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OCR for page 23
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,
OCR for page 24
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.)
OCR for page 27
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
OCR for page 28
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
OCR for page 29
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.
OCR for page 35
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:
waste streams
