7
Findings and Recommendations

OVERVIEW

The Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program has reviewed various alternative technologies for the disposal of the nation's stockpile of chemical agents and munitions. A number of specific recommendations are made in this chapter regarding the future conduct of the disposal program. Before the presentation of specific recommendations, however, it is important to present the committee's overall view of the program as background. Following the specific findings and recommendations, the chapter closes with a summary of the recommendations within the overall context of the program objectives.

Risk analyses of both storage and disposal operations have shown that cumulative total risk to the public and to the environment is dominated by storage rather than disposal operations, at least in terms of the risk of acute agent exposure. These risk analyses are being updated, but the evidence is strong that new studies will not significantly alter this distribution of risk. Furthermore, though there is no evidence of imminent disaster, storage and disposal risks must increase in time as the stockpile continues to deteriorate. The only way to avoid the continuing and growing risk from storage, of both acute agent exposure and long-term health risks, is to eliminate the hazardous materials.

The baseline system, which employs a number of preparation steps followed by incineration to destroy or decontaminate four distinctly different process streams, has been demonstrated as a safe and effective disposal process for the stockpile. However, the use of incineration for the disposal of hazardous materials has been generically challenged by some critics. The Stockpile Committee recognizes this objection and has made recommendations for alternative technologies that would replace the incinerator where the bulk of the agent is destroyed. The committee believes these technologies can be successfully developed with aggressive research and development programs. Furthermore, the committee believes that with sufficient effort, these technologies can be proven to afford essentially the



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Recommendations for the Disposal of Chemical Agents and Munitions 7 Findings and Recommendations OVERVIEW The Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program has reviewed various alternative technologies for the disposal of the nation's stockpile of chemical agents and munitions. A number of specific recommendations are made in this chapter regarding the future conduct of the disposal program. Before the presentation of specific recommendations, however, it is important to present the committee's overall view of the program as background. Following the specific findings and recommendations, the chapter closes with a summary of the recommendations within the overall context of the program objectives. Risk analyses of both storage and disposal operations have shown that cumulative total risk to the public and to the environment is dominated by storage rather than disposal operations, at least in terms of the risk of acute agent exposure. These risk analyses are being updated, but the evidence is strong that new studies will not significantly alter this distribution of risk. Furthermore, though there is no evidence of imminent disaster, storage and disposal risks must increase in time as the stockpile continues to deteriorate. The only way to avoid the continuing and growing risk from storage, of both acute agent exposure and long-term health risks, is to eliminate the hazardous materials. The baseline system, which employs a number of preparation steps followed by incineration to destroy or decontaminate four distinctly different process streams, has been demonstrated as a safe and effective disposal process for the stockpile. However, the use of incineration for the disposal of hazardous materials has been generically challenged by some critics. The Stockpile Committee recognizes this objection and has made recommendations for alternative technologies that would replace the incinerator where the bulk of the agent is destroyed. The committee believes these technologies can be successfully developed with aggressive research and development programs. Furthermore, the committee believes that with sufficient effort, these technologies can be proven to afford essentially the

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Recommendations for the Disposal of Chemical Agents and Munitions same level of processing safety and effectiveness for disposal of agents as the baseline system. The current status of potential alternative technologies ranges from some that are in commercial use for other applications to those that are based only on preliminary laboratory research. Given the availability of a proven disposal system, it is the committee's view that the total risk will be minimized if the baseline disposal program proceeds expeditiously at a pace in keeping with reasonable and safe facility construction and operating schedules. At the same time, promising alternative technologies for agent disposal have been identified. These should be developed at an accelerated pace in order that they might prove beneficial within that expeditious schedule. Given the persistent storage risk, the disposal schedule should not be deliberately delayed or interrupted in order to foster the application of emerging alternative agent disposal technologies, particularly since the committee does not believe that any alternative disposal technology will significantly reduce the total processing risk. SPECIFIC FINDINGS AND RECOMMENDATIONS 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.

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Recommendations for the Disposal of Chemical Agents and Munitions 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. 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

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Recommendations for the Disposal of Chemical Agents and Munitions 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. 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

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Recommendations for the Disposal of Chemical Agents and Munitions 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. 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.

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Recommendations for the Disposal of Chemical Agents and Munitions 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 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

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Recommendations for the Disposal of Chemical Agents and Munitions 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 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.

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Recommendations for the Disposal of Chemical Agents and Munitions 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 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.

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Recommendations for the Disposal of Chemical Agents and Munitions 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. 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

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Recommendations for the Disposal of Chemical Agents and Munitions 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 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.

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Recommendations for the Disposal of Chemical Agents and Munitions SUMMARY Existing information indicates that the disposal risk at individual sites, using the baseline system, is generally less than the stockpile storage risk, often substantially less. Further, even if this were not true, the accumulating risk of continuing storage would offset any decrease in disposal risk afforded by an alternative technology, particularly since alternative technologies are not likely to significantly reduce the disposal risks. The existing evidence is therefore strong enough to suggest that the baseline 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 to check this conclusion. Emphasis on overall safety in the selection of technologies for the disposal of chemical agents and munitions leads to a program that also happens to have favorable cost and schedule consequences, which will be of interest to those who must make the final decision. This follows from the unusual circumstance that time and money spent in search of better technology are likely to result in delays that increase overall risk, whatever the characteristics of the new technology. 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. 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 and, together with a process to dispose of neutralized products, the greatest potential for utilization without a needless delay and increase in overall risk. Sticking with existing system, or with the most proven alternative, in the apparent interest of short-term savings in time and cost is a criticism often leveled at complacent U.S. industries in the face of progressive foreign competition, and rightly so. Failure to develop for the future can lead to failure of the industry. However, short-term savings in time and cost are not the issues that have driven the Stockpile Committee's recommendations. Furthermore, as this committee and previous National Research Council committees have repeatedly written, the disposal of chemical agents and munitions is an industry without a future. The task at hand is to dispose of the existing stockpile as safely as possible. It is not to build an industry for disposal of future materials or of foreign stockpiles. It is well beyond the

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Recommendations for the Disposal of Chemical Agents and Munitions scope of the Army Chemical Stockpile Disposal Program, and unfair to the affected communities, to use this program for the experimental development and pioneering demonstration of new waste disposal technologies that might be used in some future facility to dispose of materials far less hazardous than chemical warfare agents.

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