, involving aqueous monoethanolamine (MEA) for HD and GB and aqueous caustic for CG (phosgene) (NRC, 2001a). Arsenic-containing agents such as lewisite would probably be treated with sodium hydroxide (NRC, 2001b). MAPS and PBNSF will also have components for unpacking and characterization of NSCWM, mechanical accessing of the chemical agent in munitions or containers, and explosive destruction of energetics. Secondary wastes from the neutralization process may be destroyed on-site or shipped off-site for treatment. This evaluation focuses on the current state of planning and construction of MAPS and PBNSF. For this reason, issues such as decommissioning and decontamination are not considered here. Munitions Assessment and Processing System The MAPS facility, discussed in detail in Appendix D, has been designed to deal with explosively configured chemical munitions and smoke rounds that will be recovered during the Installation Restoration Program (IRP) at APG. APG has been used for testing chemical weapons for more than 70 years, and the types and numbers of items that will be recovered are unknown at this time. A floor plan for MAPS is shown in Figure 2-1. Operators will drill or cut the munition and drain the chemical agent from the munition body in an explosive containment chamber. The separated explosives will then be detonated in a commercial detonation vessel. The chemical agent will be transported to and neutralized in the Chemical Transfer Facility (CTF) already located at APG. MAPS is designed to process munitions as large as a 155-mm projectile. MAPS could treat a maximum of seven to eight munitions per day, depending on the agent and the condition of the munitions. Pine Bluff Non-Stockpile Facility The PBNSF, also discussed in detail in Appendix D, will be designed specifically to process RCWM, binary chemical weapons components, CAIS, and chemical samples at PBA. The present inventory (Table 1-1) lists 69,878 items, including explosive and nonexplosive munitions, chemical sample containers, CAIS, binary CWM precursors, and empty ton containers. The chemical fills are diverse and include chemical agents and their mixtures (H, HS, HD, HN3, L, HL, H-CHCl3, L-CHCl3), industrial chemicals (CG, DM, CK, PS, PS-CHCl3), and binary precursors (DF and QL). The nerve agent GB is contained in two partially filled ton containers and in research, development, test, and evaluation (RDT&E) vials, and VX is in RDT&E containers. Of the 69,878 non-stockpile items at Pine Bluff Arsenal, the two GB-filled ton containers, possibly the nine M70A1 bombs, two chemical containers filled with HD and VX, and 5,814 mustard-filled CAIS could be processed in its stockpile facility. The remaining items are more suitable for processing in the PBNSF or in mobile systems such as the RRS or EDS. Stable munitions will be placed in the explosive containment chamber (ECC), where they will be drilled and drained, the chemical agent neutralized, and the liquid neutralents collected. Following the drill-and-drain operation, the munition will be pressure-rinsed with reagent and water, bagged, and transferred to the detonation chamber, where the energetics will be deactivated using auxiliary explosives. The resulting shrapnel fragments will be monitored for residual agent to verify that they are agent free. Liquid neutralents will be sent to a secondary treatment facility, whose process technologies have yet to be specified. Metal parts, when decontaminated to a level 3X,1 will be disposed of in an appropriately permitted facility. RCWM such as projectiles and mortar rounds could be processed in various versions of the EDS or by drilling and draining in an explosion containment room at PBNSF. Munitions that are designated unstable will be processed in an EDS outside the facility. CAIS items and chemical sample bottles could be handled in an RRS or, as currently planned, in glove boxes and neutralization reactors in the PBNSF, with the neutralent sent to a TSDF. Munitions not containing energetics will be destroyed in a fashion similar to that used for the explosively configured items, except that after the agent has been drained, the munition will be sent to a cutting station, where it will be reduced in size. 1   3X refers to the level at which solids are decontaminated to the point that agent concentration in the headspace above the encapsulated solid does not exceed the health-based, 8-hour, time-weighted average limit for worker exposure. The level for mustard agent is 3.0 mg/m3 in air. Materials classified as 3X may be handled by qualified plant workers using appropriate procedures but are not releasable to the environment or for general public reuse. In specific cases in which approval has been granted, a 3X material may be shipped to an approved hazardous waste treatment facility for disposal in a landfill or for further treatment.

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FIGURE 2-1 Floor plan of MAPS. SOURCE: Provided to the committee by Don Benton, Office of the PMNSCM, July 12, 2001.

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Binary CWM components could be processed by destroying the QL and DF by supercritical water oxidation (SCWO), plasma arc, or another nonincineration technology. At this writing, it has not been decided how the binary CWM components at PBA will be processed. Status of MAPS and PBNSF There are currently no functioning non-stockpile facilities. The design of the MAPS is completed, and construction has begun. The Army’s plan is to conduct a facility demonstration during FY 2002-2004, with actual disposal running from FY 2004 to 2009. The design of the PBNSF is being finalized, with construction scheduled to begin in January 2004. PMNSCM plans that PBNSF will operate from April 2006 to April 2007, completing destruction of all items on hand in time to meet the CWC deadline of April 29, 2007. In addition to incineration, two technologies are currently being evaluated for secondary waste treatment: supercritical water oxidation and plasma arc. Technical Issues Relatively few non-stockpile munitions are stored at APG (Table 1-3), although large numbers are believed to be buried there. The maximum anticipated throughput rate of eight munitions per day should be adequate to destroy the stored non-stockpile munitions as well as any recovered non-stockpile munitions at APG in a reasonable time. By contrast, the non-stockpile inventory at PBA has large numbers of non-stockpile munitions and containers of agent in storage and relatively few buried munitions. Because the PBNSF facility is still being designed, there are no reliable estimates of the throughput rate for destruction of the various types of NSCWM located there. Based on the schedule PMNSCM provided the committee (U.S. Army, 2001c), much of the PBA inventory is to be destroyed in 2006 and 2007. However, the committee finds the PMNSCM destruction schedule to be overoptimistic and concludes that the CWC deadline of April 29, 2007, will almost certainly not be met. At this writing, two technologies are being considered for treatment of secondary liquid wastes generated at PBNSF: SCWO and plasma arc. Both of these technologies face technical and/or permitting challenges that could add to concerns about meeting the CWC deadline for destruction of NSCWM at PBA. The SCWO technology, for example, was recently tested in the Assembled Chemical Weapons Assessment (ACWA) program and found to have operational problems that may make it unattractive for the disposal of certain chemical wastes. The SCWO reaction is so corrosive that it erodes the reactor container, in response to which sacrificial liners are inserted in the reactor. The choice of materials of construction for these liners is dependent on the elemental composition of the feedstock (feedstocks containing chlorine and fluorine are particularly corrosive). Indeed, the engineering design studies for the ACWA program indicate that in many cases the protective liner in the reactor must be changed every few weeks (NRC, 2002b). Also, the salts produced are insoluble in supercritical water and plug the reactor, requiring frequent shutdown and flushing. Plasma arc technology has been used successfully in Europe to destroy chemical warfare material but has not been permitted in the United States. Currently, PMCD is optimistic that it will have little difficulty in obtaining a permit. They have identified several plasma arc firms in this country that have operational units, but none has destroyed a CW-related waste stream. If the ACWA program does not develop a continuous SCWO system that is cost-effective for use on the quantities of materiel to be destroyed in the non-stockpile program and if a permit for the plasma arc technology cannot be obtained in time, the Army may be forced to incinerate its waste streams to comply with the CWC treaty deadline of April 2007.2 Regulatory Approval and Permitting Issues MAPS will operate initially under a Resource Conservation and Recovery Act (RCRA) Research, Development, and Demonstration (RD&D) permit and will transition to a standard RCRA Part B permit when operations become routine. The Army has worked closely with Maryland regulators, and the MAPS permitting process has gone relatively smoothly. The Army has just begun to evaluate permitting strategies for the PBNSF. As with MAPS, construction and initial operation of the facility could proceed under a RCRA RD&D permit. After operations at the facility become routine, the PBNSF operations could be transitioned to the full RCRA permit. Permitting activities for PBNSF are still at an early stage, and with the final treatment technology yet to be decided, it remains unclear what problems may be encountered. Public Concerns As noted above, semi-permanent facilities are designed specifically to allay public concerns that the facilities will remain open permanently and become “magnets” for off-site wastes. Using chemical neutralization rather than incineration to destroy chemical agents may also alleviate public concerns about potential hazardous air emissions. In the case of MAPS, the Army appears to have worked diligently to gain the confidence of local public interest 2   While some interest groups have advocated storage of neutralent waste streams until a viable technology alternative to incineration can be developed, the Army has indicated that it would not consider long-term storage of secondary wastes at PBA.

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groups. The Army’s public outreach efforts for PBNSF are at a very early stage (see Chapter 5). Finding 2-1a. PBA has the largest known non-stockpile inventory. It contains almost 70,000 items, including explosive and nonexplosive munitions with diverse chemical fills, binary agent precursors, CAIS, chemical samples, and empty ton containers. If the CWC treaty deadline is not extended, these items must be destroyed by April 29, 2007. Finding 2-1b. The task of destroying the very large quantity of NSCWM at Pine Bluff Arsenal by 2007 is daunting, given that the planned non-stockpile facilities are not expected to be operational until 2006. As far as the committee can ascertain, the Army has not developed a timetable for destruction of this NSCWM that is both realistic and consistent with current treaty deadlines. The committee is concerned that without clear planning and extraordinary efforts, the treaty deadlines will almost certainly not be met. Recommendation 2-1. PMNSCM should develop a detailed, realistic timetable showing how the planned non-stockpile facilities at Pine Bluff Arsenal can achieve the throughput necessary to destroy the stored non-stockpile items by April 2007 and should communicate this timetable to all stakeholders. Finding 2-2. The construction of semi-permanent facilities is a valid approach at sites where large quantities of NSCWM are stored or expected to be recovered. Installing equipment in buildings instead of trailers, tents, and other temporary facilities will provide a more comfortable and safer environment for the workers. Also, more thorough environmental safeguards can be provided than in mobile facilities, thus lowering the risk of fugitive gases escaping into the environment. Recommendation 2-2. The Army should consider constructing treatment facilities at other sites where large quantities of NSCWM are expected to be recovered. Stockpile Facilities Until November 1999, federal law prohibited the use of stockpile chemical disposal facilities for destroying anything other than stockpile CWM. In P.L. 106-65, Congress amended the law to allow non-stockpile materiel to be destroyed in stockpile facilities, provided the states in which the stockpile facilities are located agree, thus creating a new treatment option for non-stockpile materiel. The chemical stockpile contains projectiles, mortar rounds, rockets, land mines, bombs, spray tanks, and bulk containers that are filled with the blister agent mustard and the nerve agents GB and VX. Under the Chemical Stockpile Disposal Program, the Army is in the process of planning, constructing, and operating chemical disposal facilities (CDFs) at eight locations. Appendix C evaluates the suitability of stockpile chemical disposal facilities for treating non-stockpile CWM that is co-located at these facilities. Description At four of the eight storage locations in the United States (Tooele Chemical Disposal Facility, Utah [TOCDF]; Anniston Chemical Activity, Alabama; Umatilla Chemical Depot, Oregon; and Pine Bluff Arsenal, Arkansas), the agent, energetics, and agent-contaminated metal surfaces will be processed in appropriately designed incinerators and furnaces. Demilitarization machines will be used to access the agent through techniques such as reverse assembly of projectiles and mortar rounds, punching and draining of bulk containers and land mines, and draining and shearing of rockets. The CDF incinerators, pollution abatement systems, monitoring equipment, and carbon filtration systems are designed to process the agent fills found in the stockpile munitions and bulk containers. Status Agent operations with the baseline incineration system have been completed in the Johnston Atoll Chemical Disposal System (JACADS) and closure operations have begun (U.S. Army, 2000b; NRC, 2002a). Operations continue at TOCDF, which has processed almost two-fifths of its stockpile. Construction has been completed at Anniston, Alabama (Anniston Chemical Disposal Facility), and Umatilla, Oregon (Umatilla Chemical Disposal Facility), where systemization (operational testing) is under way. Construction at Pine Bluff, Arkansas (Pine Bluff Chemical Disposal Facility) is approximately two-thirds complete. A number of chemical disposal facility concepts, including incineration and alternative technologies, are in the planning and design stage as competing options for Pueblo Chemical Depot, Colorado (Pueblo Chemical Disposal Facility—PUCDF) (NRC, 2001c). Three alternative technology options are currently under consideration by the ACWA program for use at Blue Grass Army Depot, Kentucky. Recently, the Army concluded that several of the CDF incinerators will remain in operation beyond April 29, 2007, the original goal for completion of the destruction of the chemical stockpile under the CWC (U.S. Army 2001c). PMNSCM has recommended in several cases that small, non-stockpile chemical sample containers currently in storage at stockpile incinerator locations (e.g., Department of Transportation (DOT) approved bottles, vials, drums, steel

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cylinders, and ampoules having VX, GB, and mustard fills) should be processed in the CDFs. Technical Issues The CDFs are specifically designed to process stockpile items and agent fills (GB, VX, and mustard). The measured destruction and removal efficiencies of the stockpile incinerators exceed 99.9999 percent and include stringent controls on emissions of hazardous air pollutants (Smithson, 1994). In Appendix C, the technical feasibility of destroying non-stockpile items in stockpile facilities is evaluated as an alternative or supplement to disposing of these items in either other (non-CDF) facilities or non-stockpile mobile equipment such as the RRS and EDS. Incinerators for destruction of stockpile materiel are or will be available at Umatilla, Tooele, Anniston, and Pine Bluff. The suitability of the incinerators and associated infrastructure for destroying non-stockpile items is as follows: Umatilla. The existing permit allows destruction of NSCWM, and the state of Oregon prefers to use the stockpile chemical disposal facility (CDF) for destruction of the five non-stockpile ton containers stored at Umatilla. Deseret. The incineration facility at Tooele provides a technically feasible alternative for destruction of 157 of the 174 non-stockpile items stored at Deseret. The other 17 items contain lewisite and are better suited for destruction at the Chemical Agent Munitions Disposal System (CAMDS). The Tooele CDF is scheduled to complete its stockpile mission in the fourth quarter of 2003, so it would be available to treat the non-stockpile items. Existing permits would need to be modified and the public would need to agree. Anniston. The CDF at Anniston provides a technically feasible alternative for destruction of the 133 non-stockpile chemical sample containers stored there. Permits would need to be obtained and the public would need to agree. Pine Bluff. The incineration facility at Pine Bluff provides a technically feasible alternative for destruction of less than 10 percent of the 69,878 non-stockpile items stored there because its design does not include facilities for opening bulk containers of agent and CWM binary components (Appendix C). However, inclusion of such capability in the non-stockpile PBNSF would enable transfer of these liquid chemicals to vessels suitable as feed tanks for the PBCDF liquid incinerator. This modification, plus the addition of DF and QL monitoring systems at the Pine Bluff Chemical Disposal Facility (PBCDF), would allow incineration of the great majority of the PBA non-stockpile inventory. The four stockpile incineration facilities might be able to secure public acceptance for treatment of non-stockpile materiel stored at other locations within the state, but even that is likely to be difficult. Acceptance of non-stockpile materiel from outside the state is extremely unlikely. Because facilities for the destruction of the stockpile at Pueblo and Blue Grass have not yet been selected, the committee makes only general comments on their suitability for destroying non-stockpile materiel (Appendix C). Aberdeen has selected neutralization followed by off-site posttreatment at a commercial TSDF for destruction of its stockpile materiel. That system could treat at most 19 mustard-filled chemical sample containers of the 125 non-stockpile items stored at Aberdeen. MAPS is intended to treat the remaining 106 currently known non-stockpile items, as well as materiel recovered during the installation restoration program at APG. Technically, it should also be possible to use CDFs to destroy secondary non-stockpile waste streams, whether they are generated from non-stockpile treatment processes conducted at stockpile sites or remote locations. Regulatory Approval and Permitting Issues Public Law 106-65 provides that non-stockpile materiel may be disposed of in stockpile facilities if the state in which the facility is located issues the appropriate permit or permits. However, in many stockpile locations, the original CDF permits exclude or severely restrict the destruction of any materiel other than stockpile materiel at these facilities. For example, at Pine Bluff Arsenal, Arkansas, the RCRA permit for the stockpile incinerator under construction prohibits the processing of any hazardous waste, including non-stockpile materiel, in the facility, whether the waste is located at the site or off-site (Arkansas, 1999). At Umatilla Chemical Depot, in Hermiston, Oregon, the stockpile facility’s RCRA permit requires that the small quantity of non-stockpile materiel currently stored at the site be destroyed at the stockpile facility, but it prohibits any off-site hazardous wastes to be brought, stored, or treated at the facility (Oregon, 1997). Thus, permitting can represent a significant obstacle to the use of stockpile facilities to destroy NSCWM at most sites. Public Concerns The histories of the stockpile program, the non-stockpile program, and the use of mobile incinerators in hazardous waste site cleanups demonstrate that classical incineration often generates strong public opposition. There are concerns over the impact on local communities of the potential emission of small amounts of chemical agents not destroyed, as well as low concentrations of chemicals that are inevitably formed inside incinerators (e.g., polychlorinated dibenzodioxins) (Greenpeace, 2001; EPA, 1998; Sierra Club, 2001).

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In the case of stockpile incinerators, public concerns at some sites have focused on the possibility that the facilities would continue to operate indefinitely after the stockpile was destroyed and would import hazardous wastes. If CDF permits were to be modified now to allow the destruction of non-stockpile items, some public stakeholders would probably feel that the Army had violated the commitments it made when it applied for the original permits for CDF operations. On the other hand, at some sites the public may feel that use of the CDFs to destroy non-stockpile items provides a cost-effective and expeditious means of eliminating the risk associated with the storage of its non-stockpile items. Finding 2-3. The stockpile chemical disposal facilities (CDFs) are technically capable of safely disposing of a portion of the non-stockpile inventory, including secondary wastes, but could face challenging regulatory and public acceptability hurdles, especially if they accepted NSCWM from other sites or out of state. Although any NSCWM or secondary waste might be a candidate, materiel already located at stockpile sites—or, secondarily, located within the same state—may present less of an acceptance problem than NSCWM from other states. Recommendation 2-3. Provided regulatory and public acceptability issues can be resolved, any NSCM located at stockpile sites and suitable for destruction in chemical stockpile disposal facilities should be destroyed in those facilities. This recommendation applies to non-stockpile materiel, secondary wastes, binary CWM components, and bulk chemicals. Research and Development Facilities The Army also has at its disposition two R&D facilities that might be used for treating appropriate non-stockpile items. PMNSCM has proposed using the Chemical Transfer Facility (CTF) at Aberdeen Proving Ground (APG) to destroy CWM recovered at APG and the Chemical Agent Munitions Disposal System (CAMDS), at Deseret Chemical Depot, to destroy non-stockpile items containing the arsenical agent lewisite. Chemical Transfer Facility The Chemical Transfer Facility (CTF) is an R&D facility at APG that has processed munitions, sample bottles, and ton containers containing a variety of chemical fills. The CTF is not capable of processing explosively configured munitions but does contain a chemical agent transfer system that can drain ton containers. There is no treaty-imposed time limit on operation of the CTF, and if its schedule permits, it can dispose of the container items listed above. PMNSCM has proposed using the CTF as part of MAPS to destroy appropriate NSCWM items found at APG. Chemical Agent Munitions Disposal System CAMDS, located at Deseret Chemical Depot near Tooele, Utah, is the Army’s R&D facility for building and testing prototype chemical demilitarization hardware and processes. The demilitarization machines used in the stockpile CDFs and prototypes for the incinerators were fabricated and tested at CAMDS. It has been used by PMNSCM to develop, assemble, and test the RRS used for the disposal of CAIS. It has also been used to test systems for the biological degradation of chemical agents and is currently the Army’s facility for the disposal of chemical materiel containing the arsenical agent lewisite. The lewisite that was stored in stockpile ton containers at Deseret Chemical Depot (DCD) was destroyed at CAMDS. Non-stockpile items containing lewisite (mortar rounds, projectiles, and a chemical sample bottle) stored at DCD are also intended for destruction at CAMDS. The CAMDS physical facility consists of several buildings, incinerators, and engineering offices. As such, it is a valuable facility that can undertake specialized projects, destroy relatively small quantities of chemical agents, and develop and test equipment used for chemical munitions disposal. Commercial Treatment, Storage, and Disposal Facilities The fourth type of facility—commercial treatment, storage, and disposal facilities (TSDFs)—differs from stockpile and non-stockpile facilities in that commercial TSDFs cannot be used to treat CWM. However, they can accept the secondary waste generated by mobile systems and some individual treatment technologies, assuming that the secondary waste no longer contains agent, except perhaps at de minimis levels. A permit modification for treatment of these wastes may be required, however. The Army has demonstrated two mobile systems for destruction of agent and energetics in NSCWM. These systems generate secondary wastes that can be disposed by other mobile systems or in treatment facilities that may be commercial or government owned. One is the RRS, designed to treat CAIS, which contain sulfur mustard, nitrogen mustard, and lewisite, and no energetics. The other is the EDS, which is designed to treat NSCWM with or without explosive components. Both are discussed later in this chapter. The RRS was designed to neutralize the vast bulk of the agent, and the neutralent has been demonstrated to contain less than 1 ppm of agent.3 The EDS has destroyed up to one-pound equivalent of explosives and reduced the concentration of agent (phosgene, mustard, and sarin) below detection 3   John Gieseking, Office of PMNSCM, personal communication to R. Peter Stickles on January 15, 2002.

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levels.4 Both the RRS and the EDS use a liquid chemical formulation to neutralize (hydrolyze) the agent. In the EDS, the agent and energetics are converted into products that require further treatment before the mixture can be discharged (e.g., to a sewage treatment plant). In subsequent discussion, the committee refers to the liquid mixture produced in the RRS or the EDS as “neutralent.” Agent concentrations in neutralents from the RRS and EDS are so low that the neutralent should not be classified as chemical warfare materiel. Agent concentrations in rinsates and cleaning solutions from the EDS are even lower (see Table 2-2). Table 2-2 demonstrates that the concentration of chemical constituents in the neutralent from the EDS are, in most cases, below federal land disposal restriction (LDR) treatment standards. While neutralents may contain very low levels of chemical agents, they present a risk similar to commercial hazardous waste and may be safely managed in commercial TSDFs. The destruction and removal efficiency (DRE) achieved by neutralization (99.9999 percent or more) exceeds or is comparable to the DRE achieved by the best commercial technologies. Thus, the committee believes that given the range of physical and chemical properties of the chemicals in neutralents and rinsates, these wastes could be safely managed in commercial TSDFs. State and/or federal regulators would need to agree, however, with the TSDF owner/operator that a particular neutralent or rinsate is appropriate for disposal at a given TSDF. The use of commercial hazardous waste TSDFs for this purpose could reduce costs to the Army (and the taxpayer) with little or no adverse effect on human health or the environment. Informed consideration of the possibility of commercial treatment is consistent with the guidelines in Office of Management and Budget Circular A-76, which establishes the principle that the government should not perform functions that the private sector could perform unless there is a compelling reason to do so. The committee also believes that commercially available hazardous waste incinerators should be suitable for final treatment of neutralents, although test burns may be necessary. Some neutralents are high in sodium, which tends to shorten the life of the refractory brick used to line incinerators, but wastes of similar composition have been treated satisfactorily. Commercial hazardous waste facilities are available that offer other technologies that might be better for aqueous wastes. These technologies include biological treatment, supercritical fluid extraction (not to be confused with supercritical water oxidation, discussed later in this chapter) followed by incineration of the smaller volume of extracted organics, and chemically based proprietary processes. If rinsates and cleaning solutions are sufficiently dilute, they might be suitable for discharge directly to a publicly owned sewage treatment works (POTW) or a federally owned treatment works (FOTW). Rinsates and cleaning solutions sampled to date are generally dilute—more than 98.9 percent water. Except for the presence of chloroform from the sealant used in the EDS (NRC, 2001b, Table D-1), the levels of benzene, toluene, mercury, and arsenic in rinsate and cleaning solution are below RCRA LDR treatment levels and the levels allowed to be discharged to a POTW or FOTW (NRC, 2001b). Thus, based on a site-specific evaluation of the residual concentration of chemicals in the rinsate and cleaning solution waste streams, a POTW or an FOTW might accept these wastes for treatment. Of course, this determination should be made on a case-by-case basis and depends on the nature of the treatment system and the constituents and concentrations in the waste stream. Nine hazardous waste incinerators that are operating commercially in the United States might be available, two each in Texas and Ohio, and one each in Arkansas, Illinois, Kentucky, Nebraska, and Utah. The largest commercial hazardous aqueous waste treatment facility in the United States is managed by DuPont in Deepwater, New Jersey. It provides a combination of physical, chemical, and biological treatment. Clean Harbors, in Baltimore, uses supercritical fluid extraction to treat aqueous wastes. Perma-Fix, with facilities in the Southeast and Midwest, uses proprietary aqueous treatment processes tailored to specific waste streams. Status Neutralents and rinsates from the RRS were destroyed in the Onyx Environmental Services commercial hazardous waste incinerator at Port Arthur, Texas. Other wastes from RRS operations were destroyed at Safety-Kleen’s commercial hazardous waste incinerator in Aragonite, Utah, and 4   The detection limits of <1 ppm (1 µg/ml ~ 1 ppm for dilute aqueous solutions) for phosgene and <0.2 ppm for mustard were lower than the treatment goal of <50 ppm for these two agents (U.S. Army, 2000b). Likewise, the detection limit of <0.1 ppm for sarin was lower than the treatment goal of <1 ppm (U.S. Army, 2001c). The treatment goals established by the Army for concentrations of residual agent in NSCM neutralents are not risk-based but rather appear to have been set in relation to detection limits. Nevertheless, toxicity studies conducted by the Army on RRS neutralents to date suggest that at residual mustard and lewisite concentrations of <50 ppm, the acute toxicity of the RRS neutralents is no greater than that of the virgin oxidant/solvent system. In Chapter 4, the committee indicates its belief that the approach exemplified by the Army’s proposed Utah Chemical Agent Rule (UCAR) provides a good starting point for continued discussions between the Army, state regulators, and the public, on selecting appropriate standards that would be protective of human health and the environment.

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TABLE 2-2 Composition of Liquid Waste Streams from the EDS Treatment of Sarin (GB) Bomblets at RMA Waste Component from EDS Treatment of Sarin Bomblets at RMA Neutralenta,b Water Rinseb Cleaning Solutionc POTW Feed Limit for Organic Chemical Industry LDR Treatment Standards Goal of Treatment Prior to Disposal in Landfill Monoethanolamine (MEA) (%) 43.8-48.3 0-4.7 0.8-1.1 None None Water (%) 51.7-56.2 95.3-100 98.9-99.2 NA NA IMPA (isopropyl methylphosphonic acid) (ppm) 3,400-5,000 24-78     NA DIMP (diisopropyl methylphosphonate) (µg/L) 18,000-27,400 291-480 ND   NA Explosives in liquids (µg/L) <1,000 <1,000 <1,000   NA Benzene (µg/L) 1,330-2,850 28.6-40.7 <100 137 140 Chloroform (µg/L) ND-21.6 ND-4380 8,360-10,500 325 46 Dichloromethane (µg/L) ND-97.1 ND-71 377-968   NA Toluene (µg/L) 369-810 ND-23.7 <2 74 80 Mercury (µg/L) 0.1-1 0.1-2.65 17.9-25   150 Aluminum (µg/L) 8,720 to 11,100 876 to 11,800 <876     Arsenic (µg/L) <200 <20 <20   1,400 Cadmium (µg/L) 6.81-10 <0.68 2.2-46   690 Chromium (µg/L) 445-770 11.5-485 1,070-1,870   2,770 Copper (µg/L) 9,030-18,200 486-5,470 3,850-6,200     Lead (µg/L) 63-237 3.82-603 128-168 690 690 Zinc (µg/L) 23,100-38,300 72.5-308 4,920-5,680 2,610 NA pH 12 10.4-11.5 6.5-7.8     NOTE: NA, not applicable; ND, none detected. The expected source and collection regime for these wastes are presented in Table 2-1. The term “treatment” is used to describe steps involving addition of reagent or water to the EDS and oscillating for some time period prior to opening the chamber. Note that water treatment and rinse water wastes can be combined. To date, the Army has chosen to segregate the three categories of wastes so as not to foreclose on the options for treating the waste streams that are primarily water. aNeutralent consisting of the initial treatment of agent with active reagent (e.g., MEA) and any subsequent chamber washes with chemical reagent (if used). bRinsate consisting of additional agent treatment with water and chamber washes with water after opening the EDS. cCleaning solution consisting of washes (water and detergent) made between processing of each munition and final washes (e.g., water and acetic acid), made after completing a munitions campaign. SOURCE: Lucille Forrest, Office of the PMNSCM, “Interpretation of Waste Results from EDS GB Bomblet Destruction, Rocky Mountain Arsenal,” communication to the committee, February 2001. Deer Park, Texas (U.S. Army, 2001d). Spent decontamination fluids generated at the Army’s Dugway Proving Ground (DPG), Utah, have also been incinerated at the Aragonite facility. Chemical constituents in decontamination fluids are similar in general content to those in neutralents, but the concentrations of key contaminants are typically much lower. Neutralents and rinsates from the EDS used at Rocky Mountain Arsenal have been destroyed at Safety-Kleen’s commercial hazardous waste incinerator in Deer Park, Texas. Technical Issues Incineration technology is well developed. Destruction efficiency has been proven on wastes that are very similar in nature to the RRS and EDS neutralents and rinsates. Further, commercial incinerators have destroyed these specific wastes successfully. All commercial incinerators have elaborate air pollution control trains. Metal constituents of the wastes may remain with the slag or be captured by the air

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pollution control system. Both the slag and the fly ash are typically disposed of in a hazardous waste landfill. The committee has concluded that CAIS items can be destroyed safely in hazardous waste incinerators, assuming the arsenic content does not present a site-specific air emission problem (NRC, 1999a). The physical and chemical properties of a chemical govern the ability of incinerators to destroy and remove the hazardous constituents. The hazardous constituents in CWM material share the chemical and physical characteristics of the hazardous constituents in commercial hazardous waste. High-temperature commercial incineration is safe, robust (that is, applicable to a wide range of chemicals), and effective (that is, destroys or removes 99.99 percent or more of the chemicals treated) (EPA, 1999a, 1999b, 2000, 2001a, 2001b). It is also commercially available, heavily regulated, and widely utilized throughout the world, including for the destruction of hazardous wastes and chemical weapons. However, as the committee has noted, a waste-specific (and in certain circumstances, a site-specific) determination of the safety and efficacy of incineration must be made before an incinerator can be permitted to treat non-stockpile chemical materials (NRC, 1999a). Such a risk assessment is required by EPA regulations and guidance on stack emission testing of combustion emission sources (EPA, 2001b). Alternative technologies are available at several commercial hazardous waste facilities. To the committee’s knowledge, none of these technologies has been used to treat neutralents or rinsates specifically. Though they have been used to treat similar types of wastes, a treatability study would probably be required prior to waste acceptance. Regulatory Approval and Permitting Issues A commercial hazardous waste facility can accept only wastes that are specifically included in its permit. Facilities try to include as broad a spectrum of waste as possible in their permits, because acceptance of a waste that is not included could require a permit modification. Public Concerns Some members of the public and several national environmental groups strongly oppose the incineration of both commercial hazardous waste and chemical weapons materiel. The nature and scope of opposition varies. For example, a public interest group with which some committee members met in Utah was very concerned about incineration at Tooele but was indifferent to the closure of a commercial incinerator in Clive, Utah. The congressional mandate to develop alternative treatment technologies stems from the strong opposition to incineration of the stockpile chemical weapons. Ultimately, the Army and the state regulators must decide whether commercial facilities for the treatment or disposal of hazardous waste are the most appropriate approach after weighing all relevant factors, including technical feasibility, safety, legal and regulatory restrictions, willingness of the commercial facility to accept the material, timing, costs, and public concerns. Commercial rotary kiln incinerators have successfully destroyed secondary wastes from the destruction of non-stockpile materiel and are capable of handling a wide range of contaminated liquids, solids, and sludges. Other technologies offered by commercial hazardous waste facilities include deep well injection, biotreatment, and physicochemical treatment. It should be recognized that some members of the public may not believe that the risk posed by RRS and EDS neutralents and rinsates is minimal, but others may accept the trade-off between minimal risk and expeditious disposal of these liquid wastes. Thus, decisions about the acceptability of these technologies must be made on a case-by-case basis. The credibility of the Army and the likelihood of public acceptance (or acceptance by the majority of the public) are likely to be enhanced if the solicitation of public input is not viewed as a ploy to sell the public on a predetermined decision but rather as an open and transparent attempt to involve the public in government decision making. This approach results in a fair process; however, it does not and must not give veto power to persons who may still oppose the ultimate decision reached by the Army and state regulatory authorities. Recommendation 2-4. The Army should continue to use commercial TSDFs or the stockpile facilities for the disposal of secondary wastes from the destruction of non-stockpile CWM when possible. MOBILE TREATMENT SYSTEMS The Army has developed two principal mobile systems for the treatment of non-stockpile CWM, the EDS and the RRS, and is developing a third but smaller system, the single CAIS accessing and neutralization system (SCANS). The EDS is designed to destroy explosively configured munitions, although it can also destroy chemical munitions without explosive components. The RRS is designed to dispose of CAIS at the locations where they are found. SCANS is being developed to treat individual CAIS vials or bottles. Another system, the Donovan blast chamber (DBC), was developed by a private corporation in Alabama and has been evaluated by the Army Corps of Engineers. The DBC, which was originally designed to treat conventional explosive munitions, has been modified and adapted to treat explosively configured CWM and potentially offers a higher rate of throughput than the EDS. Each of these systems is considered to be “mobile,” although the term is a relative one. The

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TABLE 2-4 NSCMP Technology Test Program Technology Vendor, Test Site Feed Streams PLASMOX Burns and Roe Enterprises, MGC Plasma in Muttenz, Switzerland H neutralent simulant, GB neutralent simulant Gas-phase chemical reduction Eco Logic International, Inc., Edgewood, Maryland GB neutralent, H neutralent simulant, RRS neutralent, DF simulant, vials of CHCl3 Supercritical water oxidation (continuous) Both vendor and test site to be determined Binary chemicals, rinsates, neutralents Supercritical water oxidation (batch) Sandia National Laboratories, Livermore, California H neutralent simulant, GB neutralent simulant, vials of CHCl3 Persulfate oxidation Southwest Research Institute, San Antonio, Texas HD neutralent simulant, GB neutralent simulant, DF Electrochemical oxidation CerOx Corporation, University of Nevada at Reno H neutralent simulant, GB neutralent simulant, DF simulant Ultraviolet oxidation Purifics Inc., Toronto, Canada Rinsate simulant Wet air oxidation Zimpro Products, Rothschild, Wis. Neutralent simulant, binary DF, and QL simulant   SOURCE: Christopher Ross, PMNSCM, presentation to the committee on July 10, 2001. temperature ions and electrons that cause target chemical compounds to dissociate in a containment chamber. Plasma arc generates large volumes of high-temperature vapor that require high-quality treatment. There are many variations of the plasma arc process, involving use of different plasma gases and reactor designs that provide either an oxidizing or a reducing environment. One system developed by MGC Plasma AG in Switzerland (the PLASMOX process) has achieved destruction efficiencies greater than seven nines (99.99999 percent) when processing adamsite, Clark I and II, phosgene, lewisite, yperite, and a mixture of yperite and lewisite. PLASMOX employs closely coupled, staged reaction zones (characterized as controlled pyrolysis) to completely destroy organic compounds. The Army has also investigated the PLASMOX process for destruction of neutralent waste streams as part of its technology test program. Status MGC/PLASMOX developed a portable unit, Model RIF 2, that was put into operation in 1994, and it has since built additional units. The RIF 2 is skid-mounted and designed to be moved by four standard tractor-trailers. The unit has been used in Europe and is permitted under both Swiss and German environmental laws and regulations. It was used successfully to destroy chemical agents for the Swiss Army at its chemical materiel laboratory in Spiez, Switzerland. The PLASMOX tests run by the Germans and Swiss indicate that the system will destroy chemical warfare agent safely and rapidly (Burns and Roe, 2001). There has been no recorded destruction of NSCWM by plasma arc technology in the United States; however, as part of the technology test program (see Table 2-4), PMNSCM hired Stone & Webster to conduct tests of the Burns and Roe PLASMOX plasma arc process on simulated H and GB neutralents with MEA. MGC conducted these tests from January 8 through January 19, 2001, under a subcontract to Burns and Roe Enterprises at the MGC/PLASMOX facility in Switzerland. The system layout is shown in Figure 2-4. PMNSCM has proposed that plasma arc technology be used primarily for the destruction of neutralent waste streams, although it may be a candidate for the direct destruction of the binary CWM components DF and QL stored at Pine Bluff Arsenal. Based on the MGC/PLASMOX tests, the throughput rate for neutralent processing is approximately 13 liters per hour, with a 50 percent availability. Technical Issues Stone & Webster recommended that the PLASMOX system receive further testing on typical NSCMP liquid and solid waste streams, with particular attention paid to the deposition of solid materials in the system. Its report concluded that further improvements would have to be made to ensure that the system would comply with all EPA and state requirements (Stone & Webster, 2001b). The Army has identified approximately a dozen vendors of plasma arc technology in the United States, although none is currently permitted to treat hazardous waste or NSCWM. Regulatory Approval and Permitting Issues The Army’s test results for the PLASMOX technology raise a number of regulatory issues that must be resolved before this system could be permitted in the United States. These include improvements to the gas scrubber system, more complete knowledge of the fate of key components of the NSCWM (e.g., phosphorus), and better characterization of the solid, liquid, and gaseous waste streams. The processes used by U.S. plasma arc vendors also differ in significant ways from the PLASMOX process tested by the Army.

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FIGURE 2-4 PLASMOX system layout. SOURCE: Adapted from Stone & Webster (2001b).

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Public Concerns A key public concern about plasma arc processes for the destruction of NSCWM in the United States is whether plasma arc offers a true alternative to incineration. Depending on the type of plasma gas used and the configuration of secondary oxidation zones, quench, and scrubber processes, plasma arc systems may produce gas volumes and reaction products that are quite similar to or quite different from those associated with incinerators. Plasma arc processes that use oxygen as the plasma gas and/or have postcombustion chambers may be practically indistinguishable from incineration. On the other hand, a case can be made that plasma arc processes that do not use oxygen as the primary plasma gas differ from incineration, although even in these systems, oxidation generally takes place at a subsequent stage of the process. However, when the plasma arc system is optimally designed and controlled, dioxins, furans, and other hazardous pollutants are likely to be below regulatory limits. One indication of public attitudes toward plasma arc is that after careful consideration, the Assembled Chemical Weapons Assessment (ACWA) program Dialogue Group (NRC, 1999b) accepted plasma arc as a valid alternative to incineration. However, a spokesperson for the Non-Stockpile Chemical Weapons Citizens Coalition characterized plasma arc as a synonym for incineration and expressed concern that NSCMP was prematurely embracing the technology. As with incineration, the degree of public concern about plasma arc may vary with specific implementation and specific location. Finding 2-10. At least some plasma arc systems appear to be robust technology capable of highly efficient destruction of a variety of non-stockpile agents and secondary waste streams in a safe, environmentally acceptable manner. Systems that employ closely coupled reducing and oxidizing zones (controlled pyrolysis) have produced good results in demonstration and actual destruction projects in Europe. Plasma systems may require permitting as incinerators and may raise related public concerns. Recommendation 2-10. Additional testing of plasma arc technology should be done to ensure that proposed plasma arc systems are capable of meeting the requirements of the Environmental Protection Agency (EPA) and state requirements. Chemical Oxidation The use of chemical oxidation to treat liquid secondary waste streams from the RRS and EDS has been discussed extensively in previous reports by this committee (NRC, 2001a, 2001c). Description The use of hydrogen peroxide or Fenton’s reagent, potassium permanganate, Oxone,17 peroxydisulfate, peroxyborate, peroxycarbonate, peroxyphthalate, and UV-activated hydrogen peroxide or ozone oxidation is a promising approach for the treatment of liquid waste streams because of their demonstrated technical effectiveness for similar waste streams, good pollution prevention qualities, and low cost. The reactions are carried out at 80°C to 100°C at atmospheric pressure in aqueous solutions. Under appropriate conditions, the organic constituents of the neutralents and rinsates can be mineralized. In other cases, they are converted to less active compounds. Oxidation without UV activation is preferred. The problems associated with UV activation are discussed in Disposal of Neutralent Wastes (NRC, 2001c). These include the need for special equipment, reduced effectiveness for opaque solutions, and fouling of the optical surfaces. For chemical oxidation not catalyzed by UV light, conventional chemical process equipment and procedures are used. Status Chemical oxidation is a mature process widely used in the chemical industry. Until recently, however, there was no direct experience with the chemical oxidation of the liquid products resulting from treatment of the agent in non-stockpile weapons. UV-activated hydrogen peroxide oxidation was tested in 2001 by the PMNSCM on a 2 percent MEA rinsate simulant using equipment and facilities supplied by Purifics Environmental Technologies.18 Very limited information is available. With the application of 1,550 kWh/m3 of power, the total organic carbon of 286 liters of rinsate was reduced from 10,000 mg/L to about 9 mg/L over a period of 92 hours. The committee was not aware of any reported results of oxidation of neutralent or rinsates without UV activation. The Army is testing persulfate oxidation of neutralents at the Southwest Research Institute (Table 2-4), but no results were available at the time this report was written. However, the successful oxidation or mineralization of closely related materials, including mustard and nerve agents and their hydrolysates, has been documented. Workers at the U.S. Army Edgewood Research, Development, and Engineering Center (Yang, 1995) have conducted laboratory-scale studies on the reaction of VX, GB, GD (soman), and mustard with hydro 17   Oxone, a registered trademark of DuPont Specialty Chemicals, is a triple salt (2KHSO5·KHSO4·K2SO4). 18   Edward Doyle and Joseph Cardito, Technology Test Program for Treatment of NSCMP Feeds, presentation to the committee on September 25, 2001.

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gen peroxide, Oxone, hypochlorite, and peroxydisulfate; they had very favorable results, especially with peroxydisulfate. The committee notes that unlike most other technologies being considered, chemical oxidation without UV activation is not promoted by any technology vendors. The technology is not proprietary, and any organization can design and build the equipment, purchase the reagents, and carry out the operations. Accordingly, it would be up to the Army to take the initiative in the exploration and development of this technology. Technical Issues The greatest potential disadvantage of chemical oxidation is that it may not fully mineralize all of the compounds in the neutralents or may not mineralize them rapidly enough to be practical. Many organics, particularly simple aliphatics and halogenated alkanes, are somewhat recalcitrant to simple chemical oxidation. Long reaction times and large amounts of oxidant may be required to achieve a satisfactory result. Only testing can resolve these issues. The commercialization issues surrounding this technology were discussed in NRC (2001c). Definitive testing of the application of this technology to neutralent wastes was under way as this report was written, but the results were not available to the committee. The testing will determine the applicability of this technology to non-stockpile waste streams and identify the issues to be resolved in scaling it up and commercializing it for these applications. Regulatory Approval and Permitting Issues Provided that chemical oxidation can be demonstrated to be effective in destroying NSCWM liquid secondary waste streams, no particular problems are anticipated in obtaining the necessary regulatory approvals. Public Concerns Public reaction to the use of chemical oxidation of NSCWM secondary waste streams as an alternative to incineration is expected to be very favorable. Emissions from the process are minimal, and the formation of chlorodibenzodioxins and chlorodibenzofurans is expected to be unlikely at low temperatures (this should be verified, however). Wet Air Oxidation The use of wet air oxidation (WAO) to treat liquid secondary waste streams of the RRS and EDS was discussed extensively in previous reports by this committee (NRC, 2001a, 2001b). Description WAO is a hydrothermal process for the oxidative destruction of organic wastes that is carried out at 150­°C to 315­°C and 150 to 3,000 pounds per square inch, absolute (psia). The oxidizing agent is dissolved oxygen. WAO is a mature commercial technology that is used widely in the United States to treat wastewater and various hazardous waste streams. WAO can treat any pumpable fluids provided that the chemical oxygen demand is less than 120,000 mg/L. In the case of NSCWM neutralents, for example, it is estimated that this would require a seven- to ninefold dilution with water.19 Such dilution could be achieved in whole or in part by combining the primary neutralent with the dilute aqueous rinsates. Status WAO is used routinely in commercial applications to treat sewage sludge containing 10 to 15 percent solids. WAO does not fully mineralize organics but instead reduces them to short-chain molecules such as acetic acid. Thus, effluents may have to be treated further by biotreatment, possibly at a POTW. Prior to biotreatment, toxic heavy metals would have to be removed. Arsenic, if present, would be converted to arsenate ion, a form that is more readily stabilized. NSCMP has plans to test WAO for treatment of secondary waste streams (see Table 2-4). Technical Issues As with chemical oxidation, the principal uncertainty surrounding the application of WAO to NSCWM liquid waste streams is whether it is capable of converting the various compounds of concern into materials that are acceptable to a POTW. Planned testing of this technology by the Army should help to resolve this question. The commercialization issues surrounding this technology were discussed in (NRC, 2001a). Definitive testing of the application of this technology to neutralent wastes was under way as this report was written, but the results were not available to the committee. The testing will determine the applicability of this technology to non-stockpile waste streams and identify the issues to be resolved in scaling it up and commercializing it for these applications. Regulatory Approval and Permitting Issues If WAO can be demonstrated to be effective for NSCWM liquid waste streams, no particular problems are anticipated in obtaining the necessary regulatory approvals. However, 19   William Copa, U.S. Filter Zimpro, personal communication to Joan Berkowitz on February 15, 2000.

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because RCRA prohibits dilution as a means of achieving treatment standards, the Army may need to demonstrate that the dilution that is inherent to this process is necessary to achieve the appropriate conditions under which the technology normally operates. Public Concerns No particular public concerns regarding the use of WAO to treat NSCWM secondary waste streams are anticipated, based on its current widespread use as a wastewater treatment technology. Batch Supercritical Water Oxidation The use of batch supercritical water oxidation (batch SCWO) to treat liquid secondary waste streams of the EDS was reviewed in a previous report by this committee (NRC, 2001b). Description A batch SCWO unit is conceptually similar to a pressure cooker. Material to be destroyed is mixed with an oxidizer (such as hydrogen peroxide) and introduced into a pressure vessel, which is heated to a reaction temperature above the critical point of water (374°C, 3,204 psia) and then cooled. Organic materials are mineralized to produce carbon dioxide, nitrogen, and aqueous salts. In principle, batch SCWO could be used to treat either neat agents or more dilute secondary liquid waste streams from chemical neutralization processes. Although both applications were initially considered, the Army is no longer considering the latter, because the volumetric throughput of the batch SCWO process is low compared with the volume of liquid wastes that would be generated by treatment systems such as the EDS. Batch SCWO is still being considered for direct treatment of CAIS vials and bottles and, in the longer term, to replace the neutralization of agent released from chemical munitions following explosive accessing inside the EDS containment vessel. The advantage of the latter process would be that all operations are carried out in one vessel and that it avoids the production of secondary liquid waste streams requiring further treatment. Status Four bench-scale batch SCWO reactors have been constructed at Sandia National Laboratories in Livermore, California, each having a volume of 325 ml. Both H and GB neutralent simulants have been processed in the units, achieving a destruction and removal efficiency (DRE)20 of 99.988 percent. An experiment to test the feasibility of using batch SCWO to destroy CAIS vials was conducted, in which a half-sized simulated CAIS vial (a vial containing neat chloroform) was placed in the batch SCWO. The CAIS vial burst open when the temperature reached about 300°C, demonstrating that no additional device would be needed to access the contents of CAIS vials. A prototype of a combined EDS-batch SCWO does not yet exist. For a combined EDS-batch SCWO reactor, the same 20-inch inner diameter would allow use of the existing EDS-1 door, hinges, and clamps. The length of the vessel would be doubled, from 39 to 78 inches. Throughput rates would depend on the time required for SCWO operations, currently estimated to be 2 to 3 hours, including heating and cooling. The combined EDS-batch SCWO would be able to process up to a 4.2-inch mortar round. Much more testing and scale-up work must be done. The combined EDS-batch SCWO is part of the long-term technology program for FY 2002-2009, with prototype testing scheduled between July 2005 and July 2006. Technical Issues Batch SCWO is part of NSCMP’s long-term technology test program (see Table 2-4). As such, several years of development and scale-up are required before an operational unit is available for testing. Decisions concerning subsequent deployment of this unit would depend on the needs at the time that it is available (mid-2006, at the earliest). Preliminary results on the direct destruction of simulated CAIS vials in a batch SCWO reactor appear promising; however, it remains unclear how widely applicable this approach is to the range of vials and bottles (and the wide range of vial contents) that make up CAIS sets (NRC, 1999a). Direct treatment of CAIS in a batch SCWO has the advantage that no secondary waste streams that require further treatment would be generated; however, the cost-effectiveness of this approach, especially relative to the SCANS plus secondary waste treatment, is unclear. For the combined EDS-batch SCWO, a variety of technical issues must be addressed: the choice of materials of construction, the method used to introduce oxidant into the vessel, the durability of seals, the stability of SCWO reactions in a large-diameter vessel, the methods used to heat the vessel, the possibility of scaling and corrosion under batch SCWO conditions (salts are proposed to be captured in a pan placed in the vessel, but this has not yet been demonstrated), the method used to fabricate the vessel (e.g., single forging vs. welded sections), the impact of repeated explosions followed by thermal and pressure cycles on the integrity of the EDS vessel and SCWO reactor (e.g., crack propagation), the most appropriate method of cooldown and depressurization following munition destruction, and the disposition of process residuals. In addition to the technical issues noted above, the Army would have to demonstrate that a combined EDS-batch 20   DRE is calculated as the percentage of agent destroyed or removed.

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SCWO unit is more cost-effective than alternatives and make a case for the “market” for this unit (i.e., show that the number of non-stockpile items that it will dispose of justifies the costs of technology development). Given the late date of availability of batch SCWO and the existence of alternatives (e.g., EDS followed by incineration of neutralents), the committee questions the cost-effectiveness of this technology and the role that it will have in the destruction of recovered or buried non-stockpile materiel. Other Alternative Individual Treatment Technologies In previous reports (NRC, 2001a, 2001b), the committee evaluated several other alternative technologies that have been considered by the Army for treatment of non-stockpile secondary liquid waste streams, including electrochemical oxidation, continuous mode SCWO, gas-phase chemical reduction, biotreatment, and solvated electron technology. These technologies were evaluated against a number of criteria, including technical effectiveness, safety, permit status, and pollution prevention attributes. All were found to have serious deficiencies in one area or another, especially in comparison with the technologies that the committee considered most promising: chemical oxidation, wet air oxidation, and plasma arc. Consequently, the committee recommended that no further investment be made in developing electrochemical oxidation, supercritical water oxidation (continuous mode), gas-phase chemical reduction, biotreatment, or solvated electron technology for the treatment of non-stockpile secondary liquid waste streams. During the preparation of this report, the committee reviewed its earlier analysis and found nothing that would change its conclusions. Finding 2-11. The Army has considered three possible applications of batch SCWO: as a treatment method for liquid secondary waste streams from the RRS or EDS as a direct treatment method for CAIS vials or bottles, instead of the RRS or SCANS as an alternative to chemical neutralization in the EDS explosion containment chamber The low volumetric throughput of batch SCWO appears to make it inappropriate for option 1. The advantages of option 2 over existing treatment alternatives are unclear. While option 3 offers the possibility of eliminating the generation of neutralent, the committee sees significant technical issues associated with the thermal and pressure cycling of the EDS vessel for SCWO operation. This technical immaturity makes it unlikely that option 3 could contribute to the Army’s NSCWM destruction mission by PMNSCM’s completion goal of April 29, 2007. Recommendation 2-11. The Army should continue R&D on batch SCWO only if it can demonstrate that the technology is more cost-effective than alternatives and that the number of non-stockpile items it will dispose of justifies the costs of technology development. Finding 2-12a. The Army’s plan to destroy highly organic neutralent waste streams by incineration is appropriate. Plasma arc systems are also adaptable to destruction of highly organic neutralents when incineration is not available or acceptable. Use of such high-temperature processes to destroy aqueous secondary wastes would be inefficient, although it may be expedient in some cases. If such aqueous liquids cannot be disposed via publicly or federally owned treatment works (POTW or FOTW), chemical oxidation or wet air oxidation may be attractive alternatives for this purpose. Finding 2-12b. Several other alternative treatment technologies being investigated by PMNSCM appear to be less appropriate for the needs of the program. The current analysis points out the need for more information on the scope of applicability of UV-catalyzed oxidation and calls into question the need to continue development of batch SCWO processing. The potential applicability of UV oxidation is not well understood, and batch SCWO, when combined with explosive accessing in an EDS, is technologically immature. Recommendation 2-12a. The PMNSCM should continue its research and development program on chemical oxidation and wet air oxidation of neutralents and rinsates. Recommendation 2-12b. Consistent with the committee’s earlier analyses (NRC, 2001a, 2001b) there should be no further funding for the development of biological treatments, electrochemical oxidation, gas-phase chemical reduction, solvated electron technology, and continuous SCWO technologies for the treatment of neutralents and rinsates. PMNSCM should monitor progress in technologies being developed under the Assembled Chemical Weapons Assessment (ACWA) program but should evaluate ACWA technologies for the treatment of non-stockpile neutralents and rinsates only if no additional investment is required. Neutralization (Chemical Hydrolysis) One potentially attractive approach to the destruction of the chemical warfare agents is chemical hydrolysis reaction with water to form products of reduced toxicity. In a chemical demilitarization context, the process is known as “neutralization,” because it neutralizes the toxic properties of the chemical agent.

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FIGURE 2-5 Hydrolysis of the nerve agent GB (sarin). SOURCE: Flamm (1987). Description Hydrolysis is usually carried out under mild conditions, typically atmospheric pressure and less than 100°C, in conventional chemical process equipment. Because some of the hydrolysis products are acids, a base such as lime or sodium hydroxide is often used to chemically neutralize the reaction mixture. The base may also accelerate the hydrolysis, permitting it to be carried out more rapidly and with more efficient use of process equipment. Neutralization is potentially applicable to the whole family of phosphate-based nerve agents, to blister agents, and to binary precursors of nerve agents. The hydrolysis of the nerve agent GB (sarin) has been studied extensively and is described by the equation in Figure 2-5. The main neutralization processes in the non-stockpile program utilize aqueous monoethanolamine (MEA) as the neutralizing reagent for HD, GB, and VX agents. One of the virtues of this approach is that the neutralents thus produced are single-phase liquids.21 After neutralization, the products are neutral or alkaline solutions containing inorganic salts and organic compounds of greatly reduced toxicity. The product solutions can be treated further to produce “mineralized” products suitable for disposal in the same way as normal chemical wastes. Some such treatment is required to destroy gross quantities of CWC Schedule 2 chemicals (e.g., the sodium salt of IMPA in the above reaction) so that they cannot be converted back to chemical agents. Status The U.S. Army’s experience with neutralization of the nerve agent GB confirmed the potential virtues of this technology, as well as some practical problems associated with it. In an extensive field program carried out from 1973 to 1976 at the Rocky Mountain Arsenal, 4,188 tons of GB were hydrolyzed successfully (Flamm et al., 1987). The nerve agent was treated with a large excess of aqueous sodium hydroxide to produce a water solution of inorganic salts and organic compounds. The solutions were evaporated and the solid residues deposited in a hazardous waste landfill. With hindsight, it appears that working with a smaller ratio of alkali to GB would have substantially reduced the amount of solid wastes produced in the campaign. In addition to the U.S. Army experience with hydrolysis of GB, various neutralization processes have also been used to destroy multiton quantities of the agent in Great Britain, Canada, the countries of the former Soviet Union, and Iraq. Overall, chemical hydrolysis is attractive for the destruction of chemical agents and their precursors because it is simple and well proven, uses standard commercial process equipment, and operates under mild temperature and pressure. Neutralization of Binary Components Chemical neutralization is being considered for disposal of the PBA inventory of the chemicals DF (CH3POF2) and QL (CH3P(OEt)(OCH2CH2N-i-Pr2)), which are precursors of the nerve agents GB and VX, respectively. Both compounds are highly toxic although much less lethal than GB and VX. Both DF and QL were destroyed by hydrolysis on a significant scale in a campaign at Aberdeen Proving Ground in 1997.22 As seen in Figure 2-6, hydrolysis of DF with warm water yielded an aqueous solution of hydrogen fluoride and methylphosphonic acid (MPA) and its derivatives. Like the caustic hydrolysis of GB, the reaction of DF with water proceeded exothermally. The DF neutralent was sent to a commercial TSDF for disposal. Implementation of binary precursor neutralization does not appear in current NSCWM disposal budgets. A pilot test program for neutralization of DF and QL was scheduled to begin in late September 2001 (see Table 2-4) but has not started due to restrictions on the movement of these two 21   Lucille Forrest and James Horton, Office of the PMNSCM, personal communication to G.W. Parshall on October 1, 2001. 22   Christopher Ross, PMNSCM, presentation to the committee, November 8, 2001.

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FIGURE 2-6 Hydrolysis of DF with warm water. SOURCE: Darryl Palmer, Office of the PMNSCM, “Hydrolysis of DF, Hydrolysis of QL,” personal communication to George Parshall, December 24, 2001. chemicals. If neutralization is chosen for use at PBNSF, a punch-drain-neutralize component would be built and would operate in the 2006-2007 period. Technical Issues As demonstrated by the campaigns at APG, the neutralization of DF and QL should be considered a mature technology, especially in light of the Army’s experience in destroying large quantities of GB by a similar process. The neutralization of DF and QL can be carried out in ordinary commercial stirred-tank reactors, which are available in almost any size appropriate for the task. The neutralents may require treatment before ultimate disposal because of residual toxicity and because they contain methylphosphonic acid (MPA) derivatives that are CWC Schedule 2 precursors. (DF and QL are specifically listed in the treaty as Schedule 1 precursors.) Regulatory Approval and Permitting Issues In general, neutralization seems to be regarded by regulators and the public as a relatively safe technology. Regulatory approval and permitting should be much easier than for technologies employing high temperatures or pressures. However, a large amount of secondary waste is produced by neutralization processes, which requires further treatment prior to ultimate disposal. Public Concerns The mild reaction conditions and minimal emissions from neutralization have generally led to its acceptance by the public as a demilitarization technology. Open Burning/Open Detonation OB/OD is a traditional process that has been used to destroy waste munitions, both conventional and chemical, for many years. Description Military explosive ordnance disposal personnel are taught to use OB/OD to dispose of individual chemical rounds by countercharging the round with 5 pounds of explosive to every pound of chemical fill (OD) or by remotely opening and burning the chemical fill (OB). Using OD, the nearly instantaneous heat and pressure of the detonation of the surrounding explosives is believed to destroy most of the chemical fill, rendering the munition harmless in an inexpensive and expeditious manner. OB can be used in a field process whereby a munition is positioned on a large burn pile and is opened explosively from a distance after remote initiation of the burn. Status OB/OD remains a useful disposal option. For example, a military team working with explosive ordnance devices may recommend using OD to dispose of chemical munitions that are believed to be in a dangerous condition, either because the fuze is armed and shock sensitive or because the munition has seriously deteriorated. Using OD, the munition need not be moved because it can be disposed of in place. Technical Issues OB/OD of non-stockpile munitions is simple, inexpensive, and expedient. No secondary waste streams requiring further treatment and disposal are produced unless soil and fragments surrounding the OB/OD site are removed. Using the OB/OD for disposal of chemical munitions is based, of course, on the assumption that the area can withstand a significant high-order detonation and that no personnel or property are located in the downwind hazard area. At the same time, OB/OD has several disadvantages. The process is noisy, and the high ratio of explosives to agent required for OD and the large fire pit required for OB make OB/OD impractical for the treatment of very large munitions containing large quantities of agent. There is little information on how much of the chemical fill of a weapon

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remains after OB/OD disposal and how much of it is released into the atmosphere as vapors or particulates. In addition, the disposal of conventional high-explosive munitions by OB/OD has resulted in measurable environmental contamination from high-explosive residues. At some sites, such as the Massachusetts Military Reservation, long-term, heavy use of military high explosives has contaminated the groundwater. Regulatory Approval and Permitting Issues Today’s environmental regulations make disposal of non-stockpile munitions by OB/OD difficult or impossible, except perhaps under extreme (e.g., warfare) conditions. For example, the Army initially proposed OD to treat the GB bomblets found at RMA, but this option was strongly opposed by state of Colorado regulators. The Army lacks critical information about environmental releases of agent and other hazardous materials during OB/OD, and any attempt to permit OB/OD for routine or emergency disposal operations would likely face strong regulator and public opposition. Public Concerns Public concerns about OB/OD include the noise from repeated detonations and uncertainties about the types and quantities of toxic materials released in the process. Strong public opposition to future use of OB/OD for treatment of CWM can be expected. Integrated Ballistic Tent and Foam System The Integrated Ballistic Tent and Foam System (herein-after called the tent-and-foam system) allows partially contained blow-in-place disposal of chemical munitions (as large as 8-inch projectiles) that cannot be inserted into a mobile disposal system (e.g., the EDS) or transported to a disposal facility because they are badly deteriorated or are extremely susceptible to accidental detonation. The inability to safely move the chemical munition is expected to be rare but very problematic. Description The tent-and-foam system consists of an inner tent filled with blast suppressive foam, an outer ballistic tent, and an integrated air pollution control system. The tent-and-foam system is designed to contain the blast, fragments, and toxic emissions resulting from the detonation of a chemical munition using 5 pounds of donor explosive for every pound of chemical agent fill. The inner primary tent, constructed of a ballistic material designed to contain blast overpressure and fragments from the detonation, is 6 feet on each side at the bottom, 2 feet on each side on the top, and 4 feet high. The primary tent is supported by flexible fiberglass rods and a fill sock that allows the interior of the tent to be filled with a combination of blast-suppressive foam and chemical decontaminating agent to contain the blast and neutralize the released chemical agent. The outer secondary tent is made of Kevlar or another ballistic material and is supported by an air-rib system. It is placed over the primary tent to provide vapor containment of chemical agent and is connected with flexible stainless steel hoses to the air pollution control system. A slight negative pressure is maintained within the secondary tent prior to detonation of the chemical munition. The air pollution control system has an acid gas wet scrubber and a charcoal filtration unit, transported on one trailer. The gases flow from the secondary tent through the acid gas scrubber and demister and then through the carbon high-efficiency gas adsorbers and a high-efficiency particulate adsorber. Although some gases are expected to escape the system, most of the toxic chemical agent fill of the munition will be either consumed during the detonation or captured in the air pollution control system. Most of the solid waste, consisting of the fragmented remains of the munition, will remain within the footprint of the secondary tent, but some is expected to escape randomly. It is expected that one munition can be disposed of in one day using the tent-and-foam system, which cannot be reused. Status The tent-and-foam system is in the final stages of development; however, it has not been tested with simulants or chemical agent. When the Army completes its testing, the system will likely replace OB/OD for destruction of NSCWM in nonwarfare conditions. Technical Issues While the committee anticipates that the tent-and-foam system may reduce the amount of toxic residue and confine the spread of contamination to a smaller footprint compared with OB/OD, test data are required to ensure that it reduces contamination to an acceptable level. Regulatory Approval and Permitting It is highly unlikely that regulators will permit the use of the tent-and-foam system until the amount of released agent can be determined. Testing to determine the amount of agent and other emissions released from the system during disposal of chemical munitions was scheduled to begin in

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March 2002 using simulants in the Prototype Detonation Test and Destruction Facility in the Edgewood area of Aberdeen Proving Ground. Public Concerns Public concerns about the tent-and-foam system are likely to be similar to those about OD. However, the fact that the blast is partially contained and that the foam and the air pollution control system are expected to neutralize or capture much of the agent that survives the initial blast may make the tent-and-foam system a more attractive option. Multiple-Round Containers Several mobile treatment systems discussed earlier in this chapter can be dispatched to the site of an NSCWM discovery to perform on-site treatment of the item. An alternative to the use of mobile systems is to overpack the chemical waste to be treated in a multiple-round container (MRC) and transport it to an off-site facility for treatment or storage. MRCs are a family of six overpack containers designed to allow the safe transport of NSCWM. The dimensions and capabilities of MRCs are shown in Table 2-5. MRCs are not designed or intended to contain the accidental detonation of a chemical munition. They should be considered only as overpack containers for containment of internal leaking and for protection of their contents during accidents or rough handling. Any chemical munitions to be transported in an MRC must first be determined to be safe, that is, explosion-proof, to transport by military ordnance experts. Fragile items such as CAIS may also be transported. Individual CAIS vials are usually placed in cardboard mailing tubes and then packed in the MRC with vermiculite to act as a cushioning material. Complete PIGs can also be transported in the MRC 12x56, which was designed with this purpose in mind. Neutralents from treatment of NSCWM are generally considered hazardous wastes. Their transport does not require MRCs; instead, they may be transported in DOT-approved containers according to the regulations controlling hazardous wastes. Status The MRCs were specifically designed, tested, and fielded for transport of CWM and exceed the United Nations’ performance-oriented packaging requirements. They have been fielded and are currently in use, having been approved by the Department of Defense (DOD) and DOT for the storage and transportation of RCWM in the public domain. Technical Issues No outstanding technical issues remain to be resolved with respect to the use of MRCs. Regulatory Approval and Permitting Issues Transportation of NSCWM is heavily regulated (see discussion in Appendix G). State regulators have not identified any deficiencies in the design or use of MRCs. In some cases, such as when NSCWM is discovered in an urban area where it is not feasible to bring in a mobile treatment system such as the EDS—e.g., the Spring Valley site in Washington, D.C. (U.S. Army, 2002a)—transportation is the only option. Even here, however, the Army faces great challenges in identifying a site willing to receive the NSCWM. PMNSCM has indicated that it has “worn out the welcome mat” at sites such as APG and PBA, which accepted such shipments in the past. As a result, PMNSCM no longer considers the transportation of NSCWM to be an option for routine use; it is considered as an option only in extreme or emergency circumstances. TABLE 2-5 Multiple-Round Containers and Their Contents MRC Designed to Contain MRC 7x27 Items up to 7 in. in diameter, 27 in. long, and weighing up to 100 lb MRC 9x41 Items up to 9 in. in diameter, 41 in. long, and weighing up to 200 lb MRC 12x56 Items up to 12 in. in diameter, 56 in. long, and weighing up to 200 lb MRC 16.5x5.5 Items up to 16.5 in. in diameter, 5.5 in. long, and weighing up to 50 lb MRC 21x79 Items up to 21 in. in diameter, 79 in. long, and weighing up to 1,000 lb MRC 30x40 Items up to 30 in. in diameter, 40 in. long, and weighing up to 850 lb   SOURCE: Provided to the committee by Thomas Huff, Office of the PMNSCM, October 17, 2001.

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Public Concerns There tends to be strong opposition from local public groups to the transportation of hazardous materials such as NSCWM through their communities. There is also great reluctance on the part of public stakeholders at potential receiving sites to accept shipments of NSCWM (especially from out of state) lest these sites become a dumping ground for such materiel in the future. Finding 2-13a. MRCs will be an extremely valuable asset if the Army pursues the transportation of small quantities of recovered CAIS to the RRS or commercial disposal facilities or the disposal of NSCWM at stockpile disposal facilities. Finding 2-13b. In some cases, transportation of NSCWM from the site of its recovery to a secure location will be the most appropriate option. Recommendation 2-13. The Army should work with state regulators at specific installations to allow transport of NSCWM from off-site locations for storage or treatment under extreme or emergency circumstances.