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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program 1 Introduction The U.S. Army is preparing to dispose of thousands of chemical agent identification sets (CAIS), test kits used from 1928 to 1969 to train solders in defensive actions in case they came under chemical attack. A typical CAIS set includes small glass vials (ampoules) or bottles containing various chemical warfare agents or hazardous industrial chemicals, which could be, or have been, used in chemical warfare. 1 Many of the CAIS to be destroyed are in storage on Army bases, but CAIS sets and individual CAIS items are also being recovered during cleanup operations at current or former military installations. 2 Some CAIS sets or items have also been discovered by the public on sites of former military installations. For reasons related to the history of international treaties and U.S. law concerning the disposal of chemical warfare agents and the munitions or components associated with their use, the totality of chemical warfare materiel under U.S. control falls into two categories. One category consists of a well-defined "stockpile" of chemical agents and related munitions and other materiel. The other category includes everything else. Thus, under the Any Program Manager for Chemical Demilitarization, which has overall responsibility for disposing of both categories of materiel, there is a Chemical Stockpile Disposal Program and a Non-Stockpile Chemical Materiel Program (NSCMP). CAIS are included in the non-stockpile category, so the NSCMP is responsible for their disposal. (For a more detailed description of the NSCMP, see Appendix C, as well as the introductory discussion later in this chapter.) Public Law 99-145, which defined the stockpile, also prohibits the use of stockpile disposal facilities for any other purpose, including the disposal of CAIS or other non-stockpile chemical warfare materiel. In 1997, Congress directed the Secretary of Defense to assess the policy and plans for disposing of CAIS and to report specifically on disposal alternatives and changes in policy that "could result in significant reductions in the cost of the non-stockpile program with no reduction in overall program safety." The task of preparing the assessment report was assigned to the NSCMP, and its report to Congress was delivered in August 1998 (U.S. Army, 1998a). 1 For the purposes of this report, "industrial chemicals" includes the wide range of chemicals used by industry for civilian (nonmilitary) purposes. In many cases, these chemicals are classified as "hazardous waste" by the Environmental Protection Agency (EPA) when they are disposed of. If industrial chemicals classified as "hazardous wastes" are accidentally spilled, the soil containing the chemicals may be considered a ''hazardous substance," as that term is defined in the Comprehensive Environmental Response Compensation and Liability Act (CERCLA, commonly known as Superfund). 2 To avoid confusion in this report, the term "CAIS set" refers to a complete kit, "CAIS item" refers to recovered individual bottles or ampoules, and "CAIS chemical" refers to the agent or industrial chemical contained therein.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program STATEMENT OF TASK AND CONGRESSIONAL DIRECTION In the fall of 1997, the Army requested that the National Research Council (NRC) review and evaluate the NSCMP. The NRC Governing Board approved the formation of the Committee on Review and Evaluation of the Army Non-Stockpile Chemical Materiel Disposal Program ("the committee"). During its first year, the committee's tasks were to become familiar with the program and evaluate the Army's report to Congress. During its second and third years, the committee's task will be .to recommend improvements in the overall plan for the NSCMP. The Governing Board approved the following Statement of Task on March 10, 1998, as the charge to the committee: The NRC will: Develop a comprehensive understanding and knowledge base concerning the destruction of non-stockpile chemical warfare materiel (CWM) and provide recommendations in two written reports. These reports will (1) evaluate a DoD assessment of its policy on disposal of chemical agent identification sets (CAIS); (2) suggest changes to the mid-term that may lead to significant improvements. The working knowledge to be achieved by the NRC will concentrate on the mission, philosophy, objectives, and methodology of the non-stockpile project, which includes: current baseline systems, transportation and storage issues, monitoring and standards, environmental laws and regulations, public outreach and community involvement, and applicable technologies. Specific NRC reporting requirements are to: Prepare a first report that evaluates the Department of Defense assessment of policy aspects controlling chemical demilitarization of chemical agent identification sets (CAIS). DoD will report to Congress by March 31, 1998, on its assessment and on coordination efforts with the NRC. The NRC will examine and comment on the DoD assessment in the form of an NRC report by February 28, 1999. Examine the non-stockpile project for the mid-term. This examination may address the following: assessment and access of munitions, monitoring and standards development, agent and explosive containment, treatment of neat agent, post-treatment processes (including waste disposal), and public stakeholder concerns. The Committee will issue an NRC report by January 31, 2000, which will make recommendations regarding the conduct of the project. Each report will address any NRC interactions with public stakeholders conducted to ascertain public acceptance of the disposal technologies under consideration. This report addresses the first of the two reporting requirements. After the Army's report to Congress was delivered in August 1998, the completion date for this evaluation was extended to October 1999. The committee has begun working on the second part of its task, which will culminate in a second report sometime in 2001. The Congressional Mandate The committee read the Army's report to Congress on CAIS disposal in light of the original congressional mandate to which the NSCMP was responding. The mandate was included in Conference Report 105-340 (dated October 23, 1997), which accompanied the National Defense Authorization Act for Fiscal Year 1998 (Public Law 105-85): The conferees understand that a major aspect of the chemical non-stockpile materiel project is the development of a system for disposal of the chemical agent identification kits, which have been classified as chemical weapons/agents for the purpose of the chemical disposal program, rather than hazardous waste. The conferees direct the Secretary of Defense to conduct an
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program assessment of its policy, which includes chemical agent identification kits in the chemical agent demilitarization program, the current plans for disposal, and the potential changes in policy and disposal alternatives that could result in significant reductions in the cost of the non-stockpile program with no reduction in overall program safety. The assessment shall be conducted in coordination with the National Research Council. The results of the assessment and the Secretary's decision should be provided to the congressional defense committees by March 31, 1998. Initial Interpretation and Evolution of the Task The committee interpreted the congressional direction as stipulating two constraints to the scope of its first-year reporting task. First, the committee's report should be an evaluation of the Army's report, not a separate exploration of a broad range of technical possibilities unrelated to what Congress specifically requested from the Secretary of Defense. Second, the disposal options considered should be consistent with the congressional interest in "potential changes in policy and disposal alternatives that could result in significant reductions in the cost of the non-stockpile program with no reduction in overall program safety." As explained in Chapter 4, the Army's report to Congress focused on the use of commercial disposal facilities for CAIS disposal as the option that could most significantly reduce cost without reducing overall safety. Therefore, a major focus of this report is the Army's proposed plan for using commercial facilities to dispose of CAIS. The Army's "current plans for disposal" at the time of the congressional request depended primarily on the Rapid Recovery System (RRS), a transportable processing facility that neutralizes CAIS chemicals in a small chemical reactor. Thus, the RRS, as the "baseline" system for CAIS disposal against which commercial disposal was evaluated, is another focus of this report. When the committee began to investigate the commercial option for CAIS disposal, it learned that commercial facilities with the appropriate permits and technology would probably use incineration to dispose of CAIS. In exploratory interviews by committee staff with some of the commercial firms surveyed by the Army, the firms said that because of the reliability of incineration and "simple economics," they would use incineration for the disposal of CAIS, even if nonincineration-based disposal technologies were available. The Army's report to Congress did not specify the disposal technologies that would be used by a commercial facility to dispose of CAIS. Given the long history of public reaction to the incineration-based disposal of the stockpile materiel (see Public/Stakeholder Involvement in Chapter 3), the committee decided that the issue of whether commercial disposal would involve incineration or nonincineration technologies could significantly affect the feasibility of a commercial disposal alternative to the RRS. Representative nonincineration technologies that are, or reasonably could be, employed by a commercial treatment, storage, and disposal facility (TSDF) were therefore included in this report. Finally, a potentially low-cost option that may satisfy stringent technical criteria is the use of nonincineration facilities designed for the disposal of stockpile materiel. However, this option raises significant issues of federal law, Army policy, and commitments made by both Congress and the Army to affected stakeholders. Two deployment options for the RRS are evaluated in this report: the baseline approach, in which the RRS is transported to each site where CAIS are stored or found, and a fixed RRS mode, in which RRSs are located at one or more sites, to which CAIS from other sites are transported. In addition to the RRS, which is an Army facility dedicated to CAIS disposal, a technologically feasible alternative would be an Army facility designed for disposal of non-stockpile materiel in general, including CAIS. The committee did not evaluate that option for this report because it goes beyond the
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program congressional mandate to address CAIS disposal. The general disposal of non-stockpile materiel will be the subject of the second and third reports from the committee Report Structure Chapter 1 contains introductory information on chemical warfare materiel in general and CAIS in particular. This background information is important for understanding the Army's report to Congress and the committee's evaluation of that report. The CAIS disposal alternatives that the committee considered, in addition to the Army's commercial disposal option, are presented in Chapter 2. The evaluation methodology the committee applied to the disposal alternatives is discussed in Chapter 3. In Chapter 4, commercial disposal, as described in the Army's report to Congress, is evaluated according to this methodology. In Chapter 5, the other disposal alternatives selected by the committee are evaluated. Chapter 6 contains the conclusions and recommendations the committee drew from its analyses and evaluations. The laws and regulations that control CAIS disposal alternatives are explained in Appendix D. CHEMICAL AGENTS AND CAIS Chemical weapons were first used on the battlefield during World War I, when the Germans released chlorine gas in 1915. Chlorine and other choking agents, such as phosgene, burned the lungs and caused panic among soldiers who were unprepared for them. As gas masks became more effective against inhaled poisonous gases and were more widely deployed on the battlefield, blister agents such as mustard were employed (e.g., at Ypres, Belgium, in 1917). (Nerve agents, such as GB and VX, and blister agents are the principal constituents of chemical weapons that still exist around the world.) Types of Agents Found in CAIS In general, chemicals that have been used for military purposes to incapacitate opposing personnel (chemical warfare agents) can be classified as nerve, blister, vomiting, choking, or riot control agents. CAIS were manufactured with samples of various types of these chemicals, but not all chemical warfare agents in the U.S. inventory were included in CAIS. Table 1-1 lists the names and formulas of chemical warfare agents and agent-simulants that were included in one or more types of CAIS. Table 1-2 contains information on the physical properties and toxicity for these CAIS chemicals. This section briefly describes the broad categories of chemical warfare agents but focuses on the agents in CAIS. GB is the only nerve agent that was ever included in CAIS. Like other nerve agents (e.g., VX, tabun, and soman), GB functions by inhibiting acetylcholinesterase, which causes an accumulation of the neurotransmitter acetylcholine at nerve endings. The nerve fibers are overstimulated, causing uncontrolled and disorganized of the functioning organs. Typical effects of this phenomenon include excessive secretions of saliva and tears, muscle twitches, jerky random movements, disorientation, and convulsions. Severe exposures can lead to coma and death from respiratory paralysis. Very low levels of GB are toxic, and fatal quantities can readily be absorbed through the skin or respiratory tract.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-1 Chemical Names and Formulas of CAIS Chemicals Symbol Common Name Chemical Name Formula CG phosgene carbonyl chloride COCl2 CG-sim triphosgene (phosgene simulant) hexachloromethylcarbonate (OCCl3)2CO CK cyanogen chloride Chlorine cyanide CNCl CN chloroacetophenone Phenyl chloromethyl ketone C6H5COCH2Cl DM adamsite Diphenylamine chloroarsine C6H4(AsCl)(NH)C6H4 GA-sim ethyl malonate Diethyl malonate CH2(COOC2H5)2 GB sarin Isopropyl methyl phosphonofluoridate (CH3)2CHO(CH3)PFO H sulfur mustard HD plus impurities HD plus impurities HD sulfur mustard distilled 2,2'-dichlorodiethyl sulfide S(CH2CH2Cl)2 HS sulfur mustard in solvent H or HD with 15% diluent H/HD with 15% CCl4 HN nitrogen mustard See HN1 or HN3 See HN1 or HN3 HN1 nitrogen mustard 2,2'-dichlorotriethylamine N(CH2CH2Cl)2(C2H5) HN3 nitrogen mustard 2,2',2"-trichloroethylamine N(CH2CH2Cl)3 L (or M-l) lewisite 2-chlorovinyldichloroarsine ClCH:CH-AsCl2 PS chloropicrin nitrotrichloromethane CCl3NO2 Sulfur mustard (e.g., HD) and lewisite are blister agents, or vesicants. 3 Blistering compounds are readily absorbed through skin in liquid or vapor form and are distributed systemically. Like GB, low levels of HD are highly toxic, and lethal quantities can readily be absorbed through the skin. The acute lethal dermal dose of HD is slightly lower than that of GB; the acute lethal inhaled dose is somewhat higher than that of GB. Lewisite an arsenic-containing blister agent, is considerably less lethal than the sulfur mustard compounds, although its blistering action is equivalent to that of HD. Both HD and lewisite are carcinogenic. Adamsite is a vomiting agent. Exposure causes pain in the nose and throat, severe headache, and violent, uncontrollable sneezing, coughing, nausea, and vomiting. The effects are delayed by several minutes and can last up to two hours. Phosgene and chloropicrin are generally classified as choking or lung-damaging agents because of their severe irritant action in the lungs. At sufficiently high concentrations, they can cause pulmonary edema (buildup of fluid in the lungs), which is usually delayed but can be fatal. Other choking agents include chlorine and diphosgene. The immediate effects of exposure to phosgene include mild irritation of the eyes and lungs, but these early symptoms can be misleading because severe, life-threatening pulmonary edema can occur hours later. 3 Although nitrogen mustard (HN) is also a powerful blistering agent, its propensity to inhibit cell division has made it useful for the treatment of cancer, and it is therefore not classified as a chemical warfare agent. Lewisite was developed in 1918 by W. Lee Lewis while Lewis was working at the chemical laboratory at the Catholic University of America in Washington, D.C. Limited quantities were produced during World War I, but lewisite was not used on the battlefield.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-2 Characteristics and Biological Effects of CAIS Chemicals Agent Appearance Odor Effect on Body Rate of Action Adamsite (DM) Yellow to green solid None in pure form Vapor causes severe pepper-like irritation of the nose, throat, and eyes; tearing; severe headache; acute pain and tightness in the chest; and violent, uncontrollable sneezing, coughing, nausea, and vomiting. Several minutes Chloroacetophenone (CN) (tear gas) Colorless to gray solid Apple blossoms Vapor causes headache, irritation, burning, and pain of the nose and throat and copious tearing. Dermal exposure causes transient burning, itching, and blisters on tender areas of the skin. Minimal irritant concentration is 0.3 mg/m3; a concentration of 350 mg/m3 may be life threatening. Immediate Chloropicrin(PS) Colorless, oily liquid Stinging and pungent Vapor causes severe skin, eye, nose, and throat irritation with tearing, coughing, nausea, and vomiting. Pulmonary edema may develop hours after exposure to high concentrations. Contact with liquid causes severe skin bums and blisters. Immediate Cyanogen chloride (CK) Colorless liquid (evaporates quickly) Pungent biting odor Vapor causes intense irritation of the eyes, nose, and throat, with coughing, tightness in the chest, tearing, difficulty breathing, and possible pulmonary edema. Effects of moderate exposure include dizziness, vomiting, and incontinence. Severe exposures cause convulsions and coma. Contact with liquid bums the skin and eyes. Immediate GA simulant(diethyl malonate) Colorless liquid Sweet ester odor Vapors irritate the respiratory tract. Ingestion causes sore throat, abdominal pain, diarrhea, eye and skin irritation with redness and pain Lewisite (L) Colorless to amber liquid Geraniums Vapor causes severe, painful eye and skin irritation immediately after exposure, followed hours later by blistering. Inhalation causes severe irritation of the respiratory tract with burning sensation, coughing, and sneezing; pulmonary edema may develop hours after exposure. Immediate
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Agent Appearance Odor Effect on Body Rate of Action Nitrogen mustard (HN) Oily, colorless to pale yellow liquid Fishy or musty odor Low vapor concentrations can cause eye irritation within 20 minutes of exposure in the absence of other effects. Higher vapor concentrations or exposure to liquid causes itching and reddening of the skin followed by blistering. Inhalation irritates the respiratory tract causing hoarseness, loss of voice, and persistent coughing. A fatal bronchopneumonia may develop after 24 hours. Ingestion causes nausea and vomiting, bloody diarrhea, intestinal lesions, and may depress normal formation of blood cells. Within 20 minutes Phosgene (CG) Colorless gas New-mown hay Immediate responses to concentrations as low as 2-5 ppm include tearing, burning of the nose and upper respiratory tract, coughing, vomiting, chest tightness, and difficulty breathing; 50 ppm may be rapidly fatal. Immediate Sarin (GB) Colorless liquid None in pure form Exposure can cause runny nose, excessive salivation and tearing, miosis (constricted pupils), dim vision, eye pain, tightness in the chest, difficulty breathing, and muscle twitches. Higher concentrations cause nausea, vomiting, abdominal cramps, incontinence, convulsions, coma, respiratory failure, and death. Minutes for vapor exposure; 2 hours for dermal exposure Sulfur mustard(HD) Colorless to pale yellow liquid Garlic Early symptoms include severe irritation of the eyes, skin, and respiratory tract; vomiting, fever, and redness of the skin (erythema); severe blistering and ulceration of exposed areas may develop 4-24 hours later. Lethal quantities may be absorbed through the skin or lungs. Usually 4 to 6 hours, but may be 24 hours depending on concentration Triphosgene(phosgene simulant) White to off-white crystals Exposure to vapor can cause irritation of eyes, respiratory tract, and skin. Fatal pulmonary inflammation and edema may develop hours later. Within 10 minutes to 2 hours, depending on concentration Sources: Proctor and Hughes, 1978; NATO, 1995; U.S. Army, 1995a.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program BOX 1-1 Use of CAIS CAIS were originally intended for training combat troops in the identification of the smell and effects of chemical agents. Soldiers were intentionally exposed to the chemicals in the CAIS to enable them to recognize the odor and effects of chemical agents and to train them to take immediate defensive action. According to a training manual, "every soldier should become proficient in identification of gases through odor and other sensory reactions, since other means may not be available" (War Department, 1944). The recommended method of training was to detonate the glass vials with blasting caps to atomize the chemicals and form a small aerosol "cloud." The trainees were positioned downwind prior to the detonation and were instructed to allow the cloud to envelop them (or walk into the cloud if the wind had blown it away from them), "take a sniff, just enough to recognize the odor," and "to walk out of the cloud to the flank and exhale." According to the manual, "Normally, four gases are detonated in succession, with an interval between gases. For effective instruction the name of the gas should not be announced before it is fired." The trainees were graded on their ability to identify the four gases in order. "Men who fail to identify the gases should go through the exercise again. It should be made clear to them that this is an opportunity, not a penalty, for their lives may later depend on their individual judgement." <Silver> It is difficult to estimate the number of trainees who were exposed to this training. A conservative estimate can be made by multiplying the number of CAIS believed to have been used during training (assume 80,000 of the approximately 90,000 not destroyed at Rocky Mountain Arsenal) by the number of vials in each CAIS (24-48) for a total of 1,920,000 to 3,840,000 vials. If two vials of the four agents were used in each training exercise (a total of eight vials per session), as described in the training manual, between 120,000 and 240,000 sessions (exposure of a class of trainees to all four chemicals) were conducted. Conservatively assuming that each training class consisted of only five trainees, the estimated total number of trainees exposed to CAIS chemicals is 600,000 to 1,200,000. 1War Department. 1944. Use of Chemical Agents and Munitions in Training. T.M. 3-305. Washington, D.C. Chloroacetophenone, commonly known as tear gas, is classified as a riot control agent. These agents are typically characterized by low toxicity and rapid onset of effects, which are transient and of short duration. Exposure to chloroacetophenone causes immediate, but transient, burning, pain, and tearing of the eye and severe irritation of the respiratory tract. In recent years, chloroacetophenone has largely been replaced by less toxic compounds. Chemical Agent Identification Sets CAIS sets and CAIS items are the most commonly recovered kinds of buried non-stockpile materiel. Between 1928 and 1969, the Army used several types of CAIS to train soldiers and sailors to identify chemical warfare agents, typically by using "sniff sets" during classroom training (Box 1-1). In some instances, CAIS chemicals were vaporized in a controlled detonation; trainees then walked into the vapor cloud, sniffed the gas, and identified the agent based on odor (War Department, 1944).
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program FIGURE 1-1 Army photographs of four CAIS types: (a) a toxic gas set, containing bottles of sulfur mustard for use in decontamination training exercises; (b) war gas identification set containing ampoules of neat or dissolved agents and simulants for use in outdoor training; (c) an instructional "sniff set" with agent-impregnated charcoal for use in classroom-based indoor training for agent identification; and (d) the Navy "sniff set" for classroom-based identification training. Sources: U.S. Army, 1993, p. 5-7; U.S. Army, 1995a, p. 5-10 and Appendix E. CAIS were produced in large quantities, were widely distributed, and came in more than a dozen different types, grouped into three major varieties (see Figure 1-1 and Table 1-3). Toxic gas sets (sets containing two dozen or more glass bottles, each with about 100 ml of neat agent) were used for training in decontamination. War gas identification sets (small ampoules of neat agent or simulant, or agent in a solvent) were used for outdoor training. The sniff sets (agent or simulant on charcoal) were used for indoor classroom training. CAIS of the same major variety have similar markings and packaging. As manufactured, they generally contained a few dozen glass ampoules or bottles of chemical agent or simulant packed in metal shipping containers or wooden boxes. The chemicals were either neat, in 5 percent solutions in chloroform, or adsorbed on granular activated charcoal. In the CAIS types that are still known to exist, the only contents classified as chemical warfare agents are HD and lewisite (Fatz, 1997). (As explained in footnote a to Table 1-3, all the CAIS that contained GB were reported to have been destroyed.) The
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-3 CAIS Types and Componentsa Type and Use Number and Type of Container Chemical Agents Agent per Container (milliliters) Agent per Set (liters) K941 (toxic gas set, M 1 ).b Used from WWII to the late 1950s for training in decontamination of vehicles or equipment while in protective clothing. 24 4-ounce round glass bottles neat H, HS, or HD 103.3 2.48 K942 (toxic gas set, M2).c Used during the Korean War period for training in decontamination. 28 glass heat-sealed ampoules neat H, HS, or HD 112.5 3.15 K951/K952 (war gas identification set, M1).d Used from the early 1930s to late 1950s for identification of agents using detector kits. 48 Pyrex heat-sealed ampoules 12 ampoules of H in 38 ml of chloroform 2 0.024 H; 12 ampoules of L in 38 ml chloroform 2 0.024 L; 12 ampoules of PS in 20 ml chloroform 20 0.24 PS; 12 ampoules of neat CG 40 0.48 CG K953/K954 (war gas identification set, MLIE.e Used during the Korean War period for identification of agents using detector kits. 48 ampoules 8 ampoules of H in 38 ml chloroform 2 0.016 8 ampoules of HN in 36 ml chloroform 4 0.032 8 ampoules of L in 38 ml chloroform 2 0.016 8 ampoules of neat CG 40 0.32 8 ampoules of neat CK 40 0.32 8 ampoules of neat SUm 40 0.32 K955 (Navy/sniff set, M1)f Used from the late 1930s to World War II for classroom-based training in identification by odor. 7 4-ounce round glass bottles 2 bottles of HS on 90 cc charcoal 25 0.05 1 bottle of L (or M-l) on 90 cc charcoal 25 0.025 1 bottle of PS on 90 cc charcoal 25 0.025
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Type and Use Number and Type of Container Chemical Agents Agent per Container (milliliters) Agent per Set (liters) 1 bottle of neat SUm 6 grams 6 grams 1 bottle of neat CN 15 grams 15 grams 1 bottle of neat DM 15 grams 15 grams a Approximately 2,000 K945 (Chemical Agent Identification and Training Set [CAITS], M72 [Nerve Agent Sets]) were also produced and used until the late 1960s, but all are believed to have been destroyed. These sets consisted of eight agent bottles (four bottles of 3 ml GB nerve agent, one bottle of 3 ml of lewisite, one bottle of 1 ml of H, all on plastic pellets; and one bottle each of 5 grams of trichogynes and potassium cyanide). The bottles were contained in a plastic ''tackle box" housed in a small wooden box. The M72A1 is a similar looking nerve-simulant set b Commonly called "bulk mustard set" Sets of four bottles (labeled with heat-resistant paint) were packed with sawdust in a pressure-sealed, metal, 6.5" high can with a sardine-type key on the bottom. Six of these labeled cans were placed in a 38" long steel shipping cylinder (a PIG) with a bolted, flanged end cover. This type of CASE is found either as complete PIGs or as loose bottles. When found loose, the plastic/bakelite screw-top bottle tops tend to leak because mustard is a good solvent for plastic and rubber. (However, mustard forms a scale or sludge in contact with soil or sawdust and solidifies at cool temperatures.) c Commonly called "bulk mustard set." Each 1 7/8" diameter by 4 5/8" long ampoule was packed in its own sealed metal can, surrounded by corrugated fiberboard lining and foam rubber to prevent breakage. The 28 gray cans (with green stenciled markings) were placed in steel bolted, flanged steel drums. d Each 1" diameter by 7 1/2" long ampoule was packed in a screw top labeled cardboard tube. Twelve tubes were packaged into press fit metal cans, with four cans per 38" long steel PIG with a bolted, flanged end cover. The K951 was issued with blasting caps that were packed and shipped in a separate container. e Twelve ampoules were packed per can; four cans per PIG. The K953/K954 were the later versions of the K951/K952 War Gas Identification Sets, incorporating nitrogen mustard, cyanogen chloride, and ethyl marinate (GA nerve agent simulant). f Bottles had etched labels. Each bottle had either a screw top or stopper, which was usually wax coated. Individual bottles were housed in 4" diameter by 7" high metal cans with a paint-can type lid. The complete K955 set was packed in a hinged, wooden footlocker type box, but K955 bottles have frequently been found loose at burial sites. The Navy Replacement Sets (X302, X545-X552 series) were also produced and used by the Navy to replace components of the K955. These sets contained the same types and amounts of agent as the K955 but included the nitrogen mustard. Source: U.S. Army, 1995a; Branchlets, 1998; and Chemical Warfare School training materials provided by committee member James Pastoring. other chemicals found in existing CASE (e.g., phosgene and chloropicrin) are classified by the Army as hazardous industrial chemicals. CASE do not contain explosives or other energetics, such as the bursters, fuses, and propellants found in assembled chemical weapons. Recovered CASE Approximately 110,000 CAIS were produced between 1928 and 1969. In 1969 the use of CASE was discontinued.4 All unused CASE in Army stocks at that time, including all CASE containing the nerve agent GB, were sent to Rocky Mountain Arsenal, where 21,458 of them were destroyed by incineration between 1979 and 1982 BRanchlets et al., 1983; U.S. Army, 1998a). Most of the 90,000 CASE not destroyed in this way are thought to have been used during training, with some or all of their chemicals expended. The exact 4 Training with live agent was not conducted after the late 1960s, when the military began using simulates for training. For example, when one committee member went through training, antifreeze was used to simulate agents, such as VX, not for agent (smell) identification but rather to set off portable agent monitoring alarms. The alarm kits (and other newer and more sophisticated tests) can be easily fooled by some common substances, which give false positive indications for agent. These substances are used as simulates during training in the use of the alarm kits and in field operations in agent-contaminated environments. Reportedly, chlorine chambers are still used for training in the use of gas masks.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program numbers of used and buried CASE are not known because no detailed records were maintained. An unknown number of CASE were disposed of by burial, either as sets in their wooden or metal containers (package in-transit gas shipment, or PIG, containers) or as loose CASE items (ampoules or bottles). Some CASE chemicals were disposed of as the process effluents from simple neutralization or burning. 5 These disposal procedures, including burial of CASE sets or items, were standard and approved at the time. Today, CASE sets and items are being found at former World War II and Korean War training sites located at active or former military installations. Environmental restoration programs at former military installations are recovering additional CASE. The identification of the chemical content of individual CASE items may require sophisticated characterization equipment. PIG containers and other packaging, even if intact, are no longer considered safe for transporting CASE materials off the site where they are found. Therefore, either the entire CASE must be enclosed in a permitted container or the individual items must be removed by properly trained and protected personnel and transferred to authorized laboratory-type overpass for transport. After arrival at a disposal facility, entire sets would have to be removed from the transport overpassing. The original set containers, if intact, would presumably be opened before disposal. Individual items in laboratory overpass, if characterized prior to transport, might be incinerate without unpacking. Disposal by a nonconservation process would probably require opening and emptying the CASE items to ensure efficient destruction. Approximately 10,000 CASE items and 1,400 non-stockpile chemical munitions are currently in storage awaiting destruction (Table 1-4). The Army's report to Congress (U.S. Army, 1998a, Appendix D) listed 33 sites where CASE items are, or may be, buried (Table 1-5). At the time of that report, near-term (fiscal year 1998-1999) CASE recovery efforts were anticipated at Gentle River Expansion Area, Alaska; Fort McClellan, Alabama; the former Santa Rosa Airfield, California; England Air Force Base, Louisiana; the former Plaistering Air Force Base, New York; the former Defense Depot, Memphis, Tennessee; and Ogden Depot, Utah.6 The Army is developing the RS to (1) access CASE items (i.e., open the CAIS packaging and then open the items containing the chemicals), (2) repackage the contents classified as industrial chemicals, and (3) chemically neutralize any chemical contents classified as chemical warfare agents (sulfur mustard or lewisite). Under current plans (fiscal year 1999), the waste products from RRS operations and the repackaged industrial chemicals will then be treated and disposed of at a commercial TSDF operation under a Resource Conservation and Recovery Act (RCRA) permit. PROGRAMS FOR DISPOSING OF CAIS AND OTHER CHEMICAL WARFARE MATERIEL Because of the large numbers of casualties from chemical weapons in World War I, the international community agreed to ban their use as part of the Geneva Protocol of 1925. Since then, however, chemical weapons have been used in war a number of times, by Japan (in China), by Italy (in Ethiopia), and by Iraq (against Iranian and Iraqi Kurdish citizens) 5 In the context of this report, "neutralization" refers to a chemical reaction (hydrolysis) in which agent is converted into reaction products less toxic than the starting chemical. 6 There is an apparent discrepancy between this list of anticipated CAIS recovery sites and Table 1-5, which classifies the former defense depot at Ogden, Utah, as a site for "no further action." Both the list and the table are from the report to Congress (U.S. Army, 1998a).
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-4 Recovered CAIS Currently in Storage Location Quantity and Type Pine Bluff Arsenal, Arkansas 4,408 bottles, 891 mixed vials and bottles Deseret Chemical Depot, Utah 575 bottles, 578 vials Johnston Atoll Chemical Agent Disposal System, Johnston Atoll 59 PIGs Camp Bullis, Texas 25 K955 bottles Fort Richardson, Alaska 7 K941 PIGs Redstone Arsenal, Alabama 1 K941 PIG, 1 K941 bottle Source: Brankowitz, 1998. (e.g., IOM, 1993). A religious cult in Japan has been accused of releasing the nerve agent GB in a Tokyo subway in 1995. The recent Iraqi attacks spurred another attempt to abolish chemical weapons, the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction (commonly called the "Chemical Weapons Convention," or CWC). This treaty, together with a congressional mandate in 1986, has shifted attention in this country to the best way to destroy the inventory of chemical weapons in both the stockpile and non-stockpile categories. 7 Chemical Stockpile Disposal Program In November 1985, the U.S. Congress passed Public Law 99-145 requiring the destruction of all U.S. unitary chemical agents and munitions located at eight continental U.S. storage sites and on Johnston Island in the Pacific Ocean.8 The materiel at these specific storage sites at the time the law was passed was defined as the chemical stockpile. In response, the Army, as the executive agent, established the Chemical Stockpile Disposal Program. The stockpile's unitary chemical agents, which are highly toxic or lethal, are stored either in bulk containers or in chemical munitions. The Army has already begun disposal operations at one continental storage site, the Tooele Chemical Agent Disposal Facility (TOCDF) in Utah, and at the Johnston Atoll Chemical Agent Disposal System (JACADS) on Johnston Island in the Pacific. The current status of these disposal operations is shown in Table 1-6. Another NRC committee, the Committee for the Review 7 in addition to the Chemical Stockpile Disposal Program and the NSCMP, the Army has an Alternative Technology and Approaches (ATA) Program and an Assembled Chemical Weapons Assessment (ACWA) Program, which are investigating nonincineration-based technologies for the disposal of chemical materiel. The Army's Cooperative Threat Reduction Program helps foreign countries destroy their chemical weapons. The Chemical Stockpile Emergency Preparedness Program assists affected communities with emergency planning during disposal operations. Additional information on the Army's chemical materiel disposal programs is available on the Internet at <http://www-pmcd.apgea.army.mil/text/w_body.html>. 8 The term "unitary" refers to a single chemical loaded in munitions or stored as a lethal material (NRC, 1996a, p. 6). A "binary" chemical weapon is "one that forms a lethal chemical agent from nonlethal constituents through a chemical reaction occurring during the time of flight to the target" (U.S. Army, 1996; p. 3-1).
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-5 Potential CAIS Burial Sites, as Reported to Congress by the Army State Location Site Classificationa Alabama Redstone Arsenal 3, 4 Alaska Unalaska Island (now closed) 3 Gerstle River Test Site 2 Arizona Yuma Proving Ground 1 Arkansas Fort Chaffee 3 California Fort Ord 4, 5 Santa Rosa Army Airfield (now closed) 1 Georgia Fort Benning 2 Hawaii Schoefield Barracks 4 Indiana Camp Atterbury 4 Naval Surface Warfare Center, Crane Division 3 Iowa Camp Dodge (now closed) 3 Louisiana Camp Claiborne (now closed) 3 England Air Force Base 2 Fort Polk 3, 5 Maryland Fort Meade 3 Massachusetts Fort Devens (now closed) 1 Mississippi Camp Van Dorn (now closed) 4 Missouri Camp Crowder (now closed) 4 New York Camp Hero (now closed) 4 Plattsburg Air Force Base 1 North Carolina Camp LeJeune Marine Corps Base 3 South Dakota Ellsworth Air Force Base 3 Tennessee Defense Depot Memphis 4 Texas Camp Bullis 1 Utah Defense Depot Ogden 4, 5 a 1 = known burial; 2 = likely burial; 3 = suspected burial; 4 = possible burial; 5 = no further action. Several other sites have been evaluated by the Army and classified as "no further action" required: Fort Wainwright, Alaska; Barksdale Air Force Base, Louisiana; Mitchell Field, New York (now closed); Defense Distribution Region East, Pennsylvania; Camp Barkeley, Texas (now closed); Fort Belvoir, Virginia; F.E. Warren Air Force Base, Wyoming. Camps and forts = Army bases. Source: Adapted from U.S. Army, 1998a, Table D-1.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 1-6 Status of Agent Destruction at JACADS and TOCDF, as of April 25, 1999. JACADSa TOCDFb Total Stockpilec Original tonnage 2,030 tons 13,616 tons 31,495 tons Remaining tonnage 385 tons 10,939 tons 21,173 tons Destroyed to date 1,645 tons (81.0%) 2,677 tons (19.7%) 4,322 tons (13.7%) a Munitions and bulk containers destroyed: 13,020 GB nerve agent-filled projectiles (8 inch); 49,360 GB nerve agent-filled projectiles (105mm); 107,197 GB nerve agent-filled projectiles (155-mm); 2,570 MK-94 (500 pound) bombs filled with GB nerve agent; 3,047 MC-1 (750 pound) bombs filled with GB nerve agent; 72,242 M-55 GB and VX nerve agent-filled rockets/warheads; 45,108 blister agent-filled projectiles (105mm); 68 blister agent-filled ton containers; 66 GB nerve agent-filled ton containers; 45,108 blister agent-filled projectiles (105 mm); 43,660 blister agent-filled mortars (4.2-inch). b Munitions and bulk containers destroyed: 4,463 MC-1 (750 pound) bombs filled with GB nerve agent; 2,636 GB nerve agent-filled ton containers; 19,860 M-55 GB nerve agent-filled rockets; 116,045 GB nerve agent-filled projectiles (105 ram) c Includes chemical warfare materiel at other stockpile sites (e.g., Aberdeen, Maryland; Newport, Indiana) Source: U.S. Army, 1999. and Evaluation of the Army Chemical Stockpile Disposal Program, has reported on and provided scientific and technical recommendations for various aspects of this program for more than 10 years (see, for example, NRC, 1994a, 1999a). Non-Stockpile Chemical Materiel Program Prior to 1991, the Army program for the disposal of chemical warfare agents was limited to the unitary chemical agents and munitions defined by statute as the "stockpile." The 1991 Defense Appropriations Act directed the Secretary of Defense to establish an office with the responsibility of destroying non-stockpile chemical materiel. The Project Manager for Non-Stockpile Chemical Materiel was assigned this task under the newly established U.S. Army Chemical Materiel Destruction Agency. In the 1993 Defense Appropriations Act (Section 176 of Public Law 102-484), the Army was directed to report the locations, types, and quantities of non-stockpile chemical materiel; explain the methods to be used for its destruction; provide cost and time estimates; and assess transportation options. The Survey and Analysis Report provided an overview of the task facing the Army (U.S. Army, 1993, 1996). According to this report, non-stockpile chemical warfare materiel is located at more than 200 sites in the United States and in U.S. territories. At most sites, the materiel contains small quantities of chemical agent and does not appear to pose immediate hazards to the public or the environment. However, chemical weapons agreements and the continuing discovery of buried chemical warfare materiel have increased the impetus for locating and disposing of all non-stockpile chemical materiel. The purpose of the NSCMP is to provide centralized management and direction for the destruction of non-stockpile chemical materiel, develop characterization and disposal facilities, develop schedule and cost estimates, and ensure compliance with federal, state, and local regulations. The NSCMP is responsible for the disposal or destruction of five types of chemical warfare materiel, each of which presents unique disposal problems: (1) buried chemical warfare materiel; (2) recovered chemical warfare materiel; (3) binary weapons; (4) former production facilities; and (5) miscellaneous chemical warfare materiel. Although CAIS are only relevant to the first two categories, all five are briefly
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program described below to place the problem of CAIS disposal in the larger context of disposing of all types of non-stockpile materiel. Buried Chemical Warfare Materiel As of 1996, based on initial surveys, site visits, and interviews, the Army had located 168 potential burial sites at 63 locations in 31 states, the U.S. Virgin Islands, and the District of Columbia (U.S. Army, 1996). Of the 63 locations in the continental United States, most are current or former defense sites. In the interim version of the Survey and Analysis Report (dated April 1993), 224 potential burial sites were identified at 96 locations in 38 states (U.S. Army, 1993). A number of these sites have since been evaluated and characterized as requiring no further action. Types of burial sites include (1) sites with CAIS only; (2) sites with small quantities of materiel (possibly including CAIS) with no associated explosives; (3) sites with small quantities of materiel with explosives; and (4) sites with large quantities of materiel with and without explosives. The majority of the sites have small quantities of materiel that may be treatable by transportable (mobile) disposal facilities. The treatment of explosively configured chemical warfare materiel will involve more hazardous operations. Larger quantities of materiel will probably be treated in fixed facilities. Large-quantity sites are located at four military installations: Aberdeen Proving Ground, Maryland; Deseret Chemical Depot, Utah; Rocky Mountain Arsenal, Colorado; and Redstone Arsenal, Alabama. Buried munitions include mortar rounds, bombs, rockets, projectiles, and bulk containers (55-gallon and "ton" containers). Chemical agents contained in these munitions include blister agents (sulfur mustard or lewisite), nerve agents (GA, GB, or VX), blood agents (hydrogen cyanide or cyanogen chloride), and a choking agent (phosgene). Other hazardous substances, such as white phosphorus, may also be present. All sites will require one or more of the following steps: (1) site characterization via soil sampling, metal detection, the use of other ground-penetrating sensor technologies, and nonintrusive identification methods; (2) leaving the materiel in the ground, containing potential contamination, and controlling access to the site; (3) on-site treatment using transportable or fixed destruction facilities; or (4) transport of the materiel to another site for storage and destruction, if allowed by federal and state safety, transportation, and environmental regulations. Recovered Chemical Warfare Materiel This category of non-stockpile chemical warfare materiel includes munitions discovered during range-clearing operations, items previously removed from burial sites, and remnants from research and development activities. Much of this materiel is located at nine military installations: Aberdeen Proving Ground, Maryland; Dugway Proving Ground, Utah; Johnston Island, Pacific Ocean; Pine Bluff Arsenal, Arkansas; Redstone Arsenal, Alabama; Fort Richardson, Alaska; Fort Ord, California; Camp Bullis, Texas; and Deseret Chemical Depot, Utah. Recovered chemical munitions (mortar cartridges, artillery, projectiles, bombs, and World War II German Traktor rockets) and containers of incapacitating agents and chemical agents (CAIS, unidentified glass bottles, and bulk containers) are included in this category. Many of the recovered items are the same or similar to those scheduled for destruction through the Chemical Stockpile Disposal
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Program. However, some recovered items may be more difficult to destroy because of their deteriorated condition or the uncertainty of their contents.9 Compared with the amounts of chemical agent in buried munitions or bulk containers, the amounts in individual CAIS items (vials, ampoules, etc.) and, for most CAIS types, even in an entire set are small. A 155-mm projectile, for example, contains about 2.8 kg of agent, or about 2.3 liters if the agent is HD. The smallest HD-carrying projectile, a 105mm M60 cartridge, contains 1.35 kg of HD, or about 1 liter. A ton container of HD holds 726 kg, or about 672 liters (U.S. Army, 1988). As Table 1-3 shows, only the two CAIS types that were used for decontamination training contained 2 to 3 liters of agent "as produced." The other CAIS types contained less than a liter as produced. Following recovery from range-clearing operations or a burial site, recovered chemical warfare materiel is overpacked and either stored on site or transported and stored at a military site with an appropriate permit. After identifying the type and quantity of recovered materiel at a given site, the NSCMP conducts a destination analysis to support the decision to transport or store the materiel. If the decision is made to store it on site, the NSCMP prepares an Interim Holding Facility Plan. If the materiel is to be moved for storage and ultimate destruction, the Army prepares a transportation plan. The NSCMP considers risk to the public and the environment in deciding whether to store or transport the materiel. As required by federal law, the U.S. Department of Health and Human Services reviews the plans and recommends precautionary measures to protect public health and safety. To handle various types of recovered non-stockpile materiel, the NSCMP is developing a number of disposal technologies. One is the RRS, described above and in Chapter 5, for disposal of CAIS sets or separated items. Three types of munitions management device (MMD) are planned for handling recovered munitions. In addition, the Emergency Destruction System (EDS) is being developed for materiel that is too dangerous to move. The EDS will use a shaped-charge explosive to open a munition casing or other container and then treat the agent by chemical neutralization. For details on the MMS and EDS, see Appendix C. Binary Chemical Weapons In binary chemical weapons, chemical agent is produced by a chemical reaction of two nonlethal components at the time the weapon is fired. Three types of binary weapons were tested: (1) the Navy Bigeye bomb; (2) a binary round for the Multiple Launch Rocket System, and (3) the M687 binary 155-millimeter GB projectile, which is the only binary chemical munition that entered full-scale production (production numbers are classified). The Bigeye bomb was not produced or stockpiled, but 200 test weapons and associated equipment are currently in storage at Pine Bluff Arsenal and must be destroyed. The Multiple Launch Rocket System binary munition development program was never completed (prototype development ended in October 1990 [U.S. Army, 1996]), but production equipment and completed components, located at Pine Bluff Arsenal, will require destruction. The components of the M687 projectile are stored at Pine Bluff Arsenal; Umatilla Depot Activity, Oregon; and Deseret Chemical Depot, Utah (U.S. Army, 1993). The individual precursor chemicals that react to form the nerve agent GB are not classified as 9 Recovered materiel is typically characterized by x-ray radiography (to look for explosives) and portable isotopic neutron spectrometry (to determine the presence and type of chemical agent); some materiel is extremely difficult to characterize because of its chemical condition.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program chemical warfare agents, and they are stored separately. Therefore, they should present a relatively minor disposal problem. Some of the precursors (a liquid precursor called QL and powdered sulfur) that react in the Bigeye bomb to form the nerve agent VX must also be destroyed (U.S. Army, 1996). Simple disassembly operations, followed by chemical neutralization or thermal destruction of the precursors, are planned for the disposal of binary weapons. Former Production Facilities Seven former production facilities for chemical weapons were identified to be decommissioned: Pine Bluff Arsenal, Arkansas; Newport Army Ammunition Plant, Indiana; Aberdeen Proving Ground, Maryland; Rocky Mountain Arsenal, Colorado; Northrop Carolina Corporation Facility, Swannanoa, North Carolina; the Marquardt Facility, Van Nuys, California; 10 and the Phosphate Development Works, Muscle Shoals, Alabama.11 These facilities produced BZ (an incapacitating agent), binary agents, unitary agents (VX, GB, mustard, and lewisite), or their precursors at various times from 1941 to 1990. Asbestos and polychlorinated biphenyls (PCBs) are also believed to be present at a number of these sites. Destruction of these facilities is a three-phase process: (1) project definition, including contamination assessment; (2) prerequisite steps (e.g., abatement of asbestos and other hazards); and (3) demolition and disposal, which includes dismantling and destroying process equipment, plumbing, underground structures, and, if required, building materials, followed by environmental remediation of the surrounding site. Miscellaneous Chemical Warfare Materiel This category includes munitions, bulk containers, support equipment, and other devices that (1) were never filled with chemical agent, (2) were filled with simulants, or (3) were filled with agent but were later drained and refilled with decontaminating solution. The CWC requires the destruction of this materiel within five years after the agreement enters into force. (The CWC entered into force on 29 April 1997, 180 days after the deposition of the 65th instrument of ratification.) This materiel is currently stored at eight military facilities in the United States (U.S. Army, 1996).12 Most of this materiel, which is not contaminated with agent, can be disposed of by traditional means. However, associated explosives, propellants, and agent simulants will require separate treatment. LEGAL AND REGULATORY CONTEXT FOR CAIS DISPOSAL The disposal of CAIS is constrained by a number of legal and regulatory issues. First, Army regulations currently classify CAIS as chemical warfare materiel, rather than as a 10 Disposal plans for the Northrop Carolina Corporation Facility and the Marquardt facility, both commercial properties, are unknown. 11 Disposal of this facility was conducted by the Tennessee Valley Authority beginning in the early 1980s. No significant structures remain. 12 The interim version of the Survey and Analysis Report (U.S. Army, 1993) reported that miscellaneous chemical warfare materiel was located at Newport Army Ammunition Plant, Indiana, and Johnston Island in the Pacific Ocean.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program characteristic hazardous waste under RCRA.13 This classification mandates Army control of the materiel for all transportation and disposal, thus prohibiting the use of commercial facilities. However, whether CAIS or some of the chemicals contained in them are lethal chemical agents pursuant to the underlying statute, 50 U.S.C. 1512, is not clear.14 Nonetheless, the conditions imposed by these regulations on the handling, transportation, and disposal of CAIS increase costs significantly but may not increase safety. Second, some chemicals contained in CAIS (sulfur mustard and lewisite) are classified as chemical warfare agents, while others (e.g., phosgene and chloropicrin) are classified as industrial chemicals and hazardous waste, allowing them to be disposed of in commercial facilities. This distinction requires that recovered CAIS be unpacked and individual items characterized, segregated, and then repackaged for separate transport and disposal. Third, under this interpretation of CAIS classification, the transport of CAIS requires government and regulatory approval. Prior to transport, the Army must prepare a transportation plan for approval of the Department of Health and Human Services and must obtain the approval of the governors of all states affected by the proposed transport, particularly the state in which the final destination is located. Fourth, as noted above, the Army facilities built by the Chemical Stockpile Disposal Program for disposal of stockpile chemical materiel are prohibited by federal law from disposing of non-stockpile materiel (or any other hazardous waste except the declared stockpile). Although these facilities were specifically designed for the disposal of chemical agents, this prohibition prevents their use for CAIS disposal. INTERNATIONAL APPROACHES TO CAIS DISPOSAL The disposal of non-stockpile chemical materiel is an international problem. In Europe, farmers have been recovering WWI-era shells for many years, and fishermen have recovered chemical materiel from the North Sea and the Mediterranean. Despite the international dimensions of this problem, apparently no intergovernmental working groups are dealing with chemical weapons disposal or sharing "lessons learned." Active elements of the Technical Secretariat of the Organization for Prohibition of Chemical Weapons have focused on inspections rather than the development or sharing of technology. Army staff have attended a number of technical conferences sponsored by German, British, and NATO groups, but no intergovernmental working group has been established to address non-stockpile disposal issues. The continued involvement of the Army in international conferences and technical exchanges may provide a future forum for sharing information on destruction technologies, as well as on new and advanced detection and identification methodologies. 13 Under RCRA, a substance is determined to be a hazardous waste either because it is listed as such in the law (a listed hazardous waste) or because its characteristics meet the conditions specified in the law for being treated as a hazardous waste (a characteristic hazardous waste). Based on the second criterion, sulfur mustard and lewisite are hazardous wastes. 14 References to federal law in this report use the conventional format of the title of the United States Code (U.S.C.) followed by the section within that title. Appendix D discusses the law and the interpretation of it in Army regulations at greater length.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program CAIS AND THE CHEMICAL WEAPONS CONVENTION Chemical warfare materiel buried before 1972 is not covered under the CWC as long as it remains buried. However, recovered chemical warfare materiel, including recovered CAIS, normally has to be disposed of within 10 years. The United States, through a military working group, is pursuing a special classification for CAIS that would exempt them from the normal disposal schedule (Wakefield, 1999). (As of this writing, the working group has not released its report, so the rationale for an exemption is not known to the committee.) Other nations have similar chemical agent training sets, and inspection protocols for their disposal have been a matter of discussion in CWC working groups. For example, prior to disposing of recovered CAIS items by incineration, the British treat them as recovered chemical warfare materiel subject to CWC requirements (Libby, 1999). The British use an incinerator, located on the military reservation at Porton Down, to dispose of all waste contaminated with or containing chemical agent, including CAIS. The Germans use a military incinerator at Munster to destroy CAIS recovered from German sites.
Representative terms from entire chapter: