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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.