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OCR for page 38
5
Findings and Recommendations
The findings and recommendations below are num-
bered according to the chapter of the report from which
they derive and are grouped according to the element
to which they pertain in the statement of task (SOT) for
this report.
SOT Element 1. Review data on the stability of stored M55 rockets,
including past findings and predictions regarding the storage and
disposal risks posed by these munitions.
Finding 2-1. The committee qualitatively evaluated
past findings and predictions developed by the Army
of the risk of autoignition of leaking and nonleaking
GB M55 rockets, and it concurs with the conclusion
from these studies that the absolute risk from M55 rock-
ets during continuing storage is reasonably low. How-
ever, in a relative sense, these rockets have the highest
storage risk of any group of chemical munitions and
should be disposed of as soon as and as rapidly as pos-
sible. A more detailed review of stockpile degradation
will be forthcoming in a National Research Council
report currently in preparation.
Recommendation 2-1. The Army should continue to
give safe and expeditious disposal of GB M55 rockets
a high priority in munition destruction campaigns.
Finding 2-2. Some of the GB M55 rockets processed at
the Tooele Chemical Agent Disposal Facility (TOCDF)
contained gelled agent. These rockets came from three
particular agent lots that contained restabilized agent.
No gelled rockets were found among the munitions pro-
38
cessed at the Johnston Atoll Chemical Agent Disposal
System (JACADS). The gelled rockets at TOCDF were
processed at the conservatively permitted rate of 1.6 per
hour (compared with as many as 33 per hour for ungelled
rockets). Processing at this low rate would extend the
disposal schedule by about a year at the ANCDF.
Recommendation 2-2. The Army should continue to
examine and establish options for accelerated process-
ing of gelled GB M55 rockets that satisfy safety and
regulatory requirements.
SOT Element 2. Review operational experience from the disposal
of GB and VX rockets at JACADS and GB rockets at the TOCDF.
Obtain data and information sufficient to compare the Army's origi-
nal proposal for disposal of M55 rockets at Anniston, Alabama, with
its more recent modified proposal for accelerated disposal.
Finding 3-1. A large number of problems were solved
and process improvements were made as a result of the
pioneering operations on GB and VX rockets at
JACADS and TOCDF.
Recommendation 3-1. The full range of lessons
learned from the JACADS and TOCDF experience
should be carefully communicated and incorporated
into the design and operations of the new baseline in-
cineration system facilities at the Anniston, Umatilla,
and Pine Bluff sites.
Finding 3-2. Processing rates for ungelled GB M55
rockets at JACADS and TOCDF were substantially
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FINDINGS AND RECOMMENDATIONS
lower than intended in the baseline incineration system
design. Jams in the deactivation furnace system (DFS)
feed chute and in the heated discharge conveyor, along
with failed DFS kiln flange bolts, were the primary
causes of poorer performance. Some hardware modifi-
cations have been made to address these problems.
Recommendation 3-2. The Army should demonstrate
the operability of modified components of the baseline
incineration system during initial operational testing at
ANCDF and promptly address other problems that
arise during disposal processing operations with a view
to achieving design production rates while conforming
in all respects to permit limitations and safety criteria.
Finding 3-3. The rate for processing gelled GB rockets
at TOCDF was limited by a regulatory permit to 1.6
rockets per hour and was further reduced to 1.0 rocket
per hour when coprocessing was undertaken. Had the
permit limitation not been in force, it is quite likely that
a higher rate could have been safely undertaken, but
this was not tried.
Recommendation 3-3. The Army, in coordination
with state and local government authorities, regulatory
agencies, and the larger Anniston area public, should
act promptly to demonstrate during the agent trial burns
the safety of processing gelled GB M55 rockets at
higher rates than were permitted at TOCDF.
Finding 3-4. Flue gas emission tests made during trial
burn operations at JACADS and TOCDF for ungelled
GB M55 rockets showed higher levels of lead than
permitted. Emission levels of other metals and sub-
stances of potential concern (SOPCs) met all appli-
cable standards. Dioxins, furans, and polychlorinated
biphenyl emission levels were particularly low. The
new pollution abatement system carbon filter system
was not in place for any of these tests, but it has been
incorporated for use in the new baseline facilities at
Anniston, Umatilla, and Pine Bluff and should pro-
tect further against releases of agents, metals, and
SOPCs. This conclusion is reinforced by the surro-
gate trial burn experience at ANCDF. From a techni-
cal point of view, engineering controls should reduce
these emissions below levels of concern; however, in
view of societal concerns, the committee continues to
believe that more frequent monitoring of stack gases
for key metals and SOPCs could help to allay public
concerns about emissions.
39
Recommendation 3-4. More frequent monitoring of
stack gases for key metals and SOPCs will ensure that
the PASIPFS is operating as expected and may help to
allay public concerns about emissions; therefore the
Army is urged to analyze the stack gases for key metals
and SOPCs more frequently than is now the practice.
Finding 3-5. Gelled GB M55 rockets were safely pro-
cessed with other GB munitions at TOCDF. This in-
creased the overall rate of destruction of the stockpile
at the Tooele site.
Recommendation 3-5. Although the remaining baseline
facilities are not expected to have many gelled GB M55
rockets, it is anticipated that coprocessing or comple-
mentary processing of GB munitions and containers can
be safely accomplished at Anniston. If this turns out to
be so, the Anniston experience should be extended to
other sites.
SOT Element 3. Assess the potential of the modified proposal to
enable the Army to safely accelerate the schedule for disposal of
M55 rockets at Anniston.
Finding 4-1. The Anniston stockpile is believed to con-
tain 8,706 gelled GB M55 rockets, the processing of
which at the conservatively set TOCDF Resource Con-
servation and Recovery Act (RCRA) permit rate will
extend the disposal schedule and increase the risk to
the public from longer storage, which is a greater risk
than the risk from disposal. An increase in the autho-
rized processing rate at ANCDF for these munitions is
an important feature of the modified disposal plan that
has yet to receive regulatory approval.
Recommendation 4-1. The Army should make every
effort to obtain regulatory approval of a processing rate
for gelled GB M55 rockets that is constrained only by
valid requirements for ensuring safety and by equip-
ment capacity limitations. This rate should be estab-
lished by the results of agent trial burns.
Finding 4-2. For various reasons, the Army's relation-
ship with the public and with county and state officials
in the larger Anniston area has been severely strained.
This could result in serious delays in the overall dis-
posal schedule, which in turn would extend the storage
period and increase the attendant risk.
Recommendation 4-2. The Army should proactively
communicate and discuss its basis for establishing a
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40
sate processing rate with concerned stakeholders as
well as with regulatory authorities.
Finding 4-3a. It appears that a combination of pro-
cessing segments of gelled GB rockets and comple-
mentary processing of other GB munitions with GB
rockets could speed up the overall rate of stockpile de-
struction at ANCDF. This is an important element of
the modified disposal plan being put forth by the Army.
Finding 4-3b. The modified disposal plan envisions
destruction of the entire GB munitions stockpile prior
to VX rocket processing. This change would reduce
worker risk since it eliminates one agent changeover
and the dangers associated therewith. It would extend
the storage period for VX rockets, thus slightly increas-
ing the risk to the public, but would allow processing
of the entire stockpile to be completed sooner, partially
offsetting storage risk. It would reduce homeland secu-
rity concerns by earlier elimination of all of the chemi-
cal agents in storage at ANCDF.
Recommendation 4-3. The Army, with proactive at-
tention to public input, should seek approval of the
modified disposal plan for ANCDF and, upon gaining
regulatory approval, implement it without delay to
minimize the risks associated with continued storage.
Finding 4-4. The approach of Continental Research
and Engineering in modeling the performance of the
DFS operating on gelled GB M55 rocket segments
necessarily simplified the process mechanisms in-
volved. The committee believes that processing 34
rockets per hour is very optimistic. Processing 1
gelled rocket per hour at TOCDF showed pressure
spikes (within design limits) that were probably asso-
ciated with rapid combustion of the rockets in the first
part of the kiln. An additional concern is that the DFS
may not have time to cool sufficiently between rocket
injections at higher throughput rates. Another concern
is that gelled agent may begin to burn in the feed chute
and overheat it. Still another is that transient pressure
puffs may occur. Also, there was no prior field dem-
onstration at TOCDF that gelled GB M55 rockets can
be processed faster than the TOCDF RCRA-permit-
ted rate of 1.6 per hour. While there is the possibility
that dumping individual sheared rocket parts, as few
as one at a time, into the DFS might result in more
uniform, effective, and controlled combustion within
the kiln and fewer automatic waste feed cutoffs, the
ASSESSMENT OF PROCESSING GELLED GB M55 ROCKETS AT ANNISTON
effects of additional cycling on the chute gates must
also be taken into account.
Recommendation 4-4. The committee recommends
that the Army proceed with design and schedule work
for processing gelled GB M55 rockets at the rate of 9.2
per hour, which is equivalent to having one rocket in
the DFS kiln at any one time, with the proviso that
modeling work continue and appropriate trial burns be
conducted. The Army might consider dumping sheared
rocket parts into the DFS one at a time to determine if
this will improve kiln operations and have a positive
impact on automatic waste feed cutoffs. When the first
trial burn with gelled agent munitions occurs, the op-
erators should carefully and slowly increase the feed
rate from the 1.6 rockets per hour permitted at TOCDF
up to the design rate of 9.2 rockets per hour or higher,
if permitted by regulatory authorities and other Ala-
bama officials. In addition to continuous monitoring of
the agent destruction and removal efficiency, the emis-
sions from the stack, and the Process Data and Record-
ing System data, a continuous record should be taken
of differential pressures, along with DFS kiln and feed
chute gas and metal temperatures. Regulatory approval
should be sought for the maximum feed rate that can be
shown by agent trial burn data to be safe for the public,
workers, and the environment.
SOT Element 4. Assess the risk and hazard analyses associated
with the original and modified proposals for M55 rocket disposal at
Anniston for implications concerning potential effects on workers
and the general public.
Finding 4-5. The risk of fatalities to workers and the
public posed by agent exposure is somewhat lower for
the modified disposal plan than if gelled GB M55 rock-
ets at Anniston were to be processed at the TOCDF
rate of 1.6 rockets per hour, because the stockpile
would be destroyed a year sooner, thus reducing stor-
age risk. In either plan, however, the calculated risk is
very low. Further, if the total duration of stockpile de-
struction can be reduced, there will be fewer hours of
exposure to storage risk and the community will be
safer. Similarly, worker safety is also improved by
fewer hours of operation.
Recommendation 4-5. The Army should improve on
its attempts to promote public understanding of the
nature and magnitude of risks associated with the ex-
istence of the stockpile and the role of the stockpile
destruction program in reducing and ultimately elimi-
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FINDINGS AND RECOMMENDATIONS
eating the risk. Risk reduction options should be com-
municated clearly to interested stakeholders for input
and feedback.
Finding 4-6. The health risk assessment for ANCDF,
which defines the health risks associated with various
emissions, is not yet available, but based on trial burn
data for destroying rockets at JACADS and TOCDF, it
is likely that the emissions will meet all standards. This
is further supported by results of the surrogate trial
burns at ANCDF.
Recommendation 4-6. The health risk assessment for
ANCDF should be completed as rapidly as possible
41
and the results communicated to workers, the public,
and elected officials.
Finding 4-7. Because of the much smaller numbers of
gelled rockets estimated to be stored at Umatilla and
Pine Bluff, the modified disposal plan process devel-
oped for Anniston may not be needed at those sites.
Delays associated with permit modification to allow a
higher processing rate may exceed the delay associated
with processing at the slower TOCDF RCRA-permit-
ted rate.
Recommendation 4-7. The Army should proceed at
Umatilla and Pine Bluff based on the existing RCRA
permit applications.
Representative terms from entire chapter:
disposal plan
