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Recommendations for the Disposal of Chemical Agents and Munitions Executive Summary The U.S. unitary chemical agent and munitions stockpile that has been maintained for more than 50 years is now obsolete and scheduled for disposal. The Congress directed the Department of the Army to accomplish this task, resulting in the present Chemical Stockpile Disposal Program. Further, congressional direction, reflecting international efforts, now requires disposal by the year 2004. Historically, chemical munitions have been disposed of by land burial, open burning, and ocean dumping. In 1969, the National Research Council (NRC) recommended that ocean dumping be discontinued. The Army undertook a study of disposal technologies in the 1970s, including assessment of incineration and chemical neutralization methods. In 1982, that study culminated in the selection of incineration technology, now incorporated in what is known as the ''baseline'' system. In 1984, another NRC committee reviewed the chemical stockpile program and possible disposal technologies, and endorsed incineration as the method of choice. Construction of the Johnston Atoll Chemical Agent Disposal System (JACADS), a full-scale prototype facility using the baseline system, began in 1985, with Operational Verification Testing (OVT) being conducted in 1990-1993. The present Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) has monitored these developments. During this period, several other nations have employed chemical neutralization and incineration with flue gas scrubbing, or various combinations thereof. To address growing public concern over incineration, Congress, in 1992, directed the Army to evaluate alternative disposal approaches that might be "significantly safer" and more cost effective than the baseline and that could complete disposal operations in time to meet a 2004 treaty requirement. The Army was asked to report to Congress on potential alternative technologies by the end of 1993 (extended to 60 days following delivery of this report) and to include in that report, "any recommendations that the National Academy of Sciences makes...". This Stockpile Committee report provides that advice. The committee drew upon its own expertise and long experience with the
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Recommendations for the Disposal of Chemical Agents and Munitions disposal program and upon the report of the Committee on Alternative Chemical Demilitarization Technologies (Alternatives Committee) in the preparation of these recommendations. This report compares alternatives to the baseline system and makes recommendations for the best approach to stockpile disposal. The Office of Technology Assessment has investigated the subject, and the General Accounting Office is also assessing alternatives. In deriving its recommendations, the Stockpile Committee has been concerned primarily with the technical aspects of safe disposal operations. However, the committee recognizes that other issues will influence the selection of disposal technologies, not least of which are the concerns of citizens who might be affected by these operations. There is concern for the environment as well as for both long- and short-term health risks related to release of agent and other pollutants, either accidental or from routine storage and disposal operations. There is also a desire for more effective participation in program planning and decision processes. To learn more of these concerns, the Stockpile Committee and the Alternatives Committee held a public forum in June 1993 to listen to the public and to discuss the committee's criteria for evaluating alternative technologies. This report is arranged to progress from the general to the specific, from historic information to recommendations for future operations. The findings and recommendations of the report are included in this Executive Summary. THE UNITARY CHEMICAL AGENT AND MUNITIONS STOCKPILE There are two basic types of chemical agents in the unitary stockpile: nerve (GB, VX) and blister (mustard) agents. These are contained in a variety of bulk containers and munitions. Munitions such as M55 rockets and various projectiles have associated explosives and propellants (so-called energetics) that also must be disposed of. The stockpile is stored at eight continental U.S. sites and at Johnston Atoll in the Pacific Ocean, about 700 miles southwest of Hawaii. Each site differs in the amount and types of agents, energetic materials, and associated metal containers stored there. The condition of the stockpile is a factor in the decision to eliminate these materials and in how disposal will be accomplished. Of particular concern are the declining levels of stabilizer in M55 rocket propellants that may eventually lead to autoignition of the propellant. This hazard was addressed in the 1984 NRC study, as well as in a number of studies by the Army and its contractors beginning in 1985. Of two recent studies, one estimates that critical propellant stabilizer levels may be reached in 2019, whereas a second estimates 2002. Examination of these reports indicates considerable uncertainty in all analyses. The Stockpile Committee believes
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Recommendations for the Disposal of Chemical Agents and Munitions that this potentially serious hazard should be reexamined promptly, since it may influence the disposal schedule. Both degradation of the materials and external threats to the stockpile will continue until disposal is completed. Other forms of degradation of both munitions and agent during storage amplify the storage risks and make disposal more difficult and risky. Gelled mustard prevents drainage and impedes agent destruction by any technology. FUNDAMENTALS OF DISPOSAL Disposal of chemical agent and munitions means release of all unitary stockpile materials from Army control in an altered form that satisfies both international treaty requirements and domestic environmental requirements. Waste streams from disposal processes may be gaseous, liquid, or solid, and although the ultimate chemical products are usually similar, the selection of technologies and disposal strategies can alter the condition, timing, and perhaps location of the final products. A fully oxidized or "mineralized" end state is the most stable of discharge conditions, but other end states will meet both treaty and environmental requirements. A number of federal and state environmental regulations govern continental U.S. disposal operations, including the Resource Conservation and Recovery Act; Toxic Substances Control Act; Clean Air Act; Clean Water Act; and the Hazardous Materials Transportation Act. Each of these requirements must be met by any disposal method selected. The performance and safety of candidate disposal methods is greatly increased by separation of the stockpile feed material into distinct streams of agent, energetic materials, metal parts, and dunnage (packing and other miscellaneous material) prior to disposal or destruction. The stockpile disposal program, and any stockpile disposal technology selected, should handle each of these materials separately. HEALTH, SAFETY, AND RISK CONSIDERATIONS The health and safety of the public and the protection of the environment are leading citizens' concerns. In view of the overriding public and committee concern for health and safety, the committee selected as its primary criterion, in formulating its recommendations, the minimization of the cumulative adverse consequences from all relevant risks over the full duration of the disposal program. This total risk criterion extends to protection of the environment and relates to the risk from agent and other pollutants released as a consequence
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Recommendations for the Disposal of Chemical Agents and Munitions of either accidents or routine operations, including both acute and latent health effects. Economic considerations may also be of concern, but they do not appear to be a major factor at this time. Economic data on the use of alternative technologies are virtually nonexistent, but the committee believes that equipment and operating cost variations among alternatives will be very small in comparison to overall program costs. Consequently, cost is not an effective discriminator among alternatives at this early stage. On the other hand, research and development costs for alternatives, and accompanying increases in storage costs and risks from program delays, suggest that minimum risk and minimum cost may both be associated with an expedited program based upon existing technology. Total risk is a measure of the likelihood that people or the environment will experience adverse health effects from operations of both storage and disposal facilities. Because chemical munitions and agent inventories vary from site to site, as do storage conditions and surrounding community conditions, implementation of the minimum cumulative total risk strategy should be determined on a site-specific basis. In addition to this primary total health and safety risk minimization criterion for technology selection, there are technical requirements that all technologies (or combinations of technologies) must meet. Disposal requires an extensive system rather than a single technology to dispose of the stockpile. Agent and munitions must be moved from the stockpile to the disposal facility and unpacked; containers must be opened and drained to gain access to the agent; the four (preferably separated) materials—agent, energetics, metal parts, and dunnage—must be destroyed or treated; and waste products must be treated for acceptable discharge. Most alternative technology discussions have addressed only agent destruction, but there are five important technology selection criteria that must be addressed for any potential alternative technology system: Can the technology contribute to a program of disposal and associated storage that is safer than that of the baseline program? Can the technology treat agent, energetics, metal parts, and dunnage? Can the technology destroy all agents? Do waste products meet environmental disposal requirements? Can the technology achieve treaty requirements for irreversible agent destruction? The primary criterion, safety, involves a number of issues including basic chemistry and the composition and quantity of waste streams, system complexity, and time to completion of the disposal program. Selection among
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Recommendations for the Disposal of Chemical Agents and Munitions the alternatives with regard to these safety issues requires careful risk analyses. A great deal of progress has been made in recent years in designing safety into industrial facilities by considering safety like any other performance factor. One way to do this is by conducting a risk assessment that calculates the frequency of events that lead to consequences of various severity. Two major risks are important in the Chemical Stockpile Disposal Program: acute, high-level agent exposures (which may or may not be fatal) from accidents in storage or processing; and chronic, long-term, low-level exposure to agent or disposal products from routine storage or disposal operations. Most chemical disposal risk assessments to date have focused primarily on high-level exposures, but the public is increasingly concerned about the long-term effects of chronic, low-level exposure to agent or disposal products. Long-term effects are those that might occur during the lifetime of a person exposed to low-level emissions from continuing storage or to any emissions that might result from several years of disposal operations. Attempts to assess the latter effects suffer from a lack of preexposure population data, and the use of self-reported, nonrandom data. A recent U.S. Environmental Protection Agency study has shown that, in general, normal hazardous waste incinerator operations produce stack emissions comparable to "clean" boiler systems and common household emission sources, suggesting that they should have relatively little public health effect. Latent risks could include potential carcinogenic, mutagenic, and teratogenic risks associated with sublethal agent releases and releases of products from stockpile destruction. Off-normal operation is not monitored by the Environmental Protection Agency, but disposal facility operating permits will require cessation of agent feed if furnace conditions are outside normal operating limits. The issue of the health impact of incineration is a significant one, such that a separate National Research Council committee has been established to address the nature and probability of health effects associated with incineration. The Army has performed a quantitative risk assessment for acute or high-level agent exposure from storage and processing accidents using the baseline system. The risks assessed include continued storage versus disposal, on-site versus regional versus national disposal sites, and the reliability of individual unit operations. Although the risks for the entire program were estimated to be very low (less than a mean of 0.02 fatality per year), it was concluded that acute risks from storage were greater than those from disposal using the baseline system (with the exception of Blue Grass Army Depot, in Kentucky, where the two are about equal). At the peak of the disposal effort, the risk of disposal will be approximately 0.0004 fatality per year, by which time the storage risk will have decreased to approximately 0.012 fatality per year as the material in storage is diminished. The committee has already recommended the development of updated, site-specific risk assessments to
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Recommendations for the Disposal of Chemical Agents and Munitions clarify these findings, but it believes that new studies will likely draw the same conclusion: that the storage risks significantly outweigh disposal risks. Aside from these acute, high-level risks from accidents, either low-level agent releases from routine storage operations or low-level agent and other pollutant releases from routine disposal operations may also pose chronic health risks if not controlled. Records indicate that leaking munitions are discovered regularly (averaging more than 130 per year, largely from GB-filled M55 rockets).1 In September 1993 at Tooele Army Depot, Utah, there was a mustard leak of approximately 100 gallons from a ton container. This had a maximum distance of adverse medical effects estimated at more than 900 meters. There were no apparent exposures or casualties. The selection of an alternative technology would affect only a fraction of the releases from disposal operations (except, of course, that the risk of releases from storage would accumulate over time if an alternative technology delayed disposal). Chronic health risks from disposal operations are not well understood. However, they are believed to be low for all technologies under consideration, providing that the reaction products, which vary among the technologies, are disposed of in accordance with relevant regulations and standards. In the baseline system risk analyses, the greatest disposal risk was found to stem from transportation of materials (and associated handling) from storage areas to the disposal facility located at the site. All alternative disposal technologies will share these same activities. They also will share many other common operations, such as gaining access to the agent stored in various munitions and containers, and the disposal of energetic materials. Thus, differences in the actual agent disposal process will likely produce the only difference in overall risk. The long-term and short-term risks of the baseline system have been identified, whereas the risks of alternative technologies are largely unknown and the technical feasibility of most alternatives is unproven. However, the committee believes that all technically feasible technologies can be engineered to similar levels of safety, given sufficient time and money. Minimization of cumulative total health and safety risk may affect the disposal schedule in ways that the committee considers more important than treaty or other political considerations. Because disposal risks are generally lower than storage risks, and because agent destruction (the objective of alternative technologies) is but a fraction of disposal risk, delaying the disposal program to await the development of a safer alternative agent destruction technology (or delaying for any reason) will result in a higher overall risk. Today's evidence suggests that any reduction in disposal risk 1 The leakage rate is not high—only 0.017 percent per year for M55 rockets loaded with GB.
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Recommendations for the Disposal of Chemical Agents and Munitions afforded by an alternative technology will be more than offset by the larger cumulative risk from extended storage. It is probable that this conclusion will be verified by new, site-specific risk analyses designed to clearly define the lowest risk. Given this evidence, the disposal program should not be delayed pending development of detailed information on alternative technologies. The committee recognizes that other issues affect the selection process including social, political, economic, and even emotional issues. It will be necessary, therefore, to ensure effective public involvement in the decision-making process. For example, the construction, use, and decommissioning of disposal facilities will influence local jobs, transportation, infrastructure, and property values. There is also public concern that the facility might continue to be used as a hazardous waste facility, resulting in a continuing hazard to the local community. The committee has attempted to take these issues into account in the report that follows. All reasonable technologies have been reviewed, including an enhanced baseline system. Those technologies that are the most promising alternatives to components of the baseline system have been identified. Overall safety, as well as public participation, are emphasized as essential to the Army program. THE PRESENT BASELINE SYSTEM The baseline system is currently undergoing systemization at the first continental U.S. site, the Tooele Army Depot in Utah. This facility represents a baseline system improved as a result of the Operational Verification Testing program of the Johnston Atoll Chemical Agent Disposal System. In the baseline system, agent is removed from munitions and containers by two methods. Most are simply punched and drained, whereas artillery projectiles are mechanically disassembled to be drained. These processes yield three material streams: agents, energetic materials, and metal pans. All streams may be contaminated by agent, though the vast majority of agent is in the agent stream. This material separation is a major safety feature of the baseline system, allowing the design and operation of disposal components properly matched to the widely differing materials. Agents are pumped to, and destroyed in, a specially designed liquid incinerator. The liquid incinerator consists of primary and secondary combustion chambers and a pollution abatement system. Agent flow is stopped if the combustion chamber temperature drops below that required for agent destruction. Associated energetic materials are burned in a rotary kiln deactivation furnace system, with exhaust gases sent to an afterburner, followed by a pollution abatement system. Metal parts are decontaminated by heating them to 1000ºF for a minimum of 15 minutes in a metal parts furnace.
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Recommendations for the Disposal of Chemical Agents and Munitions Residual agent is vaporized from the metal parts and burned within the furnace. Exhaust gases are sent to an afterburner followed by a pollution abatement system that removes gaseous pollutants and particulates. Acidic gases are scrubbed from the discharge stream with alkali solutions to form salts. The brine reduction area dries collected brines from the pollution abatement system, producing dry salts for later disposal in hazardous waste landfills.2 The dunnage furnace burns contaminated or noncontaminated packing materials and miscellaneous waste or "dunnage." Exhaust gases are discharged through a separate stack without scrubbing to remove acid gases. Two auxiliary material streams, decontamination fluids used throughout the facility and ventilation air, are also processed. Except for the destruction of agent by incineration, none of these disposal operations would be eliminated by the employment of an alternative technology for agent destruction. The baseline monitoring system is used to detect agent releases and to check adherence to all environmental requirements. The system consists of a combination of the Automated Continuous Agent Monitoring System (ACAMS), which is used to provide rapid detection of immediate threats (3 to 8 minutes response time at 20 percent of permissible 8-hour exposure level for workers) and the Depot Area Air Monitoring System (DAAMS), which has a slower response time in order to achieve a much more selective laboratory analysis. ACAMS alarms require immediate agent feed shutoff. DAAMS analyses are used to confirm ACAMS alarms and to document environmental compliance. Operational Verification Testing was undertaken to gain experience with and demonstrate the baseline system at JACADS. Four testing campaigns, with representative munitions and agents, were conducted. The committee reviewed the performance of the baseline system during the testing and concluded that the system is capable of safe disposal of the stockpile. It also identified areas for improvement that should be implemented at Tooele before agent operations commence there. These included the following: upgrade of the monitoring system, demonstration of the dunnage furnace and brine reduction area or suitable alternatives, development of an abatement system for nitrogen oxides for agent disposal at continental U.S. sites if required, development and demonstration of a slag removal system for the liquid incinerator, improved control of feed materials for the deactivation furnace system and metal parts furnace, and solution of the problems of gelled agents. 2 Neither the dunnage furnace nor the brine reduction process has been proven in operations at Johnston Island. These operations (or alternative systems) must be proven before agents can be processed at Tooele.
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Recommendations for the Disposal of Chemical Agents and Munitions COMPARISON OF THE BASELINE SYSTEM AND ALTERNATIVE TECHNOLOGIES The selection of the best stockpile disposal technology should minimize the risks of agent release during both storage and disposal operations, as well as the public health and environmental risks from other process effluents. Two major routes for doing so have been considered: use of the baseline system with the improvements suggested for demonstration at Tooele or use of an enhanced baseline system with added charcoal filters; and use of completely different technologies, called alternative technologies, for destruction of one or more of the four process streams involved. Many of the candidate technologies are, or can be, developed for safe disposal of a variety of hazardous materials. However, it was necessary for the committee to use engineering judgment in developing its recommendations for promising alternatives for the very special requirements of this disposal program. In addition to the necessary fundamental process capabilities, and in keeping with the committee's desire to minimize cumulative total risk, technology readiness becomes an important selection criterion. Candidate alternatives are examined at two levels: a first screening is used to eliminate unattractive candidates, whereas the more attractive alternatives are examined in greater detail. The five major criteria, presented earlier were used in the screening. No single technology, including incineration, can satisfy all five requirements with a single process, but there are reasonable combinations that are satisfactory. The committee recommends further study of an enhanced baseline system and of four alternative technology combinations for agent destruction, all based upon neutralization (chemical hydrolysis or solvolysis) of the agent as a first step. The four alternatives are neutralization followed by incineration of the hydrolysis products, either on-site or transported to another liquid incinerator-equipped site; neutralization followed by wet air oxidation, followed by biological oxidation; neutralization followed by supercritical water oxidation; and neutralization followed by biological treatment. Neutralization is an attractive approach because it operates at low temperature and at atmospheric pressure in conventional chemical reactors. The most commonly used neutralization (or hydrolysis) reagents have been
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Recommendations for the Disposal of Chemical Agents and Munitions bases, such as sodium hydroxide, potassium hydroxide, calcium hydroxide, and ethanolamine, and oxidizers such as sodium hypochlorite. Neutralization of GB has been carried out on a large scale, but neutralization of VX and HD has been held up by the low water solubility of these agents and low reaction rates. Encouraging research results have been obtained, and research is continuing in the belief that solutions to these problems are possible. Neutralization alone may not satisfy the Chemical Weapons Convention of 1993 requirement for irreversible destruction of the agent—hence the need for a follow-up oxidation process. Wet air oxidation and supercritical water oxidation are both capable of destroying neat agent, but high operating pressures (e.g. 2,000 to 4,000 pounds per square inch) cause some safety concerns with such lethal materials. The combination of neutralization with either of these processes is synergistic: prior neutralization eliminates the extreme toxicity of the feed material to the high-pressure system, and at the same time, excess base introduced to drive the hydrolysis reaction will neutralize extremely corrosive acids formed in the subsequent oxidation step. Wet air oxidation is a proven industrial process. However, since it discharges a high percentage of organic materials, it must be followed by a subsequent oxidation process such as biological oxidation. Supercritical water oxidation may be capable of complete destruction of neutralized agents, but it is not a proven process and its application is dependent upon successful outcomes from current research programs. Biological treatment of neutralized agents will require modified neutralization processes and identification of organisms or enzymes adapted for use with each material. Neutralization followed by a second process raises the possibility of neutralization at one site followed by transport of the material off-site for subsequent treatment. Properly neutralized materials can be transported under Army control, but this option is dependent upon finding acceptable transport routes, as well as receiver sites willing and able to treat the material. This option would be particularly attractive for those sites that store only bulk agents. The committee found no feasible alternatives to incineration for energetics or for high-temperature detoxification of metal parts. Thus, even a successful alternative technology would affect only agent disposal operations and the associated potential release of either agent or other pollutants. The committee believes that alternative technologies for the liquid incinerator could be ready for full-scale pilot testing in three to seven years with a well-funded, well-staffed program, although delays in obtaining required permits for testing and for disposal operations might significantly delay implementation. In considering alternatives to the baseline system, any potential decrease in disposal risk needs to be balanced against the increase in accumulated storage risk that would result from any associated schedule delay.
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Recommendations for the Disposal of Chemical Agents and Munitions Incinerator operations at Johnston Atoll have more than satisfied all requirements for control of agent and toxics discharge concentrations, but accidents or upsets could, in principle, produce unacceptable performance until detected and corrected or operations cease. An enhanced baseline system would use charcoal scrubbing of all gaseous discharges to remove virtually all residual agent, as well as trace organics such as dioxins and other high molecular weight compounds (e.g., chlorinated compounds). This enhancement would also be effective in controlling emissions during process transient and upset conditions (e.g., loss of combustion air or sudden variations in agent feed rate). Charcoal scrubbing of the ventilation air discharge at Johnston Atoll has been highly successful. It is a proven technology at typical ambient temperatures, but some development work would be necessary for anticipated flue gas temperatures. In addition, upstream cooling and dewatering of the flue gas would be necessary to avoid condensation within the charcoal bed. FINDINGS AND RECOMMENDATIONS The committee has completed its review of the available technologies for disposal of the chemical agent and munitions stockpile. The baseline system has been demonstrated as a safe and effective disposal process for the stockpile. The current status of alternative technologies ranges from some that are in commercial use for other applications, to those that are based only on preliminary laboratory experiments. The development of a successful alternative technology for agent destruction may produce some reduction in the risks associated with that portion of disposal operations. However, all other acute and chronic risks from the other disposal operations at the six sites storing more than bulk liquid agents, and acute and chronic risks from storage at all sites, will be unaffected. Furthermore, delays in disposal operations can only increase the already much larger cumulative risk of accidental release from storage; they will extend the chronic risk from storage; and they can add to the risks of disposal as agents and munitions continue to deteriorate. Since the baseline system has already been proven, and because delays will increase cumulative total risk, the committee believes that the disposal program should proceed expeditiously at a pace in keeping with reasonable and safe facility construction and operating schedules. The only promising alternative technologies for agent disposal that have been identified involve neutralization followed by secondary treatment options. These options should be evaluated and developed at an accelerated pace so that they might potentially be available within a safe disposal schedule.
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Recommendations for the Disposal of Chemical Agents and Munitions The findings and recommendations are organized in seven categories: expeditious progress, risk analyses, public concerns, current systems, alternatives, stockpile safety, and staffing needs. Expeditious Progress Finding 1. The storage risk will persist until disposal of all stockpile materials is complete. Both storage risk and disposal risk will increase with time as the stockpile deteriorates further. Existing analyses indicate that the annual storage risk to the public at each site is the same as or greater than the annual risk due to disposal. Thus, total risk to the public will be reduced by prompt disposal of the stockpile. Recommendation 1. The Chemical Stockpile Disposal Program should proceed expeditiously and with technology that will minimize total risk to the public at each site. Risk Analyses Finding 2. Existing risk analyses did not evaluate the latent health hazards associated with storage, handling, and disposal activities. These latent risks represent one of the major concerns voiced by the public. Recommendation 2. The committee expects the latent risks from storage, handling; and disposal activities to be low. However, new risk analyses should be conducted that explicitly account for latent health risks from storage, handling, and disposal Finding 3. The finding that total risk will be reduced by prompt disposal, although apparently reasonable, is based upon earlier analyses that do not reflect current risk assessment methods and knowledge about the storage, handling, and disposal activities. Recommendation 3. Updated analyses of the relative risk of storage, handling; and disposal activities should be completed as soon as possible.
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Recommendations for the Disposal of Chemical Agents and Munitions Finding 4. The Stockpile Committee is confident that site-specific risk analyses will confirm the wisdom of proceeding promptly. Further, the schedule of the disposal program should not be delayed pending completion of the updated analyses, because they can be conducted concurrently with other activities within the overall construction and operations schedule. Both storage risk and processing risk differ from site to site. Storage risks differ greatly depending on storage configuration, types and mix of munitions, and the potential for external events, as well as nearby community conditions. Recommendation 4A. New risk analyses should be site specific, using the latest available information and methods of analysis. At this time, since there is insufficient knowledge of potential alternative technologies, a first-cut series of analyses should compare the relative risks of continued storage and disposal by the baseline system. Analyses should identify the major contributors to total risk including storage. The analyses will confirm or refute the present belief that maximum safety dictates prompt disposal. Recommendation 4B. As new, site-specific risk analyses become available, the Army should reconsider the schedule of construction and operation of disposal facilities and, if indicated, reorder the remaining sequence so as to minimize any subsequent cumulative total risk: The Army should also consider reconfiguring each high-risk stockpile to a safer condition prior to disposal if this will significantly decrease cumulative total risk: Finding 5. The committee does not foresee that any alternative agent destruction technology will substantially reduce the total agent processing risk. Site-specific risk analyses will identify the potential to improve safety over the baseline system and thus serve as a check on this belief. Recommendation 5. As research progresses on potential alternative technologies and as their potential for improved safety becomes apparent, site-specific risk analyses should be reexamined, with the potential alternative substituted in the baseline system, to estimate overall system performance. In view of the limited potential for overall safety improvement, however, the disposal program should not be delayed pending completion of such research.
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Recommendations for the Disposal of Chemical Agents and Munitions Public Concerns Finding 6. The members of the public in communities near the chemical stockpile sites have voiced diverse views and opinions regarding the stockpile disposal program, and their desire to have greater access and input into decisions concerning that program. The committee's public forum, as well as correspondence and telephone calls to the committee, indicate that the Army is not as well informed of public sentiment as desirable. The public wants a larger role in the selection of disposal technology, the monitoring of operations that ensure its own safety, and determining the fate of the facility after completion of disposal efforts. Recommendation 6. The Army should develop a program of increased scope aimed at improving communication with the public at the storage sites. In addition, the Army should proactively seek out greater community involvement in decisions regarding the technology selection process, oversight of operations, and plans for decommissioning facilities. Finally, the Army should work closely with the Chemical Demilitarization Advisory Citizen's Commissions, which have been (or will be) established in affected states. There must be a firmer and more visible commitment to engaging the public and addressing its concerns in the program. Current System Finding 7. Chemical agents and munitions materials have been successfully divided into four distinct process streams having widely differing properties. Separation of these materials for processing in distinct, well-engineered systems provides a safer and more reliable operation than would processing of a mixed stream in a single process. Recommendation 7. All disposal systems should be designed to separately process agent, energetics and associated small metal components, large metal parts, and dunnage streams. Finding 8. The committee found no acceptable alternative to mechanical methods to gain access to agent in munitions and to separate agent, energetics, and associated small metal components, and large metal parts.
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Recommendations for the Disposal of Chemical Agents and Munitions Recommendation 8. The Army should continue with mechanical methods to gain access to agent and to separate material streams. Alternative mechanical systems should be pursued if simpler, more durable concepts, which also permit separation of the streams, are discovered. Finding 9. Gelled agent, particularly mustard, is difficult to separate from its container and will hamper any agent destruction or neutralization process or any attempt to decontaminate containers. Recommendation 9. Research to develop means to extract, handle, and process gelled agents should be accelerated, to sustain the advantages of handling separate streams and to facilitate the use of alternative technologies. Finding 10. The committee found no readily applicable alternative to incineration of energetic components. Energetics are solid materials, cast in place in metal containers. In this form they are not compatible with alternative oxidation technologies that require liquid or finely divided feed materials. Extraction of energetics and reduction to suitable slurry form would be difficult and hazardous. Recommendation 10. Dispose of energetic materials by incineration. Finding 11. The committee found no alternative to high-temperature treatment for reliable decontamination of metal parts to a level suitable for release to the public. Recommendation 11. Use of the baseline metal parts furnace or other high-temperature treatment is recommended. Finding 12. The Johnston Atoll Chemical Agent Disposal System (JACADS) Operational Verification Testing (OVT) provided additional assurance that the baseline system is capable of the safe disposal of the Army's chemical stockpile. However, the committee found that OVT identified opportunities for improvements in operations, management
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Recommendations for the Disposal of Chemical Agents and Munitions practices, and training with regard to safety, environmental performance, and plant efficiency. The committee has recommended that systemization be used to implement these improvements prior to the initiation of the destruction of agent and munitions at Tooele. Recommendation 12. The Chemical Stockpile Disposal Program should continue on schedule with implementation of the baseline system, unless and until alternatives are developed and proven to offer safer, less costly, or more rapidly implementable technologies (without sacrifice in any of these areas). Baseline system improvements should be implemented as identified and successfully demonstrated. Finding 13. The Stockpile Committee finds the baseline system to be adequate for disposal of the stockpile. Addition of activated carbon filter beds to treat all exhaust gases would add further protection against agent and trace organic emissions, even in the unlikely event of a substantial system upset. If the beds are designed with sufficient capacity to adsorb the largest amount of agent that might be released during processing, addition of these beds could provide further protection against inadvertent release of agent. Recommendation 13. The application of activated charcoal filter beds to the discharge from baseline system incinerators should be evaluated in detail, including estimations of the magnitude and consequences of upsets, and site-specific estimates of benefits and risks. If warranted, in terms of site-specific advantages, such equipment should be installed. Alternatives Finding 14. After examination of all the technologies brought to the attention of the Stockpile Committee by the Alternatives Committee and others, the Stockpile Committee has determined that four neutralization-based systems offer the most promise for agent destruction. Neutralization has been demonstrated to be effective for GB but is not yet proven for mustard and VX. Utilizing lower temperatures and pressures and ordinary chemical processing equipment, neutralization is simpler than incineration, and it may be lower in cost for some sites. Recent laboratory studies have reported encouraging results for the neutralization of neat VX and mustard (see Appendix E), though questions remain for neutralizing impure and gelled
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Recommendations for the Disposal of Chemical Agents and Munitions materials. Reaction products from neutralization processes will require further treatment prior to disposal. Potentially applicable processes for further treatment of these reaction products are incineration, wet air oxidation, supercritical water oxidation, and biological treatment. All of these combinations will require further research and demonstration to ensure that the combination of these processes treats agent to levels consistent with treaty and environmental requirements. In view of the increasing total risk associated with disposal program delays, and recognizing that public opposition might delay the program for a number of reasons, including opposition to incineration, it is imperative that alternative technologies be developed promptly. Recommendation 14A. Neutralization research should be substantially accelerated and expanded to include field-grade and gelled material as appropriate and the neutralization of drained containers. Recommendation 14B. Neutralization research should be accompanied by preliminary analyses of integrated systems capable of reducing agents all the way to materials acceptable for transport or disposal Recommendation 14C. These analyses and research should be conducted in parallel to lead to the selection of a single system for further development. Finding 15. There has been continued development of various research programs involving potential alternatives since the National Research Council report Alternative Technologies for the Destruction of Chemical Agents and Munitions was issued. Recommendation 15. The Army should continue to monitor research developments in pertinent areas. Finding 16. Neutralization of agent and decontamination of containers, followed by transport of both to another facility for final treatment, offer an attractive alternative to the baseline liquid incinerator, especially for sites with no stored energetics. Receiving sites might be another chemical agent disposal
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Recommendations for the Disposal of Chemical Agents and Munitions site or commercial hazardous waste incineration facilities (if possible). This option could be viable at Newport Army Ammunition Plant and at Aberdeen Proving Ground, provided complications with gelled mustards do not arise. Recommendation 16. Neutralization followed by transport for final treatment should be examined as an alternative, at the Aberdeen and Newport sites. This examination should include location of acceptable receiver sites and transport routes, and a comparison of costs and schedules relative to on-site baseline treatment. If favorable results are indicated, the examination should be expanded as an option to eliminate the liquid incinerator at other sites. At those locations, on-site incineration of energetics and associated metal parts is still recommended. Finding 17. The current chemical stockpile disposal schedule may provide time for site-specific substitution or integration of proven alternative agent disposal processes at selected sites if research and development efforts are accelerated and results are favorable. Recommendation 17. Proven alternative technologies, if available without increasing risk; should be considered for application on the basis of site-specific assessments. Finding 18. Future developments for the baseline system as well as for a number of alternative technologies will require a flexible, agent-qualified experimental facility. Recommendation 18. The facility and staff at the Chemical Agent Munitions Disposal System (CAMDS) facility should be maintained at an effective operating level for the foreseeable future. However, agent stocks should not be deliberately retained at Tooele in order to feed an alternative technology demonstration. Finding 19. Application of all known alternative agent disposal systems will require research and development, and demonstrated safe operation (operational verification testing) with chemical agents.
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Recommendations for the Disposal of Chemical Agents and Munitions Recommendation 19. Application of an alternative technology at any site should be preceded by demonstration of safe, pilot operation (operational verification testing) at the Chemical Agent Munitions Disposal System facility. These operations should not be carried out on a trial basis at storage sites. Stockpile Safety Finding 20. A recent MITRE Corporation evaluation of stockpile condition with respect to propellant stabilization in M55 rockets suggests that the stockpile is safe until 2007 or later, whereas a similar Army report suggests 2002. The MITRE report notes that stockpile surveillance may be reduced in the belief that the stockpile will be disposed of by 2004. The committee is concerned that there is considerable uncertainty in all of the attempts to estimate safe storage life of the M55 rocket propellant. Degradation is not well understood. If surveillance is reduced, it would leave the stockpile subject to dangerous uncertainty. Further, other signs of degradation—gelled mustard, foaming mustard artillery shells, leaking and corroded ton containers—suggest that stockpile degradation can adversely affect disposal processes. Finally, realistic estimates of the duration of the disposal effort will extend well beyond 2004, particularly if alternative technologies are to be used. Recommendation 20. Further research into the nature and sequence of propellant stabilizer degradation should be undertaken promptly. The present condition of the stockpile should be evaluated with sufficient new field sampling of propellant grains, including grains from representative leakers that have been overpacked. Stockpile surveillance should be increased rather than decreased, particularly for M55 rockets. Staffing Needs Finding 21. The Army faces significant challenges in executing the Chemical Stockpile Disposal Program. As more sites begin development, important engineering and technical issues will be faced. These will cover a large spectrum over the life of this program, and will include, for example, development and maturation of alternative technologies, as well as development of a method for extracting and disposing of gelled mustard. These challenges will create more demand for planning, management, and
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Recommendations for the Disposal of Chemical Agents and Munitions supervision than the office of the Program Manager for Chemical Demilitarization will be capable of providing without augmentation. A shortage of skilled staff could have safety implications for the program, as well as its more obvious implications for program slowdown with attendant increased risk. Recommendation 21. The Army should establish a program to incrementally hire (or assign military) personnel to ensure that staff growth is consistent with the workload and with technical and operational challenges. These additional personnel must be assigned and trained before the project office gets deeply involved in addressing each challenge. The emphasis on cumulative total risk reduction in the selection of technologies for the disposal of the chemical agent and munitions stockpile leads to a strategy that also happens to have favorable cost and schedule consequences. This follows from the unusual circumstance that time and money spent in search of a better technology are likely to result in program delays and an increase in cumulative total risk, whatever the characteristics of any new technology. Although this conclusion remains to be confirmed with updated risk analyses, the existing evidence is strong enough to recommend that the disposal program proceed in parallel with the analyses and without deliberate delay. It is also clear that the updating of risk analyses should be undertaken promptly. Through Operational Verification Testing, the baseline system has a demonstrated safety record, and means have been recommended to reinforce that safety. Of the alternatives, neutralization offers the greatest direct experience with agent and, together with a process to dispose of neutralized products, the greatest potential for utilization without a needless increase in overall risk. The Army Chemical Stockpile Disposal Program should not be used as a means for experimental development and demonstration of new waste disposal technologies for other applications. It should be reemphasized that the Stockpile Committee recommends proceeding expeditiously entirely on the basis of minimizing total cumulative risk. The committee does not endorse programs that would increase risk. Others who may wish to delay the schedule in order to develop and prove alternative technologies, or to delay for any other reason, should proceed in the full knowledge that they do so at the expense of increased risk.
Representative terms from entire chapter: