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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel 3 Evaluation Factors for International Destruction Technologies The cultural, regulatory, and geopolitical environment in the United States often differs dramatically from that in other countries. Technologies that are acceptable in other countries may be unacceptable in the United States or may require upgrades or modifications as a condition of acceptance. Nowhere is this more evident than with technologies designed to destroy chemical weapons. The complicated system of environmental, surety, and safety regulations prevailing in the United States also affects the acceptability of technologies that might be applied to the destruction of chemical weapons, as do the provisions of the Chemical Weapons Convention (CWC).1 Although promising, a developing technology may not be a strong candidate in the United States if it cannot be tested, permitted, constructed, and operated in accordance with safety and environmental regulations and with the CWC. The bottom line is that acceptance of international technologies in the United States will depend on these technologies being mature, proven, efficient, reliable, robust, inherently safe, environmentally acceptable, and compatible with the provisions of the CWC, or holding great promise for being all of these things. SELECTION OF EVALUATION FACTORS In determining the evaluation factors to use for this study, the committee first examined factors used in similar evaluations in the past. The committee examined earlier NRC reports, including those pertaining to the U.S. Army’s Alternative Technology Program and the Assembled Chemical Weapons Assessment Program.2 Technology selection factors used in these reports address the special consider- ations associated with chemical weapons destruction and reflect concerns and issues raised by regulators and the public. After examining the system of comparative evaluation factors applied in these programs, the committee chose the factors used in one of these reports as a starting point for the present evaluation (NRC, 1995). The factors in that earlier report were modified for the present application to better reflect consideration of international technologies, non-stockpile issues, and present-day stakeholder concerns. Five primary factors were chosen for evaluation of the international technologies: Process maturity, Process efficacy/throughput, Process safety, Public and regulatory acceptability in a U.S. context, and Secondary waste issues. A sixth factor, process costs, was considered, but in a more qualitative sense. Cost information was not generally available for many of the international technologies examined, and in any case, a complete and quantitative evaluation of cost was beyond the scope of the committee’s task. Each of the primary evaluation factors listed above has a number of subfactors, many of them at least somewhat interdependent. Each subfactor is expressed in the form of a question listed in a table for the evaluation factor to which it pertains, and its relationship to that evaluation factor is explained. For the Tier 1 technologies, the subfactor questions are then answered in five tables, one for each of the five evaluation factors.3 The latter tables, which are contained in Appendixes B and C, provide some specific summary information and expert opinion in response to the questions. The information presented in this report, including that in Appendixes B and C, is based on the information that was 1 See Chapter 2. Additional information on regulatory approval and permitting issues can be found in Chapter 4 of NRC (2002). 2 The Assembled Chemical Weapons Assessment Program is now referred to as the Assembled Chemical Weapons Alternatives Program, although the acronym, ACWA, remains the same. 3 Chapter 1 describes how the technologies were assigned to tiers.
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-1 Process Maturity Subfactors Subfactor Relationship to Maturity Is the technology in use for any type of material, even one not related to CWM in the U.S.? If the technology is currently in use in the U.S. as described, the process is mature. Is the technology in use for any type of material, even non-CWM related internationally? If the technology is currently in use internationally as described, the process is mature. Has the technology been permitted or otherwise approved in the U.S. for CWM or energetics? If the process has been permitted or otherwise approved for treatment of CWM or energetic materials in the U.S., the technology is mature. Has the technology been permitted or otherwise approved in the U.S. for industrial wastes? If the process has been permitted or otherwise approved for treatment of industrial wastes in the U.S., it demonstrates that the technology is mature. How much, if any, additional R&D is required in order to implement the technology? If a moderate or an extensive amount of research and development is required to implement the technology, it may not be sufficiently mature. What, if any, are the scale-up requirements needed to implement the technology? Many technologies may be proven on a bench-scale or pilot plant basis, but significant scale-up issues may remain. Can the technology be implemented within 3 to 5 years? A technology should be capable of being permitted, constructed, and operated within a reasonable period of time. available to the committee; some of the information was obtained from vendors and requires validation. The tables in Appendixes B and C allow a convenient side-by-side comparison of the various Tier 1 technologies with the respective Non-Stockpile Chemical Materiel Project (NSCMP) EDS or RRS/SCANS technologies currently in use. A more detailed discussion of the evaluation factors and associated subfactors is presented in the sections that follow here in Chapter 3. DESCRIPTION OF EVALUATION FACTORS Process Maturity In general, chemical process technologies are located along a developmental continuum from laboratory-scale, proof-of-concept testing, pilot plant demonstration, and, ultimately, full-scale operation. Some technologies are in full-scale operation overseas at this time for the destruction of either CWM or industrial wastes. These or similar technologies may be in use in the United States, at least for industrial wastes. Still other technologies may not yet have reached this operational stage in the United States or elsewhere. Process maturity relates to whether the technology is being implemented in the United States or in other countries on a full-scale operational basis to deal with CWM or industrial wastes, and if it is not, to the nature and extent of the additional R&D that would be required to bring the technology to full-scale operation, specifically for non-stockpile materials. This maturity factor also considers whether technology implementation is feasible within a reasonable period of time. Process maturity subfactors are identified and their relationship to maturity is explained in Table 3-1. Process Efficacy/Throughput Process efficacy/throughput deals with the ability of the technology to destroy chemical agent and other process residuals (e.g., energetics) in a manner consistent with environmental regulations and CWC requirements. Destruction is typically evaluated by application of a concept initially established under the Resource Conservation and Recovery Act (RCRA) incineration regulations, known as destruction and removal efficiency (DRE) (40 CFR 264.343).4 In general terms, DRE is the difference between the amount of chemical going into a process and the amount vented to the atmosphere after offgas treatment. The RCRA regulations for incineration require a DRE of 99.99 percent (otherwise known as four nines) for most organic constituents, but for some constituent categories, such as dioxins and furans, RCRA requires a DRE of 99.9999 percent (six nines). Incineration is capable of destroying chemical agents to a level of at least 99.9999 percent. Although incineration of chemical agents has lost favor with public interest groups in the United States, the incineration DRE of 99.9999 percent, as a practical matter, has become an informal basis of comparison for chemical agent destruction processes. Process efficacy/throughput also involves process stability, reliability, and robustness. Considering the wide variety of non-stockpile materials that may be encountered in the future, and the conditions to which they may have been 4 DRE for an incinerator is defined by the EPA as DRE = [(WinWout)/Win] × 100%, where Win = mass feed rate of a selected organic compound in the waste stream feeding the incinerator and Wout = mass emission rate of the same organic compound in the exhaust emissions prior to release to the atmosphere (40 CFR 264.343, July 1, 2004, edition).
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-2 Process Efficacy/Throughput Subfactors Subfactor Relationship to Process Efficacy/Throughput What is the DRE? Technologies should be able to achieve a DRE for CWM of at least 99.9999 percent. Does agent destruction meet the terms of the CWC (irreversible and verifiable)? In accordance with the CWC, the physical, chemical, or biological reaction that destroys the CWM must be irreversible and verifiable. What is the DRE for energetics? Technologies should be able to meet a DRE for energetics of at least 99.99 percent. Is the process reliable and robust? The process should be able to operate with minimal downtime and should be reasonably insensitive to variations in process conditions. It should be able to complete operations in the event of a process upset (e.g., loss of power, mechanical problems). Is the process highly complex or relatively simple? It is often advantageous that a process be simple and easily explained to regulators and the lay public. What are the personnel/staffing requirements for the technology? The process should be able to be operated by personnel having a moderate level of education. What is the process throughput? Especially for large finds, the process should be able to treat a large number of munitions in a given amount of time. Is the process scalable so that it can address small, medium, and large munition finds? It is an advantage if models of various sizes and capacities can be applied to address finds of various sizes. Is the process capable of handling multiple munition types? It is an advantage if the process is capable of handling different types, sizes, and configurations of munitions in various states of disrepair and chemical decomposition. Is the process capable of handling multiple agent types? It is an advantage if the process is capable of handling different types of agents in various physical states. Is the process transportable? It is an advantage if the process equipment can be moved from site to site. exposed for many years, this factor also addresses whether the technology is capable of handling a wide variety of munition types in various states of disrepair and chemical decomposition. Also, since it is often desirable in the United States to bring the process equipment to the muni-tion (as opposed to transporting the munition to the process equipment), this factor pertains to process mobility. Finally, considering the potential need to remediate sites that may contain large quantities of buried non-stockpile munitions in the future, process throughput is also important. Process efficacy/throughput subfactors are identified and their relationship to process efficacy and throughput are explained in Table 3-2. Process Safety Process safety addresses specifically the ability of the technology, considering applied engineering controls and monitoring protocols, to ensure worker safety and also the safety of the surrounding community. Typically, evaluations of worker and community safety consider the risk of releases of chemical agent or process chemicals and the consequences of such releases. To more thoroughly evaluate such risks, maximum credible events are often postulated and the risks of such an event are assessed through quantitative risk assessments. Some of the technologies entail operations performed either in tandem or in parallel. Such operations include the preparation of munitions for treatment; the storage and/or treatment of some secondary wastes, such as offgas; and equipment cleaning or maintenance operations. Quantitative risk assessments are sometimes used to ascertain and assign probabilities and consequences for accidents and other safety considerations for each phase of a total process—for example, munition accessing, treatment, and handling of secondary wastes. The committee had neither the time nor the resources to conduct such assessments but instead attempted to identify intrinsic safety issues associated with each technology and to qualitatively evaluate worker and community risk. Subfactors are identified in Table 3-3.
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-3 Process Safety Subfactors Subfactor Relationship to Safety What are the worker safety and health risks? The process should be able to be operated with minimal risk to workers. What are the community safety and health risks? The process should be able to be operated with minimal risk to the community. What are the process monitoring requirements? Process monitoring should be no more complex than that for processes used in present U.S. non-stockpile applications. To what extent have engineering controls been developed to ensure process safety? Engineering controls should be sufficient to protect workers and the community from releases of chemical agent. Public and Regulatory Acceptability in a U.S. Context Earlier NRC reports on the non-stockpile program5 identified regulatory approval and public involvement as key considerations for technology acceptance. Perhaps the most important consideration is that environmental regulators and the public should be involved in deciding whether to apply such technologies in the United States. Acceptability in a U.S. context also addresses specific concerns pertaining to chemical munitions destruction that have been raised by the U.S. public over the years, in both the stockpile and the non-stockpile programs.6 This factor also specifically evaluates environmental regulations established by the U.S. Environmental Protection Agency and the states for the destruction of chemical weapons and materials. It is critical that the technology be able to meet environmental permitting requirements and obtain environmental regulatory approval. There are a number of different regulatory approval and permitting (RAP) mechanisms that may be applicable to approving use of technologies to treat non-stockpile CWM. For example, technologies may be approved through different processes under the Comprehensive Environmental Response, Compensation, and Liability Act. Permits and other forms of regulatory approval may be issued under RCRA as well. The NRC has reviewed extensively RAP mechanisms that may be employed to approve technologies for treatment of non-stockpile chemical warfare materiel (NRC, 2002). Regardless of which RAP mechanism is employed, the substantive permitting requirements of the RCRA program would need to be addressed in order for a technology to receive environmental regulatory approval. For example, if a technology were to be approved through the CERCLA remedial program, the substantive permitting requirements of the RCRA program would need to be addressed as an Applicable or Relevant and Appropriate Requirement, unless a waiver is obtained. The miscellaneous unit permitting requirements under RCRA7 would likely apply since the international technologies under examination in this report would be unlikely to match any of the existing types of waste management units addressed under the RCRA regulations (40 CFR 264). The permitting requirements of the Clean Air Act, as well as the principles of pollution prevention and waste minimization, would apply as well. Acceptability subfactors are identified and described in Table 3-4. Secondary Waste Issues The term “secondary waste” encompasses a broad category of materials that are produced as a result of primary treatment. Technologies typically generate liquid wastes, various solids, and gaseous materials. Some of these materials can contain residual levels of chemical agent and other chemicals of concern, and additional treatment may be required. Such treatment may be conducted on-site (at the site of primary waste treatment), but commercial off-site treatment may also be considered. Storage and transportation requirements must also be considered. The generation of large volumes of secondary wastes contributes to adverse public reaction, and the analysis and certification that the wastes meet regulatory standards for disposal contributes to 5 Review of the Army Non-Stockpile Chemical Materiel Disposal Program: Disposal of Chemical Agent Identification Sets (1999); Review and Evaluation of the Army Non-Stockpile Chemical Materiel Disposal Program: Disposal of Neutralent Wastes (2001); Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System (2001); Systems and Technologies for the Treatment of Non-Stockpile Chemical Warfare Material (2002); Assessment of the Army Plan for the Pine Bluff Non-Stockpile Facility (2004); Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities (2005). All were published in Washington, D.C., by the National Academies Press. 6 Public stakeholders are concerned, naturally, about things like process maturity, efficacy, and safety; however, the concerns raised under this evaluation factor have been raised specifically by public stakeholders in the United States in the past with regard to stockpile and non-stockpile operations. 7 Since it is likely that technologies evaluated in this report will not be directly comparable to established technologies previously permitted under the RCRA program, technologies will need to meet the broad and stringent requirements pertaining to Miscellaneous Units established under 40 CFR Part 264, Subpart X.
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-4 Public and Regulatory Acceptability in a U.S. Context Subfactors Subfactor Relationship to Public and Regulatory Acceptability in a U.S. Context Is the process inherently incineration-like? Some public stakeholders in the U.S. are opposed to use of incineration for the treatment of chemical warfare materiel. Does the process break key chemical bonds (e.g., C-P bond for nerve agents)? Regulators and other stakeholders in the U.S. have reacted favorably to technologies that result in complete destruction of key chemical bonds. Could the process produce dioxins or other notable by-products? Regulators and other stakeholders in the U.S. have reacted unfavorably to technologies that could create undesirable by-products. Does the process allow holding and testing of process residuals prior to release? Regulators and other stakeholders in the U.S. have reacted favorably to technologies that allow waste materials and by-products to be held and tested prior to their release. Does the process result in excessive noise, odors, or other nuisances? Regulators and other stakeholders in the U.S. have reacted unfavorably to technologies that are associated with excessive noise, odors, or other nuisances. Would the process be able to satisfy environmental regulatory requirements under RCRA? Permitting requirements under RCRA are stringent and have caused delays in technology implementation, particularly if there is public opposition (see NRC, 2002). Would the process be able to satisfy environmental regulatory requirements under the Clean Air Act (CAA)? Permitting requirements under the CAA are stringent and have caused excessive delays in technology implementation, particularly if there is public opposition (see NRC, 2002). Would the process be able to satisfy other applicable environmental regulatory requirements? Some technologies may require compliance with other environmental laws such as the Clean Water Act. Does the process satisfy the principals of pollution prevention and waste minimization? Technologies, to the extent possible, should employ process chemicals that are nontoxic, and the technology should result in minimal amounts of secondary wastes. processing costs. In addition, residuals from secondary waste treatment may require further treatment prior to disposal. Secondary waste issues have taken on great importance, especially over the last few years. A prime example of this is the concern that has been in evidence over the Army’s plans to send hydrolysate resulting from treatment of bulk VX from the Newport Chemical Depot to a facility located in New Jersey along the Delaware River (Ember, 2005). Subfactors for secondary waste issues are identified and described in Table 3-5. Process Costs Technology costs can be evaluated on a number of different levels and from a number of different perspectives. For example, costs can be evaluated on a per-munition basis, on a per-site basis, or as a function of the amount of chemical agent. The basis for the cost evaluation is often an important element in the evaluation of cost. For example, as the size and complexity of the chemical munitions removal and cleanup increases, permanent or semipermanent treatment facilities, which are more expensive and complicated than mobile treatment units, become more reasonable. Although cost is a consideration in technology selection, it is important to note that a relatively high cost does not necessarily mean that a technology is unacceptable, especially if no technically and socially acceptable alternative is available. Realistic cost information can be difficult to obtain, particularly for technologies that have not yet achieved production scale and for which operating experience is limited. As previously indicated, cost information was not generally available to the committee for the international technologies evaluated in this report, so it was not possible for the committee to conduct life-cycle cost analyses for these technologies. Consequently, the committee chose to evaluate costs only in a qualitative sense, with a focus on identifying those cost components of a system or technology that might be associated with a relatively high cost. An example would be the potentially high energy costs of some technologies. A summary paragraph discussing these types of considerations is presented toward the end of the Tier 1 technology evaluations. The committee assumes that if the U.S. Army chose to further consider an international technology for implementation in the U.S. non-stockpile program, it would require detailed cost estimates before proceeding with further technology research or implementation. RATING SYSTEM The committee determined that it would be useful to develop a rating system to enable efficient comparative evaluation of the technologies with respect to each of the evaluation factors and, ultimately, of the technologies themselves and the current NSCMP equipment in use. Because
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-5 Secondary Waste Issues Subfactors Subfactor Relationship to Secondary Waste Issues What is the character of secondary wastes? Secondary waste issues are most significant for wastes generated in large volume or that may contain residual amounts of agent, agent degradation products that retain some toxicity, and other contaminants of concern. Form (e.g., liquid, solid, gas) Volume Toxicity (e.g., agent, degradation products, metals, other contaminants) Do secondary wastes initially meet: Secondary wastes that are generated, and in particular solids, must meet the Army’s requirements for decontamination. Wastes that meet GPLs might be treated as non-hazardous wastes or recycled without further controls. Secondary wastes that meet STELs but not GPLs require additional management.a Secondary wastes may need additional scrutiny under the CWC if they contain Schedule 2 chemicals.b Additional treatment may be required if secondary wastes do not meet environmental regulatory requirements as generated.c General population limits (GPLs) or short-term exposure limits (STELs)? CWC requirements? Environmental regulatory requirements? For each secondary waste, will subsequent treatment be required: If additional treatment is required to meet the various listed requirements, such treatment presents additional risk and costs. The wastes may need to be transported to the site of treatment, and additional storage may be required. To meet GPLs or STELs? To satisfy CWC requirements? To satisfy environmental regulatory requirements? For each secondary waste, if subsequent treatment is needed, are treatment methods established and available? If secondary wastes require additional treatment, acceptable means of treating these wastes must be available. Will residuals from treatment of secondary waste require subsequent treatment: In some cases, even residuals from secondary waste treatment may require additional treatment to meet the various standards listed. To meet GPLs or STELs? To satisfy CWC requirements? To satisfy environmental regulatory requirements? What is the disposition of final treatment residuals: Some secondary wastes, even after treatment, may be considered hazardous and may need to be disposed of accordingly. Some types of secondary wastes may be released as is for reuse or recycling. Recycle? Hazardous waste landfill? Nonhazardous waste landfill? Other? aGeneral population limits (GPLs) and short-term exposure limits (STELs) are collectively termed airborne exposure limits (AELs) and are used by the Army as a means of protecting workers, the general public, and emergency responders from the toxic effects of airborne exposure to chemical agents. Application of AELs was reviewed extensively in NRC (2005). bThe CWC established a schedule of chemicals that are controlled under the CWC. Several of the agent degradation products are designated under CWC Schedule 2, and their manufacture and distribution in commerce is controlled. If secondary wastes contain Schedule 2 chemicals, additional scrutiny from CWC inspectors may be required during secondary waste treatment or disposal. cSome secondary wastes may contain hazardous waste constituents (e.g., heavy metals) regulated under the RCRA program, and if such contaminants are present above certain concentrations, may require additional treatment prior to ultimate disposal. the technologies differed in terms of data and information available to the committee, and considering that some of the technologies were in different stages of development and/or implementation, the committee developed the following qualitative rating system: + Fully acceptable. Indicates that no or only minor issues remain with respect to any one evaluation factor or the technology as a whole. 0 Partially acceptable. Indicates that some issues remain with respect to any one evaluation factor or with a technology as a whole but that, in general, these issues should be resolvable. – Unacceptable. Indicates that some issues remain with respect to any one evaluation factor or the technology as a whole, and that these issues are unlikely to be resolved favorably. ? Inadequate information. Indicates that not enough information was available to fully evaluate the technology with respect to any one evaluation factor or the technology as a whole. This rating may also indicate that information was available but was classified, proprietary, or otherwise restricted from public dissemination.
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Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel TABLE 3-6 Statement of Task Directives and Corresponding Technology Evaluation Factors SOT Directive Evaluation Factor Potential to be more effective for the overall disposal of specific types of non-stockpile materiel Process efficacy/throughput Assessment of technical feasibility Process maturity and process efficacy/throughput Assessment of level of maturity Process maturity Assessment of degree of scientific acceptance Process maturity and process efficacy/throughput Implementation and deployment issues related to cost Process costs (qualitative analysis only) Implementation and deployment issues related to safety Process safety Implementation and deployment issues related to risk Process safety Implementation and deployment issues related to protection of the environment Public and regulator acceptability in a U.S. context and secondary waste issues Acceptability to regulators and stakeholders Public and regulator acceptability in a U.S. context and secondary waste issues The committee recognizes that this rating system, and any similar system, is necessarily subjective. In addition, because several of the technology providers did not have or could not give out certain information to the committee (owing to proprietary considerations, for example), the ratings may not fully represent the acceptability of the technology with respect to any one factor, or as a whole. Before decisions are made about any technology, such as whether or not to further consider use its in the United States, the committee would urge a more in-depth evaluation, especially taking into consideration information that was restricted from public dissemination. ASSESSMENT OF EVALUATION FACTORS AGAINST DIRECTIVES REFLECTED IN THE STATEMENT OF TASK The committee believes that the overall system of factors and subfactors used in this report encompasses the directives reflected in the statement of task. Table 3-6 identifies directives from the statement of task and shows which of the evaluation factors specifically address those directives. REFERENCES Ember, L.R. 2005. “Army halts VX destruction.” Chemical & Engineering News 83(28): 13. NRC (National Research Council). 1995. Evaluation of the Army’s Draft Assessment Criteria to Aid in the Selection of Alternative Technologies for Chemical Demilitarization. Washington, D.C.: National Academy Press. NRC. 2002. Systems and Technologies for the Treatment of Non-Stockpile Chemical Warfare Materiel. Washington, D.C.: National Academy Press. NRC. 2005. Impact of Revised Airborne Exposure Limits on Non-Stockpile Chemical Materiel Program Activities. Washington, D.C.: The National Academies Press.
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