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.

FRONT MATTER (R1-R18)

EXECUTIVE SUMMARY (1-5)

1 INTRODUCTION (6-14)

2 EVALUATION FACTORS (15-21)

3 FRAMEWORK FOR ASSESSING ALTERNATIVE TECHNOLOGIES (22-24)

4 CATALYTIC EXTRACTION PROCESS TECHNOLOGY (25-71)

5 MEDIATED ELECTROCHEMICAL OXIDATION SILVER II (72-101)

6 GAS-PHASE CHEMICAL REDUCTION TECHNOLOGY (102-119)

7 NEUTRALIZATION TECHNOLOGY FOR MUSTARD AGENT HD (120-142)

8 NEUTRALIZATION TECHNOLOGY FOR NERVE AGENT VX (143-154)

9 COMMUNITY AND ENVIRONMENTAL REGULATOR VIEWS CONCERNING THE ALTERNATIVE TECHNOLOGIES (155-166)

10 TECHNOLOGY COMPARISONS (167-182)

11 FINDINGS AND RECOMMENDATIONS (183-188)

REFERENCES (189-254)