Executive Summary

Chemical warfare materiel (CWM) encompasses diverse items that were used during 60 years of efforts by the United States to develop a capability for conducting chemical warfare. Non-Stockpile CWM (NSCWM) is materiel not included in the current U.S. inventory of chemical munitions and includes buried materiel, recovered materiel, components of binary chemical weapons, former production facilities, and miscellaneous materiel. NSCWM that had been buried on former military sites is increasingly being dug up as the land is developed for other purposes. Other NSCWM may be found on or near the surface at former research facilities or test and firing ranges.

Through its Chemical Stockpile Disposal Program (CSDP), the U.S. Army is the designated executive agent for destroying CWM under the terms of the 1997 international Chemical Weapons Convention (CWC).1 Disposal of nonstockpile CWM is being handled by the Non-Stockpile Chemical Materiel Product (NSCMP), under the Program Manager for Chemical Demilitarization (PMCD). Because NSCWM is stored or buried at many locations, the Army is developing transportable treatment systems that can be moved from site to site as needed. Originally, the Army planned to develop three transportable treatment systems for nonstockpile chemical materiel: the rapid response system (RRS), the munitions management device (MMD), and the explosive destruction system (EDS).

The RRS was designed to treat recovered chemical agent identification sets (CAIS), which contain small amounts of chemical agents and a variety of toxic industrial chemicals. These sets were developed as training aids, and, unlike chemical munitions, they were not designed with lethal intent. The MMD systems were conceived to dispose of nonstockpile chemical munitions and sample containers deemed stable enough for transport and long-term storage. The EDS was originally developed to destroy nonstockpile items that were deemed to be too unstable for transport or long-term storage; however, it can also be used to treat limited numbers of stable chemical munitions, with or without explosive components. The MMD systems proved to be complex, expensive, and difficult to permit, so their development was discontinued. The EDS, which is smaller and less complex than the MMD, is now considered the Army’s primary transportable system for treatment of small quantities of nonstockpile items.2

This report is a supplement to an earlier report (NRC, 2001a), which evaluated eight alternative technologies3 for destruction of the liquid waste streams from the RRS and the MMD. This report evaluates the same technologies for the

1  

Formally known as the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction, the CWC requires the destruction of the chemical weapons in the stockpile by 2007 and any nonstockpile weapons in storage at the time of the treaty ratification (1997) within 2, 5, or 10 years of the ratification date, depending on the type of chemical weapon or on the type of chemical with which an item is filled. Any chemical weapons “discovered…after the initial declaration of chemical weapons shall be reported, secured and destroyed in accordance with Part IV (A) of the Verification Annex” (CWC Article IV, Paragraph 9). Thus, NSCWM buried before January 1, 1997, is excluded from the treaty requirements as long as it remains buried. However, once this CWM is dug up and removed from the ground, the recovered CWM must be identified, declared under the CWC, inspected, and destroyed as soon as possible (U.S. Army Final Programmatic Environmental Impact Statement, 2001, volume 1, pp. 1–3).

2  

The EDS Phase 1 (EDS-1) can treat munitions containing up to one pound equivalent TNT; the larger EDS Phase 2 (EDS-2), under design and development, will treat munitions containing up to three pounds equivalent TNT. All EDS testing to date has been with the EDS-1. The EDS-1 is intended for use with World War I and World War II vintage chemical warfare materiel produced prior to 1945. Post-World-War II projectiles have larger bursters that exceed the capacity of the system.

3  

The technologies were chemical oxidation, wet-air oxidation, electrochemical oxidation using Ag(II) or Ce(IV), supercritical water oxidation, solvated electrons, biodegradation, gas-phase chemical reduction, and plasma arc.



The National Academies | 500 Fifth St. N.W. | Washington, D.C. 20001
Copyright © National Academy of Sciences. All rights reserved.
Terms of Use and Privacy Statement



Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System Executive Summary Chemical warfare materiel (CWM) encompasses diverse items that were used during 60 years of efforts by the United States to develop a capability for conducting chemical warfare. Non-Stockpile CWM (NSCWM) is materiel not included in the current U.S. inventory of chemical munitions and includes buried materiel, recovered materiel, components of binary chemical weapons, former production facilities, and miscellaneous materiel. NSCWM that had been buried on former military sites is increasingly being dug up as the land is developed for other purposes. Other NSCWM may be found on or near the surface at former research facilities or test and firing ranges. Through its Chemical Stockpile Disposal Program (CSDP), the U.S. Army is the designated executive agent for destroying CWM under the terms of the 1997 international Chemical Weapons Convention (CWC).1 Disposal of nonstockpile CWM is being handled by the Non-Stockpile Chemical Materiel Product (NSCMP), under the Program Manager for Chemical Demilitarization (PMCD). Because NSCWM is stored or buried at many locations, the Army is developing transportable treatment systems that can be moved from site to site as needed. Originally, the Army planned to develop three transportable treatment systems for nonstockpile chemical materiel: the rapid response system (RRS), the munitions management device (MMD), and the explosive destruction system (EDS). The RRS was designed to treat recovered chemical agent identification sets (CAIS), which contain small amounts of chemical agents and a variety of toxic industrial chemicals. These sets were developed as training aids, and, unlike chemical munitions, they were not designed with lethal intent. The MMD systems were conceived to dispose of nonstockpile chemical munitions and sample containers deemed stable enough for transport and long-term storage. The EDS was originally developed to destroy nonstockpile items that were deemed to be too unstable for transport or long-term storage; however, it can also be used to treat limited numbers of stable chemical munitions, with or without explosive components. The MMD systems proved to be complex, expensive, and difficult to permit, so their development was discontinued. The EDS, which is smaller and less complex than the MMD, is now considered the Army’s primary transportable system for treatment of small quantities of nonstockpile items.2 This report is a supplement to an earlier report (NRC, 2001a), which evaluated eight alternative technologies3 for destruction of the liquid waste streams from the RRS and the MMD. This report evaluates the same technologies for the 1   Formally known as the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction, the CWC requires the destruction of the chemical weapons in the stockpile by 2007 and any nonstockpile weapons in storage at the time of the treaty ratification (1997) within 2, 5, or 10 years of the ratification date, depending on the type of chemical weapon or on the type of chemical with which an item is filled. Any chemical weapons “discovered…after the initial declaration of chemical weapons shall be reported, secured and destroyed in accordance with Part IV (A) of the Verification Annex” (CWC Article IV, Paragraph 9). Thus, NSCWM buried before January 1, 1997, is excluded from the treaty requirements as long as it remains buried. However, once this CWM is dug up and removed from the ground, the recovered CWM must be identified, declared under the CWC, inspected, and destroyed as soon as possible (U.S. Army Final Programmatic Environmental Impact Statement, 2001, volume 1, pp. 1–3). 2   The EDS Phase 1 (EDS-1) can treat munitions containing up to one pound equivalent TNT; the larger EDS Phase 2 (EDS-2), under design and development, will treat munitions containing up to three pounds equivalent TNT. All EDS testing to date has been with the EDS-1. The EDS-1 is intended for use with World War I and World War II vintage chemical warfare materiel produced prior to 1945. Post-World-War II projectiles have larger bursters that exceed the capacity of the system. 3   The technologies were chemical oxidation, wet-air oxidation, electrochemical oxidation using Ag(II) or Ce(IV), supercritical water oxidation, solvated electrons, biodegradation, gas-phase chemical reduction, and plasma arc.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System destruction of liquid waste streams produced by the EDS. Although it focuses on the destruction of EDS neutralent, it also takes into consideration the ability of posttreatment technologies to process the more dilute water rinses that are used in the EDS following treatment with a reagent. Between November 1999 and November 2000, the EDS Phase 1 (EDS-1) was tested at a military installation at Porton Down in the United Kingdom. In early 2001, it was used in an emergency action to dispose of six bomblets containing the nerve agent sarin at Rocky Mountain Arsenal (RMA) in Colorado. Subsequently, four more bomblets were discovered during remediation of the same area at RMA. At this writing, the EDS-1 had been dispatched to dispose of these also. As a result of the success of these operations, the decision was made to discontinue development of the MMD,4 another mobile system that used the same process chemistry as the EDS to destroy chemical agent but that was both more complex and less versatile than the EDS. The EDS produces four types of liquid waste streams for which treatment options are being evaluated: (1) a neutralent resulting from treatment of the chemical agent with an alkaline chemical reagent, (2) rinsates resulting from washing the EDS vessel with clean water to remove any residues of reagent and reaction products remaining after treatment, (3) cleaning solution consisting of washes (water and detergent) that are made between processing of each munition, and (4) final washes (using, for example, water and acetic acid) carried out after completing a munitions campaign. Neutralent wastes from the EDS are expected to be classified as hazardous wastes under the Resource Conservation and Recovery Act (RCRA)5 (U.S. Army, 2001g). The Army’s current plan is to send them to a permitted hazardous waste incinerator for final disposal. Rinsates and cleaning solution from the EDS generally have much lower concentrations of hazardous chemicals and are more likely to be classified as nonhazardous wastes.6 Assuming rinsates and cleaning solution meet the pretreatment standards specified by the Clean Water Act, these waste streams may be eligible for discharge to a publicly owned treatment works (POTW) or an equivalent federally owned treatment works (FOTW). The incineration of chemical agents has generated opposition among some public interest groups, and this opposition may be extended to the incineration of EDS neutralents, even though the concentration of any remaining agent in the neutralents will be miniscule, ranging from undetectable to a few parts per million (ppm). As a result of this public concern, the Army is investigating alternative (nonincineration) technologies for disposing of EDS neutralents and has asked the National Research Council (NRC) for advice. The committee wishes to stress that this report is a supplemental evaluation that is focused on the destruction of EDS liquid waste streams. Nothing discussed here should be interpreted as the committee’s evaluation of the EDS as a complete operating system. Such an evaluation would examine issues such as the structural integrity of the EDS with repeated use, operational procedures, the process chemistry, and whether a secondary vapor containment structure is needed. A summary of NSCWM that has been destroyed to date by the EDS, as well as the main constituents of the liquid waste streams, is given in Table ES-1. The principal agent fills of nonstockpile munitions encountered are expected to be phosgene (CG), sulfur mustard (H, HD), and sarin (GB). In addition to these fills, it is possible that some nonstockpile items containing VX7 as well as arsenic-derived chemical agents such as lewisite, an organoarsenic TABLE ES-1 EDS-1 Liquid Waste Streams Considered in This Study Agent Fill Items Destroyed to Date Key Constituents of Liquid Waste Streams Phosgene (CG) 4 cylinders, 7 mortar rounds Water, NaOH, NaCl, metals Sulfur mustard (HD) 2 cylinders, 12 mortar rounds or projectiles Water, MEA, volatile and semivolatile organics, metals, HD degradation products Sarin (GB) 1 cylinder, 10 bomblets Water, MEA, GB degradation products, volatile and semivolatile organics, metals   SOURCE: Compiled by the NRC from Army sources. 4   Lt. Col. Chistopher Ross, Product Manager, Non-Stockpile Chemical Materiel Project, “U.S. Army Non-Stockpile Chemical Materiel Product (NSCMP) Project Overview/Status,” presentation to the committee, March 15, 2001. 5   Under RCRA, a substance is determined to be a hazardous waste either because it is listed as such in the federal or state regulation (a listed hazardous waste) or because it exhibits one or more characteristics of hazardous waste, as defined in the hazardous waste regulations (e.g., corrosivity), or because it is derived from a listed waste. 6   High levels of chloroform—a listed hazardous waste under RCRA— were observed in EDS cleaning solutions from the RMA tests (Appendix C, Table C-1). The source appears to be the particular type of lubricant/sealant used to seal joints. The chloroform is therefore not a necessary constituent of the waste stream and could be eliminated by using a different formulation of sealant/lubricant. 7   Although there are no known nonstockpile munitions containing the nerve agent VX, there are about 100 VX-filled containers in the nonstockpile inventory. Some of these—for example, glass bottles and vials—can be disposed of in the RRS, while others—for example, steel Department of Transportation (DOT) bottles and cylinders—are potential candidates for disposal in the EDS should the Army decide to do so.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System blister agent, may also be processed in the EDS. If this processing does take place, arsenic compounds such as sodium arsenite (from treatment with sodium hydroxide) will be produced, and these compounds will require conversion to relatively insoluble arsenate salts as part of the posttreatment of the EDS neutralent. STATEMENT OF TASK On March 16, 2001, the Army Product Manager for the NSCMP requested that the NRC undertake a supplemental assessment of alternative technologies for destruction of EDS liquid waste streams. The statement of task is as follows: The NRC will: Examine alternative destruction technologies for liquid waste streams generated from the Explosive Destruction System (EDS). Discuss the regulatory approval issues and obstacles for the combined use of the EDS and the alternative technologies that treat the EDS secondary waste streams. COMMITTEE APPROACH As in the previous study (NRC, 2001a), the committee began by establishing some boundary conditions. Only liquid neutralent wastes from the EDS were considered, in accordance with the statement of task. Treatment of solid wastes, such as metal munition bodies, packing materials, and carbon air filters, was not considered. Waste solids from the EDS include metal fragments (from the munition bodies and the fragmentation suppression system), dunnage, used carbon filters, and disposable personnel protective equipment. These solids will be bagged, placed in waste containers, and disposed of in a hazardous waste landfill. The treatment goals for the neutralent destruction technologies considered were taken to be solids that could be disposed of in an approved (i.e., permitted) landfill and liquids that could be released to a POTW or FOTW.8 Air discharges from the neutralent treatment technologies should contain primarily carbon dioxide, water vapor, and nitrogen. The primary analytical approach in this report was to evaluate the ability of alternative technologies to process EDS liquid waste streams, taking note of any differences between these waste streams and those generated by the MMD considered previously (NRC, 2001 a). The committee then examined the extent to which any differences between the EDS and MMD liquid waste streams might alter its earlier recommendations on alternative technologies for destruction of these wastes. However, the committee notes that several important developments have occurred since the publication of the earlier report, Disposal of Neutralent Wastes (NRC, 2001a): The MMD program has been suspended; this means that the liquid waste streams generated by nonstockpile mobile treatment systems will be primarily from the EDS, with a small volume from the RRS. New data have become available regarding the performance of several of the alternative technologies, both from the Army’s Technology Testing Program (see Chapter 3) and from its Assembled Chemical Weapons Assessment (ACWA) program, which was reviewed by another NRC committee (NRC, 1999a, 2000). The committee’s earlier recommendations are also reconsidered in light of recent test results from both the Army’s Technology Testing Program and its ACWA program. The committee also considered the criteria for public and regulatory acceptability that are likely to affect the selection of alternative destruction technologies. It identified several regulatory approval/permitting (RAP) issues associated with EDS liquid waste disposal, discussed the regulatory status of these wastes, and developed several findings and recommendations on regulatory and public acceptability issues. FINDINGS AND RECOMMENDATIONS Technical Issues Finding: Neutralents from the EDS are similar to those from the MMD owing to similar treatment chemistries. However, there could be three differences: The potential presence of residual explosives or explosive-derived organic compounds in the EDS neutralents and rinsates. The MMD and the EDS produce different liquid wastes because of the different ways that munitions are processed. The MMD does not process items containing explosives, while the EDS can handle munitions containing bursters and/or fuzes. The EDS also uses explosives to open the munition and detonate any explosives contained therein. Potentially higher concentrations of dissolved or suspended metals (e.g., Hg, Pb, Cu, and Al) in EDS neutralents and rinsates owing to explosive accessing of the munition and/or the presence of fuzes or bursters. The fragmentation of the munition bodies may expose more metal surface to the 8   The committee felt that, on the one hand, a technology need not be excluded if it did not completely mineralize the neutralents, as long as the resulting liquids could be sent for final treatment at a POTW/FOTW. On the other hand, it felt that multiple treatment technologies should not be necessary; the selected technology should be able to destroy neutralent such that the residuals could be either released to a POTW/FOTW or sent to a permitted landfill.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System monoethanolamine (MEA) reagent,9 which is a good extractant for some of these metal ions. In addition, the detonator materials in fuzes, such as lead azide and mercury fulminate, may introduce some highly toxic metal ions. The potential presence of arsenic compounds in the EDS neutralent from a small number of munition fills (the MMD was not intended to treat agents containing arsenic). Finding: The fills expected to be processed most frequently in the EDS are sulfur mustard (H, HD), phosgene (CG), and—to a lesser extent—sarin (GB). Items filled with other agents—such as lewisite (L), which contains arsenic, or the nerve agent VX—are expected to be encountered much less often, but they do exist in the nonstockpile inventory. The Army has conducted operational testing of the EDS only for munitions containing H, CG, and GB. Thus, the committee’s analysis focused mainly on liquid waste streams resulting from EDS treatment of these three types of agent. However, because lewisite munitions are known to exist in the inventory and may be treated in the EDS, the committee also considered in its analysis the effect of high concentrations of arsenic compounds. Finding: If agents containing arsenic (such as lewisite) are processed in the EDS, additional treatment steps will be needed to remove the arsenic from the EDS neutralent or reduce its mobility in treated solids. In these rare cases, however, suitable treatment chemistries are known and have been demonstrated to be effective. Finding: The EDS neutralization process and subsequent water rinses produce four liquid waste streams in two categories: (1) organic-rich liquids consisting of the neutralent and a reagent-based rinse and (2) cleaning solutions and final washes containing relatively low concentrations of organics. Recommendation: The committee recommends that the Army consider separate treatment strategies for organic-rich liquids and these other aqueous liquids, since their chemical properties and regulatory status are different. Finding: Chemical analyses of EDS neutralents and rinsates obtained from testing of HD, CG, and GB in the EDS may not have accounted for some species, such as energetic compound decomposition products, that may be encountered during operations. Recommendation: The Army should review the sampling and analytical techniques employed at Porton Down and at RMA to ensure they are sufficiently sensitive and complete to detect any species of agent, energetics, and other components that could be in concentrations high enough to be of concern to human health or the environment. Finding: The two-track approach10 recommended for selecting treatment technologies for RRS and MMD neutralents in the committee’s previous report (NRC, 2001a) remains valid for EDS liquid waste streams. However, based on new and preliminary results from NSCMP’s Technology Test Program, as well as test results on some of the technologies obtained in the Army’s Assembled Chemical Weapons Assessment (ACWA) Program, the preferential ranking of technologies in the resource investment track has changed, as described in the following recommendation. Recommendation: The NSCMP should pursue a two-track strategy to identify a suitable treatment technology for EDS liquid waste streams. As part of the first track, the NSCMP should take advantage of available equipment that would require little or no investment (that is, it should piggyback on alternative technologies from the ACWA Program or on existing commercial technologies, such as chemical oxidation, wet-air/O2 oxidation, or plasma arc11 technology). The committee judged that if any of these existing and available technologies can accomplish the task safely, this would be a relatively rapid and inexpensive course of action. If, on the other hand, none of the existing and available technologies can be used as is—for example, if substantial research and development resources would be needed to adapt them to the destruction of nonstockpile neutralents— the committee recommends that NSCMP, as part of track two, should invest first in chemical oxidation and wet-air/O2 oxidation. Only if these technologies cannot be adapted eas 9   The choice of MEA as a reagent was based on extensive previous experience with it in other CWM programs, its ability to dissolve the agents, miscibility with water, low corrosivity with stainless steel, and low flammability. 10   In the report on disposal of neutralent wastes (NRC, 2001a), the first track of the two-track approach contained technologies that did not need any Army development investment. The second track consisted of alternative technologies requiring investment. The earlier report recommended investigating the track one technologies before turning to track two. 11   One commercial plasma arc technology (the PLASMOX process) has treated a chemical warfare agent in Switzerland. Although it has not yet been permitted for use on any hazardous waste in the United States, it has also been used for the commercial treatment of hazardous waste in Switzerland. The Army has represented to the committee that there are a number of plasma arc facilities permitted in the United States, primarily for treatment of medical wastes, and that it intends to test some of these plasma arc designs. The committee has not reviewed the emissions data from the PLASMOX treatment of chemical agent or from these commercial facilities. Plasma arc technologies may emit low levels of polychlorinated dibenzodioxins. Since PLASMOX uses oxygen, it may be considered by some regulators and some members of the public as a more sophisticated incinerator.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System ily does the committee recommend that the Army consider investing R&D resources in supercritical water oxidation (batch mode).12 The committee recommends that no further resources be spent on development of electrochemical oxidation, supercritical water oxidation (continuous mode), gas-phase chemical reduction, biotreatment (by itself), or solvated electron technology for this purpose. Finding: The Army has an ongoing program to test several alternative technologies for their ability to destroy EDS neutralents. Based on information provided to it regarding this test program, the committee has several concerns: The tests are often being conducted with simulated EDS neutralents mixed from laboratory chemicals rather than with actual EDS neutralents. The Army does not appear to have identified key tracking compounds13 that are the most difficult to destroy and whose disposition can serve as indicators for the performance of the treatment technologies. The test program does not appear to be designed to provide basic data on the kinetics and thermodynamics of the oxidation of key waste stream components under process conditions. Recommendation: The test program could be improved if the following steps are taken: To the extent feasible, the Army should use a representative range14 of actual EDS neutralents obtained from munition destruction in its tests of alternative treatment technologies. A limited number of tracking compounds chosen for their ability to gauge process performance and issues of regulatory concern should be identified and analyzed for in the treatment effluent. To supplement tests on EDS neutralents, the Army should collect information about the kinetics and thermodynamics of the destruction of these tracking compounds by the preferred destruction technology. Physical properties of neutralents such as phase behavior (including suspended solids) and flash point should be determined on neutralent samples obtained from EDS-1 and EDS-2 treatment of actual chemical munitions. Regulatory Issues Finding: EDS neutralent may be treated off-site or on-site. If the EDS liquid waste is treated off-site, the Army must obtain a permit for a new facility or find a permitted hazardous waste treatment facility or a FOTW or POTW that can treat the EDS liquid wastes. If a facility with an existing permit is used for treatment, that existing permit may require modification. Finding: Based on available data and the experience of the members of the committee, the chemical constituents most likely to be of concern in the RAP process for EDS liquid wastes are chlorinated organics, possible degradation products of energetic compounds, metals, suspended solids,15 and monoethanolamine (MEA). These constituents were chosen based on their abundance in the neutralent, their inherent toxicity, their resistance to treatment, or overall regulatory and public concern. Recommendation: The Army’s RAP strategy should ensure that sufficient information is obtained about the chemical constituents of greatest concern in the RAP process for the EDS liquid wastes: chlorinated organics, degradation products of energetic compounds, metals, suspended solids, and MEA. Finding: RAP options associated with treatment of EDS neutralents, rinsates, and cleaning solutions depend on whether the waste is regulated as hazardous within the state where it is generated and, if it is, whether it is a “listed” hazardous waste, a “characteristic” hazardous waste, or both. If EDS liquid wastes are determined to be hazardous under the federal RCRA program (via the RCRA characteristics), RCRA’s land disposal restrictions (LDRs) apply, and the wastes must be treated to meet specific requirements. Note that the remainder of the findings and recommendations in this section are based on the premise that neutralent (but not necessarily rinsate or residue) will be defined as hazardous waste. This may not always be the case, although the Army’s policy to date has been to treat the neutralent as hazardous waste. 12   If any of the technologies in track one can be demonstrated to work and be cost effective, then the committee recommends that research and development on track two technologies be terminated. However, the strict time constraints imposed by the CWC—i.e., that all NSCWM recovered prior to 1997 must be destroyed by 2007—in effect require that the two tracks be pursued at the same time. 13   One example of a tracking compound for destruction of nerve agents might be methylphosphonic acid, which is very stable and difficult to destroy. Further discussion of tracking compounds may be found in Appendix D. 14   As noted in Chapter 2, the compositions of EDS neutralents from destruction of separate NSCWM will not necessarily be consistent, even for munitions of the same type. 15   Suspended solids are a concern only if they are determined to contain residual chemical agent in microscopic cracks and crevices. See discussion in Chapter 2.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System Finding: In the near term, the Army is likely to continue to use permitted hazardous waste incinerators to dispose of EDS liquid wastes (especially neutralents), because of their proven effectiveness. Many commercial hazardous waste facilities use nonincineration technologies to treat wastes similar to EDS liquids and might also be available. Finding: Dilute aqueous rinsates from the EDS and wastes resulting from treatment of neutralent may be classified as listed hazardous wastes either as a result of the “derived from” rule or because the state explicitly lists the rinsate. However, these solutions are primarily water with much lower concentrations of hazardous constituents than the initial neutralent. As a result, they pose relatively little risk and could probably be safely managed as nonhazardous wastes, thereby lowering disposal costs without causing any meaningful change in the degree of protection. Finding: The EDS treatment process also generates spent cleaning solutions that are distinct from the rinses. The cleaning solutions are a mixture of aqueous detergent solutions and a dilute acetic acid wash. The detergent apparently has a tendency to leach chloroform out of the solvent-based sealant used on the EDS seals. While the acetic acid may also leach metals from the walls of the EDS, the levels of these metals appear not to be high enough to warrant considering the resulting waste as hazardous. The chloroform may be of concern, however. Except for the higher amounts of chloroform, these solutions are also primarily water, generally with much lower concentrations of hazardous chemicals than the initial neutralent. As a result, if chloroform is not generated in the EDS cleaning process, even the aqueous cleaning solutions could probably be safely managed as nonhazardous waste. Finding: The Army has suggested that the chloroform found in the rinsate is leaching from a sealant utilized in the EDS. There may be other equivalent sealants that do not contain chloroform and that could be substituted for these sealants. Recommendation: The Army should expeditiously substitute a sealant that does not contain chloroform in the existing EDS systems and all future EDS units. Recommendation: In states where rinsates, cleaning solutions, or wastes resulting from treatment of neutralent are listed as hazardous wastes or are considered hazardous waste because they are derived from treatment of a listed hazardous waste, the Army should work with the state regulators toward the designation of these wastes as nonlisted hazardous waste. For spent cleaning solutions, this recommendation assumes that the source of chloroform in the rinses can be eliminated. The Army should collect all data on the EDS rinsates and cleaning solutions for presentation to the state regulators in support of a hazardous waste listing determination. If it is found that these wastes do not meet the hazardous waste listing criteria, they should be designated nonlisted hazardous waste by modifying the state regulations or the permit or equivalent documentation. While the state regulators could require the Army to submit RCRA delisting petitions, the committee believes that a modification in the state regulations or in the permit or equivalent documentation would be the more cost-effective option. Recommendation: The Product Manager for Non-Stockpile Chemical Materiel (PMNSCM) should work with regulators and the concerned public to resolve RAP issues surrounding the EDS waste streams well in advance of EDS deployment to a particular site. Finding: Regulatory issues related to the posttreatment of liquid wastes (neutralents, rinsates, and cleaning solutions) produced by the EDS are distinct and different from the regulatory issues related to use of the EDS itself. There are a number of RAP mechanisms that could be used for management of EDS liquid wastes. With the proper approvals or permits, treatment of EDS liquid wastes may be conducted on-site or at off-site facilities. In some cases, treatment may be conducted under a facility’s existing treatment, storage, and disposal facility (TSDF) permit, if that permit is written sufficiently broadly to allow acceptance of EDS liquid wastes. Other options include obtaining a hazardous waste permit for treatment, modifying an existing hazardous waste treatment permit, using emergency exemptions available under most state hazardous waste regulations, obtaining an emergency permit under the state hazardous waste regulations, using a RCRA compliance order (RCRA §§ 3008(a), 3008(h) or 7003), or using the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) removal authority. In some cases, the wastes could be managed under a waste management plan established under a CERCLA record of decision. RCRA research, development, and demonstration (RD&D) permits and treatability studies may also be appropriate in certain cases. Recommendation: The Army should develop RAP guidance for field personnel (e.g., base commanders) on the disposition of EDS neutralent and rinsate waste streams, taking into consideration the nature of the NSCWM and the specific regulatory environment at locations where the EDS might be sited. This guidance should cover all aspects of RAP for the EDS and treatment (as necessary) of neutralents and rinsates, including setup, operation, and closure. Development of this guidance should be coordinated with the states, and a jointly issued guidance document should be considered.

OCR for page 1
Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System Public Acceptability Issues Finding: The committee’s earlier conclusions (NRC, 2001a) concerning public acceptability for RRS and MMD neutralent treatment processes also apply to treatment of EDS neutralents and rinsates. The committee’s discussion with citizen groups indicated a need for—and the value of— public involvement in the Army’s decisions on the selection and deployment of technologies for disposing of neutralents and, indeed, all nonstockpile chemical materiel. Recommendation: The Army should continue to expand its program for public involvement in the disposal of nonstockpile chemical materiel. Enough time should be scheduled and enough resources allocated to ensure that the decision-making process is open and that members of the public are involved in making the trade-offs among the selection, siting, deployment, and employment of disposal technologies.