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--> 3 Framework for Assessing Alternative Technologies This chapter describes the framework and procedures within which the evaluation factors described in Chapter 2 were used to carry out the work of the AltTech Panel. The first section describes the framework as it was used to produce data-gathering questionnaires. The second section explains the basis for a supplementary consideration that arose during the study—the potential for the off-site treatment of process residuals. Framework for the Questionnaires Because of the short duration of this study, the strategy for gathering data was critical. In particular, a framework for the information needed to address the evaluation factors (see Chapter 2) had to be ready prior to requesting information and making site visits to the Army and the TPCs. Because the panel had limited time for direct meetings with the TPCs and the Army, the panel provided advance notice of the type of information required. The evaluation factors were converted into a "Questionnaire for Technology Assessment" (see Appendix J ), which was sent to each TPC and to the Army. Another reason for the questionnaire was to ensure that the proponents had fully considered all aspects of their technologies in the written responses, which the panel would later use to assess the technologies. The panel's evaluation was based on the completed questionnaires, additional data obtained in the course of the site visits, and information from follow-up questions and discussions. The panel formed itself into technology assessment teams of approximately four members each, based on the expertise of the individual members. Each team was responsible for organizing the site visits to gather data on one technology, for analysis and evaluation of the data, and for the initial draft of the analytical chapter on that technology. The assessment teams reported on the status of their findings and evaluations at the full panel meetings. The analytical chapters were subsequently reviewed, revised, and approved by the full panel. The assessment teams also made follow-up trips and telephone calls as necessary to obtain needed information. The panel found that the TPCs and the Army were very responsive to the checklist questions. Several data iterations ensued until the cutoff date of April 4, 1996. The absence of data in some responses to checklist items helped the panel and the respondents to focus further efforts where they were most needed. The discussion of each technology in the analytical chapters (Chapters 4 through 8) follows the questionnaire framework, which consisted of the following categories: process description; scientific principles; technology status; operational requirements and conditions; materials of construction; process stability, reliability, and robustness; operations and maintenance; utility requirements; scale-up requirements; facility decommissioning; process safety; and schedule. Each submission was required to provide a total solution to chemical demilitarization at the two sites, including handling and processing containers, treating dunnage and decontamination solutions, as well as destroying chemical agents. Process Description. A detailed process description was needed so that the panel could understand the overall approach to agent destruction. The panel asked that the description include all available drawings and other materials needed for the panel to evaluate all components proposed as part of a pilot system. Scientific Principles. To facilitate understanding of the basic physical and chemical principles underlying the technology, the panel asked for complete disclosure of all expected chemical reactions and end products. Technology Status. The panel was interested in the degree of maturation and proof-of-concept demonstrations of the technology. Technology status proved challenging to evaluate because of the ongoing development of the technologies while the study was under way.
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--> Operational Requirements and Considerations. This category addressed how the process would operate under actual conditions. Operational requirements included all process instrumentation and controls, material and energy balances, and the methodology and locations for disposing of process residuals. Operational considerations included how the bulk containers of agent would be moved from the storage location to the treatment facility; how the agent would be decanted, fed into the process, and treated; how remaining agent and agent heels in the ton containers, as well as the ton containers themselves, would be treated; and how process residuals would be managed, including the treatment and disposition of drained ton containers. Materials of Construction. In addition to the materials to be used in constructing the facility, this category included questions about process streams, environmental chemistry, qualification of materials for use in the proposed facility, failure modes, material monitoring and inspection, and the previous experience of the TPC in operating the technology at processing rates and operating conditions (e.g., temperature, pressure, and materials) similar to those required for a pilot-scale demonstration of agent destruction. Process Stability, Reliability, and Robustness. Process stability included consideration of potential deviations from "normal" operations that could lead to uncontrolled reactions or catastrophic failure of the facility. Reliability included information about the reliability of the equipment, such as whether it is in common use in the chemical industry and its performance under comparable operating conditions. Operations and Maintenance. Issues of interest in operations included staffing and training requirements for operating a facility, the TPC's operational experience with the technology, operational safeguards and control systems, and startup/shutdown procedures. Under maintenance, the panel was interested in maintenance procedures and manuals, downtime expectations, documentation that maintenance was done, equipment replacement procedures, and maintenance staffing requirements. Utility Requirements. The panel asked for the electrical, water, and fuel requirements for each process. Utility requirements only become a significant consideration if local sources would be unable to meet demand during an agent destruction campaign. Scale-Up Requirements. The panel asked at what scale each technology had already been demonstrated and with what feed materials. Other questions concerned the extent to which the process, or parts of it, had been demonstrated commercially, how process streams would increase in mass and volume, and whether scale-up might affect design of the chemical reaction vessel or other key components. Facility Decommissioning. The agent destruction facility will be decommissioned after the stockpile is destroyed. The panel asked about the process by which the facilities would be removed and the extent of site remediation needed. Process Safety. Process safety issues include the potential risks of catastrophic failure and agent release, in-plant risks and hazards to workers, and the risks to the neighboring community and the environment from agent or other hazardous chemicals, whether from long-term, low-level exposures during normal operation or from brief but higher-level exposures after an accidental release. Schedule. Because the storage risk to the community remains until the stockpile is destroyed, the panel sought to determine the time required to design, construct, and evaluate a pilot plant and the time for construction and systemization of a full-scale facility. Off-Site Transport, Storage, and Processing of Process Residuals Internal Army procedures require special approval for off-site shipment, storage, or processing of wastes derived from agent processing. At the time of the Commerce Business Daily announcement of the Army's interest in alternative technologies (see Chapter 1), the program manager for the CSDP (Chemical Stockpile Disposal Program), who is often referred to as the program manager for chemical demilitarization (PMCD), had limited the requests for such approval to individual cases of shipping, storing, or processing contaminated (or possibly contaminated) materials. Examples included contaminated wastes from laboratory work on agents (analyses, investigation of destruction processes, etc.), potentially contaminated salts from the brine reduction systems at the Johnston Atoll and Tooele stockpile sites, and decontaminated personal protective suits from these sites. Special approvals have also been
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--> obtained by other parts of the Army for shipping ton containers decontaminated to a 3X status at the Rock Island Arsenal, Illinois, to be melted down, tested, and released for general reuse. Because of the limited conditions under which special approval had been sought or given in the past, the Commerce Business Daily announcement requested information only on technologies that would not require the off-site shipment of contaminated wastes, except for ton containers treated to 3X condition. After the announcement and the start of the AltTech Panel's work, the Army recognized that there might be a programmatic advantage to off-site waste treatment by one or more licensed commercial treatment, storage, and disposal facilities (TSDFs) that have both extensive experience in handling hazardous wastes and the facilities to do so. However, uncertainty remained about the capabilities of commercial TSDFs, their willingness to accept the process residuals from an agent destruction facility, and the costs for their services. Accordingly, the Army conducted a study to characterize the probable residuals from the neutralization processes (for which it had data to specify the residuals) and to determine the likelihood that they would be acceptable for subsequent treatment or disposal, or both. The Army then conducted a survey to acquire information on the general feasibility of and costs associated with various types of off-site shipment and disposal of process residuals. Although the report on the results of the study and survey is only in draft form (U.S. Army, 1996c) and the Army is continuing to evaluate further details of off-site shipping, the initial results indicated that process residuals probably would be acceptable to several off-site facilities and several commercial facilities are interested in performing such services. The Army also obtained cost information from this survey, but the cost information was not considered by the AltTech Panel in the technical evaluation of alternative technologies. The CSDP staff has since taken further action by requesting and receiving approval to ship the following items for off-site disposal (U.S. Army, 1996d): solid wastes generated from laboratory and monitoring operations: paper; plastic; glass; metal; wood; absorbents; and personal protective equipment (PPE) including gloves, boots, outer garments, and self-contained breathing apparatuses liquid wastes from laboratory and monitoring operations: decontamination solutions, acids, alkaline solutions, flammable liquids, rinse solutions, and analytical solutions plant wastes: filters (pre-filters, high-efficiency particulate-arresting filters, charcoal filters), PPE, dunnage, spill debris (rags, absorbents, plastic bags, and plastic sheets), brine salts from the pollution abatement systems, demister packing, ash from the furnace systems, and pieces of utility and process equipment Although this list does not include all process residuals, it does include a number of components that might ease the burden on several of the alternative technologies being evaluated and sets the stage for possible future approval of off-site shipment, storage, or processing of other plant wastes. Although the Army study of this option has not yet been completed and the Army has not yet formally changed its policies, the panel found nothing in the available documentation that would preclude it. The panel recognizes that procedures will have to be developed, such as setting standards and defining best practices for off-site shipping and treatment. Particulars include the maximum allowable residual concentrations of agent and other toxic components in various residuals, the methods for measuring and verifying the actual concentrations, and pathway constraints to ensure the safety of workers, the public, and the environment. Procedures will also have to be developed to allow verification that all precursors in the process residuals have been destroyed at the off-site location. In light of this information, and at the direction of the Army as sponsor of the study, the AltTech panel agreed to expand the evaluation framework to include consideration of the off-site shipment and processing of wastes (see Appendix D). The reader should remember, however, that the technologies submitted by the other TPCs represented "total solutions" to chemical demilitarization and included methods for processing ton containers, decontamination solutions, and dunnage, as well as the destruction of chemical agents. Because the Army may not have discussed the implications of a change in Army policy with the TPCs, no modified concept design packages were received from them by the April 4, 1996, deadline. However, because submissions by the Army did include off-site shipment and treatment for hydrolysate from the neutralization processes, these options were considered and are addressed in Chapters 7 and 8.
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