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2 Evaluation Factors This chapter describes the factors the ACW Com- mittee used to evaluate the technology packages for ACWA. The committee reviewed the criteria in DOD's RFP (U.S. Army, 1997a) and in the 1996 NRC report, Review and Evaluation of Alternative Chemical Dis- posal Technologies (AltTech Report), which focused on the disposal of bulk chemical agents stockpiled at the Aberdeen Proving Ground, Maryland, and the New- port Chemical Activity, Indiana (NRC, 1996a). The criteria in the RFP represented a consensus developed by DOD and the Dialogue. After some deliberation, the committee concluded that the program-implementation criteria in the RFP, which are very similar to the criteria in the AltTech Report, incorporated all of the major factors required for this study. The committee made some slight addi- tions to provide more detail in selected areas and elimi- nated cost as a factor, except as it was reflected in the maturity and complexity of the technology package. The committee did not attempt to estimate costs. The primary evaluation factors are: · Process Efficacy. Does the system meet the re- quirements for the demilitarization of munitions (especially those covered by the CWC), including the destruction of agent and energetic material, the disassembly of munitions (if needed), and the de- contamination of metal and other parts? Are the sampling and analysis methods well developed and appropriate? Is the system likely to operate in a stable and reliable manner under industrial con- ditions? Have the components and processes of the system been proven in similar applications? Is 23 the system flexible enough to treat several muni- tion types, and can it deal with anomalies in the munition feeds? Process Safety. Is the process safe, and does it in- clude adequate protection for workers and the pub- lic in the event of an accident? (The definition of safe is the same one used by the Stockpile Com- mittee and the AltTech Panel: minimization of to- tal risk to the public and the workers.) · Human Health and the Environment. During nor- mal operation, does the system expose workers, the public, or the environment to excessive health risks? Are the waste streams adequately charac- terized, and can they be managed in accordance with regulatory limitations? What are the resource requirements? Is permitting relatively straightfor- ward, or are there significant unknowns? Public Acceptance. Are there impediments to the acceptance of this technology package by the pub- lic? Will the package be perceived as too similar to incineration by concerned citizens? Is the pub- lic likely to accept the composition and disposi- tion of the final waste streams? Regardless of the technical approach, the destruc- tion of assembled chemical weapons is a complex pro- cess involving many interrelated steps. For the pur- poses of the evaluation, the committee divided the overall demilitarization process into the following six major operations: · Munitions disassembly involves the segregation of parts into chemical agent, energetics, other parts,
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24 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS and dunnage. The latter three may or may not be contaminated with chemical agent. The treatment of chemical agent involves detoxi- fying the agent and reducing it to environmentally acceptable products. The treatment of energetics involves decompos- ing energetic materials and reducing them to inert and environmentally acceptable products. The treatment of metal parts involves decontami- nating the munition metal casings. The treatment of dunnage involves decontaminat- ing munition packing materials and demilitariza- tion protective ensemble (DPE) suits. - The disposal of waste involves disposing of waste streams from all of the treatment systems. The technology packages were evaluated for all of these operations in terms of the four primary evalua- tion factors (process efficacy, process safety, human health and environment, and public acceptance), each of which has several subfactors. A detailed discussion of the primary factors and their associated subfactors is provided below. Some of the subfactors could have been placed under more than one primary factor. Thus, the grouping of the subfactors under a particular factor is somewhat arbitrary. The groupings parallel the breakdown in the REP whenever it was reasonable. PROCESS EFFICACY Process efficacy encompasses the effective demili- tarization of the assembled chemical munitions and the reduction of the waste products to disposable materi- als. The proposed process must also be able to destroy all of the agents and all of the energetics in the stock- pile at a given site. The process must also be control- lable, reliable, and robust. That is, if some variation in the process conditions occurs, the process must be ca- pable of continuing or returning to normal operation automatically and easily. Possible variations include changes in feedstocks, excursions in temperature or pressure, and changes in pH, electrical conductivity, or other process conditions. In addition, the process must generate material streams that can be reliably sampled and analyzed in order (1) to control the process, (2) to obtain accurate mass balances, and (3) to verify the composition of waste streams. Finally, the waste streams must be well characterized to support health and environmental evaluations and to determine options for further waste management. Efficacy includes the maturity of the process. Dur- ing development, a process advances from simple labo- ratory bench-scale experiments to larger scale labora- tory trials to pilot-plant scale and, finally, to full-scale operation. In general, the further a process is from the full-scale phase, the more likely unforeseen problems are to arise that will delay its development. The subfactors under process efficacy are listed be- low and discussed in the following pages. · effectiveness -ability to disassemble the munitions capacity to decompose and detoxify chemical agents and to reduce the products to disposable waste streams capacity to decompose and deactivate ener- getic materials and to reduce the products to disposable waste streams - ability to decontaminate munition parts and other materials · sampling and analysis · maturity · robustness · monitoring and control · applicability Effectiveness Ability to Disassemble Munitions Most of the technology providers proposed using the baseline disassembly process discussed in Appendix C. However, some proposed modifying it, and some proposed alternatives. If a system uses the baseline dis- assembly process, the committee considered the extent of the modifications and the impact of these modifica- tions on the timing and operation of the disassembly procedure. In general, the more extensive the modifi- cations, the greater the likelihood of delays and prob- lems during development. The committee also consid- ered the level of detail in the design and whether any tests had been performed to evaluate the proposed modifications.
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EVALUATION FACTORS When a technology provider selected another method for disassembly or pretreatment, the commit- tee examined the past history and performance of the method in other applications and its suitability for the unique tasks at hand. The following areas were of par- ticular interest: · How were previous applications of the disassem- bly method similar to the proposed application? How were they different? · At what throughput rate had the method been dem- onstrated, and for what period of time? · What problems were encountered, and how were they solved? · Had remote operation been demonstrated? Capacity to Decompose and Detoxify Agent An effective process must be capable of consistently destroying (i.e., decomposing and detoxifying) the chemical agent during operation under all conditions, including the presence of impure agent, gelled agent, contaminated explosives, and contaminated solids. To detoxify a chemical agent satisfactorily, the reaction must proceed until the concentration of agent is below a specific level, often specified in terms of a destruc- tion efficiency, defined as the percentage destroyed. The Army has specified a destruction efficiency of 99.9999 percent for chemical agent, based on the most stringent regulatory requirement under the Resource Conservation and Recovery Act (RCRA) for the de- struction of dioxin one of the most toxic regulated iFor incineration systems, the term destruction and removal efficiency (DRE) is often applied. DRE is a very specific term used by the Environ- mental Protection Agency (EPA) to evaluate the performance of incinera- tion systems in destroying hazardous wastes. EPA defines DRE as (Win- WOu~)/Win, where Win is the mass feed rate of hazardous waste to the incin- erator, and WE is the mass emission rate of hazardous waste present in the gaseous exhaust prior to release to the atmosphere (ASME, 1988). Thus, DRE has a very specific meaning and is a measure of the waste remaining in gaseous exhaust emissions. DRE does not take into account potentially haz- ardous constituents in the input streams that become part of the solid or liquid effluent phases. This committee believes the hazardous waste re- maining in all effluent streams should be considered and, therefore, uses the more "generic" term destruction efficiency throughout this report to refer to the fraction of a particular material destroyed. For a treatment step, destruc- tion efficiency will be defined as (Min - MoU~)lMin, where Min is the mass feed rate of the particular material in the treatment step, and Mom is the mass emission rate of that material present in all effluent streams after that treatment step. The committee has found that DRE is sometimes inappro- priately used by the Army and the technology providers. 25 substances. The committee's evaluation factors include the ability of the technology packages to meet this Army requirement. An acceptable process must, therefore, have an agent destruction efficiency of 99.9999 percent or greater.2 In addition to the destruction efficiency, the Army sets limits on allowable contamination by chemical agent of materials to determine if the material (1) must be retained in an agent-controlled facility, (2) may be re- leased to a hazardous waste treatment facility for fur- ther treatment, or (3) may be released to the environ- ment or to the public sector. The contamination levels, which differ for gases, liquids, and solids, are given below. Gases. The release of gases to the atmosphere is con- strained by a health-based general population limit at the site boundary. The limit values for HD, GB, and VX are, respectively, 0.1, 0.003, and 0.003 ,ug (micro- grams) per cubic meter of air. Liquids. No standards have been established for the unconditional release of liquids containing chemical agents. The standard for the release of certain specified liquid wastes from incineration facilities to qualified disposal facilities is 200 ppb (parts per billion) for HD and 20 ppb for GB and Vx.3 These levels were taken from the standard for military drinking water in the field. Solids. The Army has three primary classifications for solids contaminated with chemical agent. The first classification, 1X, refers to contaminated solid mate- rial that has not been subjected to decontamination or testing. This material cannot be released from Army- supervised agent-control areas. The second classifica- tion, 3X, is for solids that have been decontaminated to the point that the agent concentration in the head space above the encapsulated solid does not exceed the health-based, eight-hour, time-weighted average limit for worker exposure. These levels for HD, VX, and GB are, respectively, 3.0, 0.01, and 0.1 ,ug per cubic meter of air. A 3X material may be handled by qualified plant Destruction efficiencies are often expressed as the number of 9's in the percentage. Therefore, 99.9999 percent may be referred to as "six 9's." 3At the time of this writing, the Army was verifying that detection of VX down to 20 ppb in hydrolysate was possible with current analytical meth- ods. Resolution of this issue is pending.
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26 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS workers using appropriate procedures but is not releas- able to the environment or for general public reuse (i.e., not releasable "to the public". In specific cases in which approval has been granted, a 3X material may be shipped to an approved hazardous waste treatment facility for disposal in a landfill or for further treat- ment. The third classification, 5X, is defined as fol- lows (Department of the Army, 1997~: An agent symbol with five "Xs" (XXXXX) indicates an item has been decontaminated completely of the indicated agent and may be released for general use or sold to the general public in accordance with all applicable federal, state, and local regulations. An item is decontaminated completely when the item has been subjected to proce- dures that are known to completely degrade the agent molecule, or when analyses, submitted through MACOM (Major Army Command) and DA (Department of the Army) channels for approval by the DDESB (Department of Defense Explosives Safety Board), have shown that the total quantity of agent is less than the minimal health effects dosage as determined by The Surgeon General. SX condition must be certified by the commander or des- ignated representative. One approved method is heating the item to 538 degrees C (1,000 degrees F) for 15 m~n- utes. This is considered sufficient to destroy chemical agent molecules. in addition to meeting the Army requirements listed above, a process must meet the requirements of the CWC, which states that chemical weapons destruction must take place using "a process by which chemicals are converted in an essentially irreversible way to a form unsuitable for production of chemical weapons, and which in an irreversible manner renders munitions and other devices unusable as such." The requirement of irreversibility implies that both the chemical agents and any by-products that could be readily converted to chemical agent (CWC Schedule 2 [agent "precursor"] compounds) must be destroyed by the process. The CWC imposes no numerical requirements (e.g., the destruction efficiency) on the degree of agent or Sched- ule 2 compound destruction. It specifies only that the destruction should be irreversible, safe, and environ- mentally friendly. Environmental regulations include specifications for the allowable quantities of some Schedule 2 com- pounds in process effluents. Because Schedule 2 com- pounds are much less toxic than chemical agents, the destruction efficiencies set by the Army for these compounds are less stringent than for agents. For ex- ample, the design-basis destruction efficiency for ethylmethylphosphonic acid ([EMPA]; a Schedule 2 precursor to VX) is 99.9 percent, compared to 99.9999 percent for VX (U.S. Army, 1997c).Thus, to evaluate the capacity of a technology package to decompose and detoxify agent, the committee considered its ability to achieve the required destruction efficiency for agents and Schedule 2 compounds and to reduce the agent contamination in other media to below the allowable levels. Capacity to Decompose and Detoxify Energetics Effective processes must be capable of consistently destroying energetic materials by decomposing them to nonenergetic compounds. The concentration of residual energetic materials or toxic by-products must not exceed established limits for release to the environment. This is significantly different from merely rendering a material safe to handle or reducing the hazard classi- fication of explosives or propellants. Energetic materi- als must not be simply diluted so that they will not react or propagate with explosive or propulsive vio- lence. Standard laboratory sensitivity tests, such as impact, friction, electrostatic discharge, vacuum ther- mal stability, or differential scanning calorimetry can- not be used to measure acceptance or ensure quality because substantial explosive residues may be present but may not produce a positive response to standard tests. The decomposition of energetic materials such as RDX (cyclotrimethylenetrinitramine), Composition B. tetrytol, or M28 double-base propellant requires that the process reactions destroy the energetic chemical bonds (e.g., N-NO2, C-NO2, or C-ONO2~. The reaction is usually considered complete when the concentrations in liquid process effluents do not exceed the limits per- mitted for either a publicly owned treatment facility or by state environmental permits. For example, the limit typically established by local sanitation districts is less than or equal to 1 ppm (part per million) of energetic material in water. Lot acceptance testing is usually per- formed by either high-pressure liquid chromatography or a gas chromatograph/mass spectrometer. The vapor- phase process emissions (e.g., NO, NO2, CO, CO2, etc.)
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EVALUATION FACTORS must be managed to meet local or state ambient air quality standards. Any solids and/or hazardous wastes generated by the process must be sufficiently charac- terized so that appropriate landfill sites or other means of disposal can be identified. The committee, therefore, considered the ability of the proposed system to decompose the energetic materials into nonenergetic compounds and achieve the residual concentrations required by environmental regulations. Decontamination of Meta/ and Other Munitions Parts Once the agent and energetic materials have been removed, the remaining parts of the munition must be decontaminated to either the 3X or (preferably) 5X level before disposal or release to the public sector (as allowed). If the parts were only at the 3X level, the technology provider was required by the REP to de- scribe how these parts would be disposed of. Disposa/ of Other Contaminated Materials The process must also dispose of a variety of other agent-contaminated wastes generated during demilita- rization. These include decontamination solutions, used DPE suits, and spent activated carbon filters. The com- mittee evaluated the ability of each technology to dis- pose of these contaminated materials while meeting the required decontamination standards. Sampling and Analysis To verify process performance, stream compositions must be sampled and analyzed at various stages. Sam- pling is required to validate monitoring and control of the process, to determine mass balances of the major constituents, and to characterize waste streams before release to the environment. Analytical techniques must be sensitive enough to determine the presence of and measure the levels of trace constituents in the waste streams. These trace components are often the constitu- ents of greatest concern to the public and in health risk assessments (HRAs). Detection limits and sensitivities depend on the nature of the compound and the media in which it is contained. All phases (solid, liquid, and gas) within each waste stream must be analyzed (e.g., liquid plus particulates). 27 A process could, for example, simply dilute critical streams to below the sensitivity level of available sam- pling and analytical methods. In that case, it would be impossible to verify that the process had achieved its treatment objectives during operation. Although there is some dilution of toxic materials in most processes, this cannot be the primary mechanism for reducing the concentration of toxic material in effluent streams to acceptable levels. Therefore, the committee examined the proposed processes in the context of available sam- pling and analytical methodologies to establish whether their performance could be verified. The committee considered the detection limits of current analytical methods for chemical agents, energetics, and the major and minor products of destruction. Process Maturity The committee defined maturity of a technology as the stage to which the technology had progressed to- ward industrial operation and, hence, the level of con- fidence that the process would operate successfully at full scale. In general, chemical-process technologies can be located along a developmental continuum from laboratory-scale to proof-of-concept testing to pilot- plant demonstration and, ultimately, to full-scale op- eration. Laboratory-scale testing refers to the basic development of the treatment processes. Proof-of- concept refers to the testing at sufficient scale to dem- onstrate that the technology is a workable process. The earlier a process is on the continuum, the greater the uncertainty of its full-scale performance and the greater the likelihood that unanticipated problems will cause delays in its implementation. Many considerations are involved in determining whether a technology is ready to move to the next stage or how close it is to being "successfully demonstrated" at a given stage. For instance, at the laboratory scale, assays and chemical analyses are important for estab- lishing that the desired reactions predominate and that unwanted side reactions can be controlled or elimi- nated. During proof-of-concept testing, it is important that critical components of the treatment process be tested with either actual target chemicals or with realis- tic surrogates under process conditions that simulate the expected conditions under full-scale operation. At the pilot-plant stage, precise mass and energy balances
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28 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS become essential, along with quantitative characteriza- tions of how key process variables affect outcomes. The documentation for a pilot design must be complete enough for a preliminary assessment of risks related to the hazard inventory (e.g., agent concentrations at each process step, reactive materials, pressure) and the safety features, such as process interlocks and safe means of releasing excess material or energy. A matu- rity status is, therefore, not a simple classification but a running checklist of what has been accomplished to date and what remains to be done. The maturity level of a technology was based on the documentation and evidence submitted by the technol- ogy providers. Committee representatives visited sites suggested by the technology providers to confer with knowledgeable personnel and to observe experimental equipment the providers had designed and constructed. In this way, the committee was able to assess the cur- rent state of development of the proposed systems and technologies. Process Robustness Robustness, a significant factor in the evaluation, is defined as the ability of the total process to achieve its objectives even when the properties of the material being processed deviate from the nominal or average or when a process component does not behave as in- tended. For example, a process must be able to contain the explosion of a fuze or the ignition of rocket propel- lant during processing. If a more modest deviation oc- curs, the process must be capable of returning to nor- mal operation without incident. Determining the ability of a process to treat pure, uncontaminated (neat) chemical agents was the first step in the committee's evaluation. However, past ex- perience with the baseline systems at Johnston Island and Tooele, Utah, has shown that unforeseen condi- tions occur frequently. Examples are listed below: · A significant fraction of the chemical agents and energetics found in the munitions contain substan- tial impurities. · The agent in many munitions may have become partially gelled or crystallized, making it difficult or impossible to drain the agent from the munition casing. (At Johnston Island, such munitions are treated in the metal parts furnace where the gelled or crystallized agent is vaporized and burned. Be- cause the munitions are essentially undrained, throughput rates are greatly reduced to limit the amount of agent present in the furnace. For nonincineration processes, other ways of handling these munitions must be found.) · Some of the energetics may have deteriorated to the point of potential instability, increasing the risk of deflagration or explosion during processing. (At Johnston Island and Tooele, explosion contain- ment structures are used to house the energetics processing and destruction activities. A similar approach could be used with alternative technol- ogy packages.) · Components of some munitions have rusted or corroded, making disassembly difficult. · The attempted removal of the lifting lugs from projectiles during baseline disassembly has some- times caused the lug to fuse to the shell body. The proposed system must be capable of dealing with these conditions and should be flexible enough to re- spond effectively to other unanticipated occurrences. The committee also considered the ability of the sys- tem to process multiple feeds (agent, energetics, metal parts, process wastes) simultaneously and the impact this could have on the overall robustness of the system. Process Monitoring and Control Each process must be monitored continuously at various stages and locations to ensure the destruction of agent and energetics and to verify that operating conditions are satisfactory. Proper operation requires that the process include built-in controls to maintain temperatures, pressures, flow rates, pH, and other key parameters within the necessary ranges. All of the technology providers proposed using stan- dard Army technology to monitor for chemical agent. They also proposed using state-of-the-art distributed monitoring and control systems linked to a central con- trol room and data-collection system. Because the overall proposed monitoring and con- trol systems were standard industrial configurations, the committee focused its evaluation on aspects of monitoring and control that appeared to be unique or
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EVALUATION FACTORS potentially difficult. The committee examined each process from the perspective of how effectively it could be monitored and controlled, whether the process was understood well enough to allow implementation of a sound monitoring and control strategy, and whether existing monitoring and control technologies could pre- vent or control process upsets. Process Applicability In the REP, DOD allowed the technology providers to discuss the destruction of only one type of munition. Clearly, a practical process must be able to destroy all types of munitions at a given site. Thus, a process must be capable of treating all of the chemical agents and energetics found at a site. PROCESS SAFETY Process safety factors include risks to workers and risks to the nearby public from accidents. In this report, the term risk refers to the chance of adverse conse- quences (e.g., fatalities) from some event. Risk evalua- tions of processes for destroying chemical weapons should include the consequences of releases of chemi- cal agent and of accidental detonations and conflagra- tions of energetic materials. Risks during the storage, transportation, handling, and disassembly of munitions should also be considered, as well as risks from the actual destruction process. A comprehensive assessment of safety requires quantitative risk assessments (QRAs), which can only be done based on a detailed plant design. Because of the immature status of the systems reviewed in this re- port, quantitative evaluations at almost any level that would be consistent across all of the technologies could not be made. However, the committee has performed a qualitative evaluation of whether each technology can be operated safely. The qualitative evaluation focused on identifying intrinsic and probable safety issues and how technology providers propose to respond to these issues. Issues unique to a technology were emphasized over across-the-board issues (e.g., baseline munition unpacking and handling operations). The safety-related analyses of the committee are referred to as evalua- tions rather than assessments. The term assessment is reserved for actual risk assessments, which should be 29 performed later (following the demonstration phase) when more complete descriptions will be available and a commitment to a particular design has been made. The ACW Committee considered the following subfactors in the category of process safety: · worker health and safety normal facility operations facility accidents · public safety facility accidents · transportation accidents Worker Health and Safety In-plant safety and health risks depend on the nature and magnitude of the hazards inside the process facil- ity. The committee's preliminary evaluation of each alternative technology included the following aspects of in-plant risks: · major failure and agent release · worker exposure to agents without catastrophic failure · worker exposure to other hazardous chemicals used or produced during the process · worker exposure to other hazardous process con- ditions (e.g., high temperature, electromagnetic ra- diation, electrical energy, moving equipment, etc. The severity and likelihood of these risks are af- fected by the following factors: · hazard characteristics (e.g., mass of agent and other toxic chemicals; stored thermal, mechanical, and electrical energy; mass of reactive chemicals) · inherent safety of the process (e.g., limits on in- ventory, self-limiting characteristics of chemical reactions, etc.) · the need for and feasibility of systems and pro- cedures to prevent or mitigate accidents (e.g., 4The Army and the Centers for Disease Control have established maxi- mum allowable dose standards and human toxicity estimates for exposure to chemical warfare agents. These standards form the basis for protecting both workers and the public from exposure to chemical agent. The acute- exposure standards were recently reviewed by the NRC Committee on Toxi- cology, which recommended that the database supporting these standards be improved. In this report, the ACW Committee has not commented on the existing standards. Interested readers should consult NRC, 1997, for a complete discussion of the standards.
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30 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS potential for energetics to carry over from primary to secondary treatment that might require in- creased containment) · systems, equipment, and training to prevent worker exposure (e.g., in-plant monitoring for worker exposure, personal protective equipment, and well developed maintenance procedures) Public Safety An evaluation of public safety includes factors that characterize the effects of accidental releases. The pro- pensity for uncontrolled low-level releases during nor- mal operations and the latent health effects or gradual environmental damage caused by long-term exposure to these emissions are considered in the category of human health and the environment. The committee reviewed handling and processing operations throughout the projected range of facility operations, from the removal of munitions from stor- age to the completion of munition destruction and the packaging of all waste streams for transport. Public exposure from accidents during the transportation of hazardous materials (including transport to waste-dis- posal sites) is considered in the next subsection on transportation accidents. Specific components in the evaluation of public safety are: · the likelihood and magnitude of agent release and exposure during the disassembly process · the likelihood and magnitude of agent release and exposure during the agent and energetics destruc . lion process the likelihood and impact of releases and expo- sures associated with storage, process chemicals, and unique forms of energy Risks to the public and the environment from agent storage have been cited as a reason for prompt destruc- tion of the stockpile (NRC, 1994), and storage risks have been the focus of ongoing debates in communi- ties near the stockpile sites. The AltTech Report stated that reducing storage risk at individual sites, for the most part, is independent of the technology selected for stockpile destruction and that the critical factor af- fecting storage risk is the overall implementation/de- struction schedule. The shorter the schedule, the lower the risk. Thus, the key evaluation factor for storage risk is the likelihood of a technology meeting or beating the required schedule. The implementation/destruction schedules for the alternative technology packages, however, are currently too uncertain for meaningful evaluations of storage risk. Therefore, storage risk is not considered further in this report. Evaluating public safety during the destruction of the agent and energetics must also take into account the coexistence of energetics and agent and the possible presence of large amounts of stored energy. In addi- tion, the use of technology-specific forms of energy must be considered, as well as the formation of inter- mediate reaction products that may be highly chemi- cally reactive or unstable. Some of the proposed sys- tems require unique forms of energy (e.g., high-energy plasma) that must also be evaluated for their risk to public safety. Another factor considered in this evaluation is the risk of storage of hazardous or reactive chemicals required for the proposed technology. The risk in this instance does not involve exposure to agent or agent by-products but exposure to other hazardous chemicals. Transportation Accidents Technology-specific safety issues also may arise during the transportation required for each proposed technology. The issues or factors that have been evalu- ated include both worker and public exposure to acci- dental releases during the transport of assembled chemical weapons from storage to the disassembly area, hazardous chemicals transported to and on the processing site, and hazardous waste transported from the processing site to the disposal or post-processing site. The transport of weapons from storage to the dis- assembly area was essentially identical for all of the proposed systems (i.e., the Army's on-site container unit is used) and was not considered further in this study. The risk from transporting hazardous process mate- rials to, or hazardous waste from, the destruction facil- ity is proportional to several parameters. At this stage of the ACWA program, the only parameters that one can reasonably evaluate are (1) the particular toxic, fire, or explosive hazards presented by the material; (2) the quantity of material transported per shipment; and
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EVALUATION FACTORS (3) the number of shipments. Uncertainties at this stage of facility design make even these few parameters dif- ficult to evaluate (e.g., the concentration and/or physi- cal form of some materials). Therefore, the committee made several assumptions to establish a consistent basis for evaluating transpor- tation risks across sites, technologies, and materials. First, all shipments to and from the facility were as- sumed to be by tractor-trailer truck rather than by a combination of truck and train. The number of ship- ments will be determined from weight limits, volume limits, schedules, and other practical considerations. The second assumption was that the truck gross weight limit was 80,000 lb (36,300 kg), even though the limit is higher in some states. It was also assumed that the tractor weight was 15,000 lb, and the trailer weight, whether a flatbed, enclosed trailer, or tanker, was an- other 15,000 lb. The maximum material weight would then be 50,000 lb/shipment. The average amount across all materials was assumed to be 35,000 lb (15,900 kg) per shipment, which is slightly conservative (i.e., results in a higher number of shipments). The last assumption was that the consequences of a release of toxic, flam- mable, or explosive material would be roughly equal; thus, the transportation risk would be proportional to the number of shipments to and from the site. All shipments by railcar or heavy truck have the potential for public injury or fatality regardless of the cargo; however, only the shipments of process chemi- cals or process wastes are considered in this analysis. Using the approach described above, it was esti- mated that the number of incoming truck shipments per week would be 50 or less for any of the technology packages. Similarly, the number of outgoing truck ship- ments was estimated to be less than 60. Even these maximum values do not appear unusual for a large in- dustrial facility or a moderately busy highway. There- fore, the risk from the transportation of process materi- als to or from the site was not considered a significant criterion for the evaluation of the technology packages. HUMAN HEALTH AND THE ENVIRONMENT The human health and environment factor includes the impact of normal facility operations on the health of the public and the surrounding environment, includ- ing various ecosystems. All waste streams released 31 from the facility as part of the proposed process should be characterized and their imnactLs evaluated. The fol . . . ~ lowing suniactors are considered: characterization of effluents and their impact on human health and the environment · the completeness of effluent characterization · effluent-management strategy · resource requirements · regulatory environmental compliance end permitting Characterization of Effluents and Their Impact on Human Health and the Environment Treatment processes generally have effluent streams from certain parts of the overall process. These efflu- ent streams can be discharged into the air, water, or land. The committee considered not only the potential for agent release but also the potential for release of other hazardous constituents under normal (not acci- dent) conditions. Normal conditions include typical types of process upsets under steady-state and un- steady-state operations, such as start-up, shut down, and normal process variabilities in treating older chemical weapons components. In addition, all waste streams that must be subsequently treated and disposed of were considered effluent streams that could pose risks to human health and the environment. The level of risk associated with potential and actual effluents released into each medium (air, water, and land) is addressed separately. The goal is to gather enough information on the possible pathways of poten- tially harmful materials for comprehensive health and environmental risk assessments. For each discharge into each medium, the assessments should include the types, quantities, and duration of releases; the fate and transport of releases (particularly off-site); and the po- tential effects on humans, plants, and animals. Another consideration is whether appropriate and proven methods for characterizing normal releases can be incorporated into the treatment processes. This is particularly important for public acceptance of the tech- nology. Many citizens protested that process designs should include testing prior to the release of effluents (i.e., a hold-test-release sequence for all effluents). The committee considered whether existing monitoring techniques for detecting low levels of contamination
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32 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS within process effluents could be used. The process- specific contaminants of concern include those that could have long-term chronic effects. Ideally, the moni- toring methods will be validated by comparison with standard sampling and analysis methods. Completeness of Effluent Characterization The systems under consideration have not yet been applied to the specific task of demilitarizing assembled chemical weapons. All of the proposed technology packages would generate effluents that must eventu- ally be fully characterized in order to assess the overall impact to human health and the environment and to determine the best disposal process or control method for effluents. The committee's assessment of the human health and environmental impacts is based on completeness of characterizations of the potential effluents in bench- scale or pilot-scale operations. The committee took into consideration the methods used to characterize the ef- fluents. Determining the chronic effects to human health and the environment requires measuring very low levels of certain pollutants. Therefore, not only are mass balances on the major effluent streams important but also the completeness of the tests conducted to date on trace substances that might be of concern to human health or the environment. The effluent characterization should include normal transient conditions. Often, the greatest environmental impacts of treatment processes are incurred during start up and shut down when process controls are not always optimal. Effluent characterizations should include both species at high concentration that would be considered in normal mass balances and trace species of environ- mental concern. Effluent-Management Strategy All of the waste streams generated by the proposed systems must be managed in an environmentally ac- ceptable manner. Some systems would produce waste streams that are particularly difficult to manage. This evaluation factor addresses whether the proposed sys- tem has a well developed effluent waste management immature, management strategies may still have sig- nificant unknowns. The committee defined these un- knowns in its assessment of the requirements for mov- ing toward implementation. The committee paid particular attention to the mate- rials of potential health and environmental concern that might be left in the waste stream or created by the tech- nology. The residuals and materials that remain after treatment can have significant environmental impacts, as well as permitting challenges. For example, RCRA regulated hazardous wastes are subject to stringent per- mitting requirements for treatment, storage, and dis- posal. Thus, any RCRA-regulated material generated must be clearly identified. If the plan proposes off-site treatment or disposal, it is important to ensure that ex- isting facilities will accept the waste. If the plan calls for on-site waste management, it is important to evalu- ate current experience for treating the material. The committee evaluated special requirements for the dis- posal of waste streams that might be problematic. The committee also evaluated whether the waste could be separated into batches, which would allow for testing prior to release of the waste stream. Resource Requirements The resources required for a technology, such as energy, water, and land, can have a significant impact on the implementation of a technology at a specific site because some resources are limited at some sites. In addition, if excessive resources are required, the eco nomic viability of the process could be decreased. For this reason, it is important to assess the projected de mand for water (including quantity and quality); the requirements for energy, such as electricity and fuel; and the requirements for land, particularly for large equipment and storage areas. Environmental Compliance and Permitting The committee evaluated each technology to deter mine whether its inherent features might create prob lems with environmental compliance or permitting. Although a complete analysis of the required permits is well beyond the scope of this study, the committee tried plan that is compatible with applicable laws and reg- to identify potential problems. Two specific issues were ulations. Because these technologies are all rather examined:
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EVALUATION FACTORS . . the quantity and hazardous nature of the air emis- sions similar to those from other processes that have encountered permitting problems discharges that may be difficult to dispose of at existing waste disposal facilities (e.g., solid waste that might not be acceptable to a hazardous waste disposal facility) The RCRA permits (40 CFR §264, 266, 270) for all of the technology packages are likely to be issued under one of the following categories: 40 CFR§264 Subpart X,5 Miscellaneous Units or 40 CFRQ264 ~ . ~ . ~ Subpart J. lank Systems. In general, permitting for tank treatment (Subpart J) processes is much simpler than for Subpart X processes, and the permitting pe- riod for Subpart J processes has historically been much shorter than for Subpart X. Because the technologies evaluated in this study are relatively new, few precedents have been established for permitting. In all likelihood, some aspects of the processes) (e.g., the hydrolysis of agent or energetics) would be permitted under Subpart I; other parts (e.g., SCWO or thermal treatment units) would be permitted under Subpart X. The RCRA permitting process is generally adminis- tered (with minor exceptions) by the state. In addition to RCRA standards, most states also have unique re- quirements. Assessing the requirements of each state that may be impacted by one of these technology pack- ages is also beyond the scope of this study; however, the committee did consider the state-specific issues dis- cussed below. RCRA permits are usually comprehensive and in- clude conditions that restrict the ranges of operating conditions (e.g., temperature, pressure, flow rates), limit waste feed rates, require specific maintenance procedures, and require monitoring of specific param- eters. The permit conditions generally require that the system have an automatic interlock that shuts off the 5Subpart X is a general category that covers treatment systems that do not fit any given category. Quoting 40 CFR §264 Subpart X, "A miscella- neous unit must be located, designed, constructed, operated, maintained, and closed in a manner that will ensure protection of human health and the environment. Permits for miscellaneous units are to contain such terms and provisions as necessary to protect human health and the environment, in- cluding, but not limited to, as appropriate, design and operating require- ments, detection and monitoring requirements, and requirements for re- sponses to releases of hazardous waste or hazardous constituents from the unit. Permit terms and provisions shall include those requirements of other rules that are appropriate for the miscellaneous unit being permitted." 33 feed of hazardous material under certain specified ex- cursions from the acceptable operating conditions. The permit is highly site-specific and process-specific and is issued on the basis of a complex process of engineer- ing evaluations and testing. The EPA has issued guidance documents for com- mon waste-treatment units, such as incinerators, ce- ment kilns, and boilers. These peer-reviewed docu- ments are based on consensus opinions of many permit writers around the United States. Although the com ~, Settee reviewed these documents, the technologies considered in this study are new, and established docu- ments are not directly applicable. Because the environmental regulatory agencies of each state will have to accept the technologies, the com- mittee contacted representatives of state agencies where ACWA treatment facilities exist or are planned. Although regulators cannot pass judgment on any tech- nologies until they receive a specific application, the committee was able to identify initial general concerns through informal discussions with permit writers. The issues that arose during these discussions are described in Appendix H. The committee evaluated the technologies in the light of the above considerations. If no major stum- bling blocks were found, (e.g., if the agent treatment aspects of the process could be permitted as a Subpart J system and if the wastes produced appeared to be ame- nable for ultimate disposal at commercially available sites), the committee concluded that the process did not appear to have any unusual permitting issues. If, however, potential permitting issues were identified (e.g., the process required Subpart X permits for its agent treatment system, its air emissions were similar to some processes that have encountered permitting problems, or the process created a waste that was dif- ferent from typical hazardous waste), then these issues are discussed within the environmental compliance and permitting section of the technolo~v chanter. PUBLIC ACCEPTANCE a,, ~ This committee was asked to "gather data and ana- lyze information on stakeholder interests at the as- sembled chemical weapons storage site locations..." The committee gathered data from the following sources:
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34 ALTERNATIVE TECHNOLOGIES FOR DEMILITARIZATION OF ASSEMBLED CHEMICAL WEAPONS · attendance at public meetings in Richmond, Ken- tucky; Anniston, Alabama; and Pueblo, Colorado · private discussions with many of the residents and concerned citizens who attended the public meetings · attendance at meetings of the Dialogue held dur- ing the preparation of this report · private discussions with participants in the Dialogue · interviews with Keystone facilitators · discussions with state regulators in Colorado, Ken- tucky, and Utah · briefings by DOD officials and managers Analysis of the information proved to be a complex undertaking for a number of reasons. First, the com- mittee had to determine who was meant by "the pub- lic" and how "acceptance" of a chemical weapons destruction technology should be understood. Further- more, the committee found that very little systematic data were available with which to evaluate public ac- ceptance of the alternatives to incineration for chemi- cal weapons destruction. Because the collection of new data was beyond the scope of this study, the committee was unable to assess how the characteristics of the alternative technologies would be related to public acceptance. For these reasons, the discussion of public accep- tance in this report does not follow the technology-by- technology approach used to evaluate other factors (ef- ficacy, safety, and human health and environment). The analysis of public acceptance is presented for all tech- nologies in Chapter 10, which includes an overview of the processes by which public views of controversial policy options tend to be shaped and a discussion of how these views are likely to affect public acceptance of the alternative technologies. Second, the focus of the discussion is on public views of incineration, the only technology for the de- struction of chemical weapons that has received broad and sustained political attention. The discussion in- cludes implications of public attitudes toward incinera- tion for the chemical weapons destruction program. Third, the committee evaluated the prospects for the public acceptance of alternatives to incineration, espe- cially the innovative process for public involvement being used by the ACWA program. The discussion fo- cuses on the development and workings of the ACWA Dialogue Group, which has directly involved interest groups, regulators, and citizens in the process of iden- tifying and selecting alternative technologies. The com- mittee also attempted to identify the characteristics of the alternative technologies that are likely to influence public acceptance. Finally, the committee's findings are summarized and very general recommendations are offered for in- creasing public acceptance of alternative chemical weapons disposal technologies. CLOSING REMARKS The factors described in this chapter were used to evaluate the seven technology packages described in the next seven chapters. Three aspects of the evaluations that merit further explanation are mentioned below. First, all of the technology providers proposed using the baseline structures, support systems, and support equipment as much as possible. The committee consid- ers this a very positive indication. However, because significant experience has been gained with these sys- tems, the technology providers did not provide detailed descriptions of how the baseline systems would be used, and the committee did not consider them in its evaluations. Second, DOD required that the technology provid- ers design their systems to achieve the throughput rates shown in Table 2-1. The overall system availability was set at 38 percent, and a five-year operating period was specified. In some proposals, however, the providers chose to optimize their processing rates to handle mixes TABLE 2-1 ACWA REP Throughput Rates Prescribed in the Munition Processing Rate Processing Rate Agent (munitions/hr) (lb agent/hr) 105 mm projectile 155 155 155 4.2-in mortar 4.2-in mortar 8-in projectile M55 rocket M55 rocket M23 land mine HD HD VX H HD HI GB GB VX VX 100 100 80 80 50 50 20 20 20 30 300 1,170 600 1,170 300 290 280 214 200 315 Source: U.S. Army, 1997a.
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EVALUATION FACTORS of the munitions at actual storage sites. They also as- sumed higher system availabilities than those pre- scribed in the REP. Thus, the technology providers in- cluded mass balances for a variety of munition feeds in their proposals and other documentation. The commit- tee examined these mass balances to determine whether the providers had a solid understanding of their pro- cesses. The committee decided to include mass bal- ances in this report so that the reader could get a feel for the mass flows and materials involved in the full 35 scale processes. Although the assumptions and levels of detail in the mass balances vary, the committee did not attempt to standardize the information. Third, the committee was asked in the statement of task to evaluate each technology's "potential for imple- mentation." In response, the committee included the process maturity factor described earlier in this chap- ter. To address this issue more fully, the committee also included a section in each technology evaluation chapter entitled "Steps Required for Implementation."
Representative terms from entire chapter: