5
Alternatives to Commercial Incineration of CAIS

In this chapter, the committee evaluates several disposal alternatives to commercial incineration. These include the mobile RRS, which is the Army's "baseline" approach to CAIS disposal; the RRS operating from one or more fixed sites (fixed-mode RRS); and nonincineration technologies at commercial or Army facilities. These alternatives are evaluated in terms of the issues enumerated in Chapter 3.

BASELINE, MOBILE RAPID RESPONSE SYSTEM

The committee's evaluation of the mobile RRS alternative is summarized in Table 5-1 and discussed below.

Technology

In principle, the RRS should be a safe and effective method for disposing of recovered CAIS chemicals. The neutralization chemistry on which the RRS design is based has been demonstrated in laboratory studies (U.S. Army, 1997c). However, some questions associated with use of the RRS can only be answered through practical demonstration, and the RRS unit is still undergoing testing in final, integrated form.

Effectiveness and Reliability

The committee observed during an RRS demonstration that the major operations have a laudable simplicity. Most CAIS processing activities are performed manually, and the steps appear to be easily learned by operators and easily controlled. These characteristics contribute to the general reliability of the system.

Several neutralization technologies for destroying chemical warfare agents have been demonstrated as part of the Army's ATA (Alternative Technologies and Approaches) Program and disposal programs by European nations (Shaw and Cullinane, 1998; Yang, 1995). In general, these neutralization processes have proven to be simple, safe, and effective.

The specific chemistry used in the RRS neutralization reactor is closely related to the chemistry used to decontaminate military personnel and equipment under battlefield conditions (Yang et al., 1992). The RRS chemical reagent, 1,3-dichloro-5, 5-dimethylhydantoin, oxidizes sulfur mustard and lewisite to form products that are much



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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program 5 Alternatives to Commercial Incineration of CAIS In this chapter, the committee evaluates several disposal alternatives to commercial incineration. These include the mobile RRS, which is the Army's "baseline" approach to CAIS disposal; the RRS operating from one or more fixed sites (fixed-mode RRS); and nonincineration technologies at commercial or Army facilities. These alternatives are evaluated in terms of the issues enumerated in Chapter 3. BASELINE, MOBILE RAPID RESPONSE SYSTEM The committee's evaluation of the mobile RRS alternative is summarized in Table 5-1 and discussed below. Technology In principle, the RRS should be a safe and effective method for disposing of recovered CAIS chemicals. The neutralization chemistry on which the RRS design is based has been demonstrated in laboratory studies (U.S. Army, 1997c). However, some questions associated with use of the RRS can only be answered through practical demonstration, and the RRS unit is still undergoing testing in final, integrated form. Effectiveness and Reliability The committee observed during an RRS demonstration that the major operations have a laudable simplicity. Most CAIS processing activities are performed manually, and the steps appear to be easily learned by operators and easily controlled. These characteristics contribute to the general reliability of the system. Several neutralization technologies for destroying chemical warfare agents have been demonstrated as part of the Army's ATA (Alternative Technologies and Approaches) Program and disposal programs by European nations (Shaw and Cullinane, 1998; Yang, 1995). In general, these neutralization processes have proven to be simple, safe, and effective. The specific chemistry used in the RRS neutralization reactor is closely related to the chemistry used to decontaminate military personnel and equipment under battlefield conditions (Yang et al., 1992). The RRS chemical reagent, 1,3-dichloro-5, 5-dimethylhydantoin, oxidizes sulfur mustard and lewisite to form products that are much

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 5-1 Summary Evaluation of the Mobile RRS Option   Committee Evaluation Technology   Process reliability and effectiveness Neutralization process is proven; reliability and effectiveness appear to be high; some issues remain unresolved. Technical maturity Process chemistry is mature; RRS system is being tested. Monitoring and disposal of process effluents Liquid process wastes must be packaged, transported, and treated; liquid wastes must be characterized to ensure safe disposal. Laws and Regulations   Consistency with present laws, regulations, and treaties State-by-state and site-specific RCRA permitting could lead to significant delays and costs. Costs   Permitting Site-specific permit required for each state in which RRS is used; RCRA permit required to store CAIS for more than 90 days. Indemnification None Facility modifications None Transportation Transportability of RRS is a major advantage, but transporting and staffing costs are considerable; treatment of liquid wastes at commercial facilities adds to cost. Processing operations Estimated costs of processing (site preparation, set-up, operations, closure) are high; large staff and overhead required; support costs of RRS between deployments required. Indirect costs Cost recovery for design and construction; usage fees. Environmental Impacts, Worker/Public Safety, and Risks   Environmental impact Will be assessed during RRS test program and initial permitting. Worker safety Will be assessed during RRS test program and initial permitting. Public safety Will be assessed during RRS test program and initial permitting. Risk analysisa Essentially covered in design and development of procedures, costs, etc.; risks of disposition of neutralized wastes unknown but less of a concern. Public/Stakeholder Involvement A mobile facility is likely to be more acceptable than a permanent, fixed facility; however, incineration of RRS wastes is strongly opposed by some segments of the public Programmatic Aspects   Schedule Movement and permitting of RRS could cause delays Funding Operational funding requirements are significant. Organizations Movement of RRS would require coordination. a Risk analysis includes identifying hazards, understanding the risks, identifying risk control measures, and putting risks into context. The initial discovery of CAIS items, particularly by untrained members of the public, seems to pose the greatest risks. However, the committee's analysis begins at the point of CAIS recovery.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program less toxic than the agents, although they are not innocuous. This reagent appears to have been chosen for the RRS because it reacts slowly with the chloroform solvent in some CAIS ampoules but destroys the agents extremely rapidly at low temperatures (25 to 100°C). At these low temperatures, the reactor can operate under pressures only slightly higher than atmospheric pressure (U.S. Army, 1997b). The combination of low reactor pressure and containment of the entire reactor within a controlled-atmosphere enclosure (a glove box vented through a carbon filter stack) minimizes the risk of leaks of agent vapor into the workplace. The reaction in the RRS reactor is intended to reduce the concentration of agent in solution to less than 50 ppm (i.e., a DRE of 99.9 percent for a 5 percent solution of mustard or lewisite). The products of the mustard reaction include chlorinated sulfoxides, sulfones, chlorinated ethanes and butanes, aldehydes, monochlorodimethylhydantoin, and dimethylhydantoin, all of which are dissolved in the chloroform/tert-butyl alcohol mixture used in the neutralization reaction (U.S. Army, 1997c). The solution of reaction products is drained into a waste drum approved by the U.S. Department of Transportation for storage until it can be transported to a commercial hazardous waste disposal facility for further treatment (to reduce the agent concentration to less than 0.01 percent) and final disposal (U.S. Army, 1998b). An analytical system based on gas chromotographymass spectrometry analysis has been developed to measure unreacted agents (mustard or lewisite) in the neutralization products. The analysis appears to be sensitive down to approximately 10 ppm of agent. However, there may be some problems in analyzing mixtures of agents (Lucas, 1997). The composition of the neutralization product solution raises a number of issues that the committee was unable to resolve with the information available: Is a reaction product containing up to 50 ppm of mustard or lewisite suitable for transport without further treatment? In the Army's ATA Program, the release standard for mustard in the neutralization effluent is 0.2 ppm, which corresponds to a DRE of 99.9995 percent. Can the liquid waste stream be made compatible with nonincineration technologies for secondary treatment of these wastes? For example, can glass fragments and other solids be filtered from the neutralization mixture and readily treated? If items in a CAIS set are broken or leaking and the packing material has been contaminated, how would this material be processed? •Does the working environment of the RRS glove box allow for an effluent sample to be held until it is analyzed and for the effluent to be reprocessed if it does not meet the release standard? Are special toxicology issues associated with some reaction products, such as bis(2-chloroethyl) sulfoxide, that are formed in the mustard neutralization reaction? Are special disposal issues associated with the major arsenic-containing product, 2-chlorovinylarsonic acid, produced by the oxidative neutralization of lewisite? Are special disposal issues associated with chlorinated hydrocarbon by-products, such as 1,2-dichloroethane, which is a so-called "land-banned chemical" subject to special regulatory restrictions? Will the neutralization process deal effectively with the solid deposits (e.g., cyclic sulfonium salts) often found in old samples of sulfur mustard?

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Technical Maturity The RRS concept includes aspects of many established operations in the Army's chemical demilitarization operations. For example, the Army has extensive experience using chemical systems for destroying chemical warfare agents and using monitors to detect their presence in the atmosphere. The Army also has extensive experience with the handling and transportation of toxic materials. Although the RRS design draws heavily on the Army's experience, the overall system is only now being assembled and tested as an integrated system. Until testing has been completed, a final judgment about many facets of its operation would be premature. For example, problems may be encountered in analyzing the incoming samples in the unpacking and characterization compartments of a working RRS if the atmosphere contains high concentrations of organic vapors. The current assumption that the liquid waste will be treated by incineration may have to be reconsidered. Solving these problems may increase development time and cost significantly. A flow chart, or similar analytical tool, that captures all the possible paths from CAIS feeds to final disposal states should be developed and made available to all parties involved in evaluating the RRS and approving its use. Monitoring and Disposal of Process Effluents The efficacy of the monitoring systems used throughout the RRS apparatus can only be evaluated when the system is completed and in operation with actual CAIS materials. Analysis of the neutralization effluents may prove to be a challenge, especially if the release standard is lower than the current 50 ppm. In that case, the methods used for analyzing the water-based effluents from the neutralization process developed in the ATA Program may not be adaptable to the chloroform-based effluents generated in the RRS. A critical point concerning the disposal of RRS process effluents is that they will require further processing for ultimate disposal. The currently proposed approach is incineration of these effluents in an approved commercial facility. Laws and Regulations Use of the baseline, mobile RRS for CAIS disposal is likely to require obtaining a RCRA operating permit for each state, and even for each site within a state. Permit conditions are likely to vary from state to state and perhaps from site to site. Because there may be dozens of CAIS recovery sites, and because many months are often required to obtain RCRA operating permits, this requirement could lead to significant delays in CAIS disposal unless some process can be established to expedite approvals for sites within a state and across states. The transportability of the RRS, which solves a number of difficult issues related to transporting CAIS prior to characterization and treatment and to transferring one site's CAIS problem to another site, is a favorable feature that could help expedite the permitting process.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Costs Permitting For every non-Superfund site where CAIS are found and the RRS is used, a RCRA permit will be required. The cost of obtaining a RCRA permit has been estimated to be $250,000 by the Army (U.S. Army, 1997a, p. F-13), and, based on the Army's experience in obtaining a RCRA permit to test the RRS in Utah, can take up to three years. The time required to obtain RCRA and other permits in each state where CAIS are found may mean the use of the mobile RRS is impractical. Also, state-specific permit restrictions may limit the use of the RRS to a single campaign to destroy known CAIS items; a permit modification (or new permit) may be required to process CAIS items found after the permitted RRS operation has been completed. If the simplicity and transportability of the mobile RRS option are appealing to regulators and community stakeholders, the costs in time and resources to obtain individual permits could be reduced by an effective public involvement program. Transportation The costs and logistics of transporting the RRS (two trailers and a mobile analytical laboratory), as well as supplies and staff, could limit the use of the RRS as a rapid disposal facility. Transport by air would require two C-141 aircraft. Transport by land would entail trucking the RRS trailers and other equipment. The Army estimates the cost of moving the R-RS and associated equipment from Tooele, Utah, to Anchorage, Alaska (2,500 miles) to be $33,000. Land or air transportation would also involve moving the staff required to operate the RRS. These costs were estimated by the Army to be more than $172,000 for 55 calendar days of operation of the RRS in Alaska (U.S. Army, 1997a, p. F-14). Packaging Under the baseline RRS approach, the costs of identifying CAIS items, separating them into industrial chemicals and chemical warfare material (sulfur mustard and lewisite), and repackaging them would be borne by the Army, typically through the environmental restoration line item in the budget of the installation where the CAIS are found. For CAIS found on former military bases, these costs will be paid from a special environmental restoration fund reserved for inactive military sites. Processing The principal cost with the RRS would be the cost of processing CAIS items. In the cost estimate for the proposed treatment of CAIS at Fort Richardson, Alaska, 13 RRS-specific staff and several on-site Army staff were required for processing operations. The processing of the seven PIGs at Fort Richardson, including mobilization, site preparation,

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program set-up, processing, closure, and site cleanup was estimated to take 55 calendar days and to cost almost $457,000 in labor costs alone (average $64 per hour). The cost of materials and equipment, not including transportation and usage fees, was estimated to be another $228,000. Finally, management, engineering, and other costs were estimated to be more than $250,000. Based on the one-gallon capacity of the RRS neutralization reactor, the Army assumed that the RRS can process one CAIS bottle or three ampoules per batch and that the time required for neutralization of a batch is 15 minutes (30 minutes for the CAIS types consisting of agent-on-charcoal). The processing rate is not a cost issue, per se, although the daily labor cost of operating the RRS (more than $13,500 per day in Alaska) is significant. Indirect Costs The costs of designing, building, and maintaining the RRS, as well as the costs of replacement and spare parts, were included in the cost estimate of RRS operations and were estimated to be $5,100 per calendar day. This cost, along with a usage fee of $2,150 per day for the mobile analytical laboratory, came to almost $400,000 in materials and equipment costs for disposing of the seven PIGs during a 55-day campaign. Environmental Impacts, Worker/Public Safety, and Risks Many potential environmental and safety issues will be evaluated during the RRS test program in Utah, and during the site-specific permitting process for R-RS operations. In general, because CAIS disposal via the RRS would be implemented by the Army, the risks of recovery, treatment, and disposal were probably addressed in the planning and design process. The risks of storage, handling, and treatment are controlled through the secure storage areas, glove boxes, monitoring systems, excess neutralization capacity, and other features of the RRS design. The Army's Technical Escort Unit is assumed to be responsible for the recovery, packaging, and transport of the CAIS. The two areas that have not been covered explicitly in the design are the transport and disposal of the neutralized wastes, although these wastes will be similar to other regularly handled industrial wastes. Because risk reduction, mitigation, and control measures are built into the process design and procedures of the RRS, as well as the proposed staffing plans, risks are accounted for in the cost and schedule estimates. Public/Stakeholder Involvement The issues about public acceptability raised in Chapter 4 can also be applied to the options for CAIS disposal discussed in this chapter, including the RRS options. Key Stakeholders With the exception of commercial facility owners, the stakeholders for the mobile RRS option are the same as for the commercial incineration option. Stakeholders include the Army and Congress, regulators, local populations near the RRS and along

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program transportation routes (which will differ from those for the commercial option), and national interest groups. Although the basic issues for each stakeholder group are the same as for the commercial disposal option, the particular application of each issue and the potential critical issues vary with the option under consideration. Key Issues for Each Stakeholder Group Army and Congress. An issue of primary concern to both Congress and the Army is that the mobile RRS is not cost efficient for treating small quantities of CAIS. However, one advantage of the mobile RRS is that it avoids the need for construction of a permanent disposal facility and the need to transport CAIS. Transportable facilities minimize the impacts on active military bases and may make this option more acceptable to the public than a fixed RRS. State Legislators and Regulators. The mobile RRS has several features favoring its acceptability to the constituencies represented by legislators and regulators. First, it provides a means of eliminating risks from recovered CAIS to nearby communities without transferring the risks elsewhere (for example, transportation risks en route or disposal risks at a distant facility). Second, it avoids the potential for negative public reaction to permitting changes that could be required for commercial incineration facilities. Third, it eliminates concerns about location of a permanent facility and safe transportation. This option would, however, require storage of CAIS, which could raise concerns among nearby communities. Local Populations. On balance, the mobile RRS appears to be more positive for communities near recovered CAIS than either commercial disposal or the fixed RRS option. Three major advantages are (1) it does not use incineration; (2) it is not a fixed facility (which might be used for other disposal purposes), and it can be removed quickly following on-site disposal of CAIS; and (3) it avoids the risks of transporting CAIS and the associated handling risks. Issues that could cause concerns among nearby communities are (1) the extended period of storage pending deployment of an RRS; and (2) the storage of residual wastes, if these are stored until a nonincineration technology becomes available. Regional and National Interest Groups. The mobile RRS meets several of the stated acceptability criteria of regional and national interest groups. It uses neutralization rather than incineration. It is a temporary rather than a permanent facility, and it does not require the transportation of chemical agent off the site where CAIS are discovered or stored. It also enables an affected community to take care of its own waste rather than placing the burden on another community. However, a major concern of these groups is the proposed use of incineration technology for the treatment of residual wastes. In their view, using incineration would establish a precedent for continued reliance on this technology and would undermine the urgency of developing more acceptable alternatives. Stakeholder Influence On Policy Local, regional, and national stakeholders can affect policy through political and regulatory processes. The mobile RRS offers several advantages in terms of regulatory

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program requirements. Transporting the technology to the waste, rather than transporting the waste to the technology, eliminates the need to comply with complex transportation requirements that could arouse public concerns. In addition, it eliminates the need for statutory or regulatory changes that might be necessary for commercial incineration. However, stakeholders may still have opportunities for review and comment on project-specific NEPA documents. They may also intervene in the state permitting processes that would be required for the RRS and for on-site storage of CAIS pending deployment of the RRS to the site. As noted in Chapter 4, comments recently submitted by the Non-Stockpile Chemical Weapons Citizens Coalition to the state of Utah indicate a likelihood of strong opposition to the use of incineration as a secondary technology. The Army could resolve this problem in two ways. First, the Army could apply for permits for storing CAIS or retaining residual wastes following neutralization on site or shipping them off site to an interim storage facility (either commercial or government-owned) until an acceptable nonincineration technology becomes available. However, this approach entails several potential disadvantages: (1) it is uncertain when an acceptable technology will become available; (2) Congress and the Army would be faced with additional monitoring costs; (3) federal and state regulators may be reluctant to approve long-term monitoring of wastes for which a technical solution (incineration) is already available; and (4) communities near a proposed interim storage facility may oppose the facility (e.g., concerns about health and safety, equity, and becoming a permanent dumping ground). A second approach would be to engage the leaders of interest groups and the local community with Army representatives in developing ''win-win" solutions. This approach has the advantage of bringing together key group members and the Army personnel who have already established working relationships with them. A possible disadvantage of this approach is the uncertainty about the storage time required until an acceptable technology becomes available. Programmatic Aspects Movement of the RRS between states, and between sites, will require significant coordination among the Army, federal and state regulators, and other state and local government officials. A lack of coordination could lead to delays and add to the cost of CAIS disposal, and thus add to the funding requirements for the program. FIXED RAPID RESPONSE SYSTEM The committee also evaluated the use of the RRS in a fixed mode of operation. (It also briefly investigated modified RRS options, such as the Army's ECS [Expedient CAIS Disposal System], which is described in Box 5-1). To avoid permitting and other site-specific costs associated with moving the RRS to CAIS discovery sites, the committee considered the alternative of having one or more fixed RRSs at permitted storage sites for CAIS materials. In this scenario the CAIS materials would be transported to the nearest RRS (see Table 5-2). Technology The technical issues for the fixed RRS alternative are the same as for the baseline, mobile RRS option.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program BOX 5-1 Expedient CAIS Disposal System Disposal of CAIS via a modified RRS, called the Expedient CAIS Disposal System (ECS), would be an alternative to the RRS in some situations. Although the ECS has substantial technical limitations, using it might result in cost savings in terms of reduced permitting needs because of its rapid deployment to a CAIS recovery site and its reduced staffing and support needs. The usefulness of the ECS would be limited by its small glove box, its inability to remove CAIS items from metal overpacks, its inability to remove neutralization wastes from the reactor under engineering controls, and other factors. Nevertheless, the ECS could be applicable in some situations. Laws and Regulations Operation of the RRS in a fixed mode offers significant regulatory advantages over the mobile RRS option. Once an RRS is sited and granted a long-term operating permit at one or perhaps a few regional sites, no additional state-by-state or site-by-site operating permits would be necessary, which would be a significant cost and schedule advantage over the mobile RRS. However, use of the RRS in a fixed mode would require transporting recovered CAIS, as found, to the RRS. This transportation would require transport plans approved by the U.S. Department of Health and Human Services and by state governors. Costs Most of the costs for the fixed RRS are the same as for the baseline, mobile RRS. The key differences in cost are for permitting; packaging and transporting the CAIS sets and items; processing; and recovery of indirect costs. Each of these factors is discussed below. Permitting RCRA and other permits would only be necessary for the relatively few states in which fixed RRSs would be located, which would result in substantial savings in permitting costs and time. The savings are based on the assumption that the permits would allow out-of-state CAIS items to be destroyed in the RRS and would allow the RRS to process CAIS items that have not yet been recovered and stored in the state. Neither of these assumptions would be valid in Utah, the only state that has issued a RCRA permit for RRS operations so far. State permit requirements vary, however, so these factors may not necessarily make the fixed RRS a less attractive option in terms of cost. They should be kept in mind, however, when considering this alternative. Transportation Although the CAIS materials would have to be brought to the fixed RRS, transportation costs are modest. In its cost analysis, the Army estimated that the cost of

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 5-2 Summary Evaluation of the Fixed RRS Option   Committee Evaluation   Technology   Process reliability and effectiveness Neutralization process is proven; reliability and effectiveness appear to be high; some issues remain unresolved. Technical maturity Process chemistry is mature; RRS system is being tested. Monitoring and disposal of process effluents Liquid process wastes must be packaged, transported and treated; liquid wastes must be characterized to ensure safe disposal. Laws and Regulations   Consistency with present laws, regulations, and treaties RRS permitting requirements by states and EPA are reduced; approvals for CAIS transportation by U.S. Department of Health and Human Services are increased. Costs   Permitting Several operating permits are necessary for RRSs; permits may limit use to in-state or known CAIS items; permits and transportation plans are required to ship CAIS. Indemnification None Facility modifications None Transportation Transporting CAIS to RRS with escorts is an added cost, but field staffing costs are lower; treatment of liquid wastes at commercial facilities adds cost. Processing operations No site preparation or closure costs; in-field costs of characterizing, separating, and packaging CAIS would be incurred. Indirect costs Cost recovery for RRS design and construction; usage fees. Environmental Impacts, Worker/Public Safety, and Risks   Environmental impact Will be assessed during RRS test program and initial permitting. Worker safety Will be assessed during RRS test program and initial permitting. Public safety Will be assessed during RRS test program and initial permitting; transportation to fixed RRS must also be assessed. Risk analysisa Essentially covered in design and development of procedures, costs, etc.; risks of disposition of neutralized wastes unknown but less of a concern. Public/Stakeholder Involvement Incineration of RRS effluents is strongly opposed by some segments of the public; Army should seek public approval o f RRS sites. Programmatic Aspects   Schedule CAIS transportation approvals may cause limited delays. Funding Operational funding required. Organizations RRS sites would have to be approved by base commanders. a Risk analysis includes identifying hazards, understanding the risks, identifying risk control measures, and putting risks into context. The initial discovery of CAIS items, particularly by untrained members of the public, seems to pose the greatest risks. However, the committee's analysis begins at the point of CAIS recovery.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program transporting seven PIG overpacks by military aircraft from Fort Richardson, Alaska, to the permitted storage site at DCD in Utah and the cost of temporary storage to be $33,300. The same cost for moving the PIGs to the permitted storage site at Pine Bluff, Arkansas, was estimated to be $45,300. The associated staff travel and per diem costs were about half of the costs of transporting the RRS to the CAIS location in Alaska. Additional costs could be incurred, however, in moving chemical warfare materiel rather than moving the processing equipment, especially if transportation plans must be prepared and regulatory agency approvals obtained. Processing and Indirect Costs The same issues and concerns that were raised for the mobile RRS apply to the fixed RRS because the CAIS handling and processing operations would be the same. Environmental Impacts, Worker/Public Safety, and Risks Use of the RRS in a fixed mode would require that all recovered CAIS be transported from recovery sites to the RRS, as recovered, which would increase risks to the public. However, using the Army's Technical Escort Unit to transport recovered CAIS could minimize transportation risks. Public/Stakeholder Involvement Key Stakeholders The stakeholders for the fixed RRS are the same as for the mobile RRS, although the local populations would differ. In this option, local populations would be located near a fixed RRS, near an interim storage facility, and along proposed transportation routes. Key Issues for Each Stakeholder Group The basic issues for each stakeholder group are the same as for commercial incineration or the mobile RRS, although the particular applications and relative importance of issues may vary. Army and Congress. The fixed RRS offers a cost advantage over the mobile RRS by processing CAIS at fewer locations. Compared with commercial incineration, it avoids potential negative public reaction and controversy over attempts to change the law or regulations. However, the cost savings may be less than anticipated because siting a permanent facility might require more funding and public involvement than the mobile RRS would. Three issues are likely to arise for the fixed RRS: (1) concerns of local communities about the health and safety impacts; (2) concerns about the economic impacts of a permanent, fixed facility; and (3) concerns about transporting CAIS (this concern may be reduced once the small numbers and amounts of CAIS are made known). An additional issue for the Army is that the selection of RRS location(s) may have to focus on sites at existing chemical weapons disposal facilities; thus coordination with the Chemical Stockpile Disposal Program will be essential.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program State Legislators and Regulators. The fixed RRS option would address public concerns and political pressures to remove CAIS risks from communities near the sites where CAIS are recovered but not processed. However, this option is likely to arouse new concerns in communities along CAIS transportation routes, near interim storage facilities, and near the fixed-RRS sites. National and Regional Interest Groups. Although the fixed RRS would use neutralization to treat CAIS materials, incineration is the most likely technology for treatment of residual wastes. Incineration has aroused much public opposition among national and regional environmental groups. In addition, a key issue for the Army will be balancing short-term and long-term program goals and nurturing the effective relationships that have begun to develop with the stakeholders. Interest groups may also be concerned about the risks of CAIS transportation. Local and Tribal Populations. Although communities near CAIS discovery sites will appreciate the removal of the risk of untreated CAIS, the transfer of risk to other communities is likely to be a concern. Communities along transportation routes may be concerned about the risks of transporting CAIS and the capabilities of local and tribal emergency responders (again, this opposition may be limited because of the small amounts of CAIS involved). Communities near proposed RRS site(s) may raise issues related to the siting of RRSs, including equity (more than one RRS), health and safety, involvement of local communities in decision making, fears that the RRS will become a site for treatment of other wastes, and Army accountability. Stakeholders Influence on Policy Stakeholders will have several opportunities to influence policy: during the selection of site(s) for the fixed RRSs, during the application process for the operating permit for the RRS, and during regulatory oversight of the transportation of CAIS to the RRS. U.S. Department of Health and Human Services requirements for notification prior to the shipment of CAIS and U.S. Department of Transportation regulations that require appropriate placards would increase the public visibility of shipments. Programmatic Considerations The fixed RRS would have some programmatic impacts. First, the Army would have to work with military base commanders, regulators, and affected stakeholders to select the site(s) for the RRS(s). Permits for operation at the site(s) would have to be obtained. Transportation of as-recovered CAIS would require coordination of transportation resources (i.e., Technical Escort Unit personnel and equipment) and funding. Close coordination between the Army, regulators, and the affected state and local governments would be necessary. NONINCINERATION ALTERNATIVES The committee's evaluation of nonincineration alternatives for CAIS disposal is summarized in Table 5-3 and discussed below.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 5-3 Summary Evaluation of Selected Nonincineration Optionsa   Committee Evaluation Technology   Process reliability and effectiveness Neutralization proven during stockpile program development; other processes are under development or unproven. Technical maturity of the process Some commercial processes exist; agent-specific treatment processes are under development. Monitoring and disposal of process effluents Unknown, but, no monitoring is expected beyond routine analysis of residual wastes prior to release; addition of agent monitors could be an added cost at a commercial facility. Laws and Regulations   Consistency with present laws, regulations, and treaties Requires legal/regulatory relief, clarification, or flexibility; some facility permit modifications may be required. Costs   Permitting Some permits required for all CAIS disposal alternatives. Indemnification A potential added cost to the Army or facility. Facility modifications Monitoring and other modifications may add cost. Transportation Transportation to commercial sites may add cost; military escorts may be required; not clear how handling, characterization, and transportation costs are funded. Processing operations CAIS packaging would add costs; dedicated processing of CAIS could be costly. Indirect costs Hidden indirect costs (overhead, administration, maintenance). Environmental Impacts, Worker/Public Safety, and Risks   Environmental impact Air/water emissions minimized by nature of process. Worker safety Will be assessed after technology identified and tested. Public safety Will be assessed after technology identified and tested. Risk analysis Potential risks should be considered in the specification of any treatment option, especially for storage and handling of CAIS items. Public/Stakeholder Involvement Nonincineration-based methods likely to be more acceptable to many members of the public. Programmatic Aspects   Schedule Significant delays possible during technology development or identification; more rapid disposal schedule possible once available. Funding Significant funds required for any technology development program. Organizations Corporate commitment is unknown. a This summary assumes that lewisite could be treated by the technology already in use in the Army's CAMDS (Utah) facility for destruction of bulk lewisite (the Canadian Swiftsure process—neutralization followed by immobilization of the arsenic-containing products in a cement-like matrix that is subsequently disposed of in a landfill). Sulfur mustard could be treated by the technology to be used in the chemical stockpile disposal facility being built at Aberdeen Proving Ground (Maryland) for destruction of sulfur mustard in ton containers (neutralization, followed by biodegradation), or technologies at other commercial facilities could potentially be used.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Technology Both the Chemical Stockpile Disposal Program and the ATA Program have demonstrated technologies for the disposal of sulfur mustard and lewisite that do not involve incineration of either CAIS chemicals or effluents from initial treatments. Additional technologies are being tested in the ACWA (Assembled Chemical Weapons Assessment) Program. Some of these processes may be directly applicable to CAIS materiel. The Army might consider using facilities of the Chemical Stockpile Disposal Program (if permitted by changes in statutes), commercial facilities, or small, government-owned facilities dedicated to CAIS disposal. Treatment in a chemical surety laboratory might be feasible for isolated finds of CAIS ampoules. Existing procedures for laboratory-scale disposal of agent residues with oxidative reagents, such as bleach or persulfate, should be applicable to small quantities (up to seven grams) of blister agents, either neat or in solution. Laboratory disposal might be acceptable if it were limited to finds of just a few ampoules of solution (certainly less than a full or nearly full CAIS), if there were an established route for disposal of CAIS now in storage or for finds of full or nearly full CAIS. Laboratory disposal thus represents a supplementary approach for removing a hazard quickly and efficiently, but it is not a comprehensive solution to the problem of CAIS disposal. Mustard or lewisite adsorbed on charcoal may require different treatment than neat chemicals or solutions. Process Reliability and Effectiveness Both sulfur mustard and lewisite have been neutralized successfully with water or aqueous alkali. In fact, neutralization with hot water will be used to destroy 1,625 tons of "stockpile" HD stored at Aberdeen Proving Ground in Maryland. The reaction with water produces an aqueous solution of thiodiglycol, a relatively innocuous commercial chemical. The mustard concentration is reduced to less than 0.2 ppm, which corresponds to a 99.9995 percent DRE. However, the thiodiglycol solution must undergo further treatment because it is defined as a Schedule 2 precursor compound under the CWC, which means it must be monitored until it is destroyed to ensure that it is not reconverted to sulfur mustard. The thiodiglycol will be destroyed in a biological reactor closely analogous to a sewage treatment plant (NRC, 1996a). The effluent from the bioreactor has very low toxicity to mammals and aquatic species and meets CWC and Maryland standards for destruction and disposal. After treatment in a federally owned treatment works, the effluent will be released into Chesapeake Bay. Ten "ton containers" of lewisite stored at the DCD are scheduled to be destroyed by neutralization in a facility recently built and permitted at the Chemical Agent Munitions Disposal System (CAMDS), a pilot-scale facility located at DCD.1 The CAMDS process involves oxidation of the agent by hydrogen peroxide followed by neutralization with aqueous alkali (Maggio, 1998). Based on Canadian experience with this technology, the agent concentration in the effluent from treating neat agent should be reduced to less than 0.09 mg/ml. The effluent will be prepared for disposal by immobilization in a cement-silica grout. The process appears to meet CWC and Utah standards for destruction and disposal. Neutralization is generally a reliable, robust technology for agent destruction. The Aberdeen and CAMDS processes both operate at near-atmospheric pressure and at temperatures below 100°C. Such mild conditions greatly reduce the danger of dispersing 1    Utah State Department of Environmental Quality. 1998. Permit I. D. Number 5210090002. April 16.

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program agent vapor in the event of loss of containment (e.g., a reactor leak). The same conditions facilitate safe shutdown of the reactor in the event of an electrical failure or stirring problems. With neutralization, the reactor contents can be retained until agent destruction is confirmed. The processes of unpacking, draining, and decontaminating containers are more complex for a neutralization process than for incineration. Metal containers must be cut, punched, or disassembled, and glass containers must be crushed in a glove box to contain agent vapors. Decontamination of metal and glass residues, as well as packing materials (e.g., sawdust) can be done most easily by burning or thermal treatment although nonthermal decontamination is planned for the ATA Program. Technical Maturity Neutralization of sulfur mustard has been tested on a significant scale (114 liter reactor) in the ATA Program (NRC, 1996a) and will be pilot tested on a "production scale" in the Aberdeen facility. This neutralization technology involves detoxification of the agent with hot water. An alternative approach to neutralization of sulfur mustard is based on treatment with monoethanolamine (MEA) or with glycol mixtures (Petrov et al., 1998). The MEA procedure has been extensively tested at laboratory scale in Russia and will be pilot tested at a facility being built at Gorny in the Saratov region (Kovalyev, 1997). Gas-phase hydrogen reduction, as discussed in the Mitretek report (Amr et al., 1998), has been successfully demonstrated with sulfur mustard on a scale of 780-870 g., roughly equivalent to processing seven 4 oz. ampoules or bottles of HD (Kummling et al., 1999). In Canada's Project Swiftsure in 1990-1991, 2.5 metric tons of lewisite were treated by oxidation followed by hydrolysis (McAndless et al., 1992). Hydrolysis of lewisite followed by electrochemical reduction of the arsenic-containing wastes has been selected for pilot testing in Russia (Kovalyev, 1997). Destruction of lewisite by gas-phase hydrogen reduction was demonstrated in Russia but was found to be "very unsafe for the working staff and detrimental to the environment" (Petrov et al., 1998). Monitoring and Disposal of Process Effluents Neutralization processes produce mostly liquid wastes, plus varying amounts of solid waste in the form of decontaminated packaging materials. The gaseous effluents from neutralization are usually small and are handled by venting through charcoal filters. The metal or glass container materials can be decontaminated by thorough washing with hot water, dilute caustic, and/or bleach solution. Prior to disposal, they can be monitored for the presence of residual agent by holding them in a closed chamber with an ACAMS monitor, as is done for empty ton containers in the ATA Program. Liquid waste streams from neutralization generally undergo further treatment before final disposal. In the ATA Program, the effluent from hydrolysis of sulfur mustard is analyzed to confirm a satisfactory level of agent before the liquid is released for further processing and disposal (NRC, 1996a). It remains to be seen whether such a monitoring system would be necessary in a commercial neutralization facility. With arsenic-containing agents, such as lewisite, it is desirable that the arsenic content be immobilized as an insoluble arsenate salt (such as ferric arsenate) before disposal in a landfill. In the CAMDS process, the toxic arsenate-containing waste stream from lewisite neutralization will be immobilized in a solid grout before final disposal (Maggio, 1998).

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Specific Applications of Nonincineration Processes Sulfur Mustard. At the Aberdeen facility, the treatment of sulfur mustard, either pure or in solution, would entail the following steps: hydrolysis by vigorous stirring with hot (90°C) water to generate a dilute solution of thiodiglycol and hydrochloric acid adjustment of the solution acidity to near-neutral pH with aqueous sodium hydroxide steam stripping or air stripping to remove volatile organic impurities (mostly chlorinated hydrocarbons) biological oxidation of thiodiglycol and other organic components of the aqueous solution discharge of the aqueous effluent into the sewage treatment plant at Aberdeen Proving Ground for final cleanup before disposal It seems likely that a chloroform solution of mustard could be treated similarly. The chloroform would distill from the neutralization effluent along with other volatile chlorinated hydrocarbons that are normally present. Monitoring and waste disposal for CAIS might be the same as in the Aberdeen process. The major modifications in procedure would relate to unpacking CAIS items and decontaminating the glass and metal residues. The latter might be carried through the ton container clean-out line in a basket, as is done in the Aberdeen process for small metal parts, such as valves and fittings. The following points would have to be verified for the destruction of CAIS mustard: establish that chloroform can be treated like other chlorinated hydrocarbons in the Aberdeen process verify the efficacy of the biodegradation process because the sulfur mustard in CAIS items may have different impurities than those found in ton containers stored at Aberdeen demonstrate the effectiveness of the current ACAMS and Depot Area Air Monitoring System (DAAMS) air monitors in the modified process Lewisite Solutions. Lewisite solutions should be amenable to destruction by the CAMDS process. The process would involve the following major steps (Maggio, 1998): oxidation of lewisite to chlorovinylarsonic acid with aqueous hydrogen peroxide catalytic decomposition of excess hydrogen peroxide hydrolysis of the chlorovinylarsonic acid with hot aqueous alkali to form sodium arsenate and acetylene (gas) analysis of the neutralization product to show that the agent concentration is below 1 ppm The neutralization product, an aqueous solution of sodium chloride and sodium arsenate, would be shipped off site for immobilization in a cement-silica grout, which would then be deposited in a hazardous waste landfill. It seems likely that a chloroform solution of lewisite could be processed similarly. The chloroform, which should distill before the treatment with hot alkali, could be condensed in the vent gas knockout drum or collected on the vent filter for commercial disposal. In addition to the questions listed

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program above for the neutralization of mustard, the following questions unique to lewisite processing would have to be resolved: effectiveness of the air monitoring systems for lewisite (ACAMS and DAAMS) requirements for disposing of the arsenate-containing effluent Blister Agents on Charcoal. Bottles containing charcoal on which lewisite or sulfur-mustard is adsorbed present a special problem. The water-based Aberdeen and CAMDS processes may not be effective for removing the agent completely from the carbon matrix, which is likely to be poorly saturated by the aqueous reagents. (The neutralization process in the RRS uses an organic solvent to overcome this problem.) If the aqueous processes do not prove to be effective with agent-on-charcoal samples, other approaches are available, especially because the CAIS items containing only solids pose relatively low risks. If these materials were reclassified simply as hazardous waste rather than as lethal chemical weapons, they could be transported to commercial TSDFs for incineration with very little risk to the public, the workforce, or the environment. Otherwise, the agent-on-charcoal CAIS could be stored safely until appropriate disposal processes were proven. Some disposal options are listed below. Gas-phase hydrogen reduction. One company in the Army's survey uses high-temperature, gas-phase hydrogen reduction in facilities outside the United States (Amr et al., 1998). In testing under the ATA Program, the process destroyed sulfur mustard effectively on a laboratory scale. A similar Russian-developed process also destroys lewisite but appears to be problematic because of questions about the fate of arsenic in the reaction effluent (Petrov et al., 1998). The arsenic might exit the reactor as metallic arsenic or arsine gas, both of which are toxic. Extensive research and development may be required to establish an effective means of removing these materials from the effluent. Neither process has been reported to destroy agent adsorbed on charcoal, but they might work because hydrogen readily penetrates porous solids. The gas-phase hydrogen reduction process would require extensive development to demonstrate its effectiveness. One open issue is whether the hydrogenation reactor should be placed in an enclosure, which would contain agent vapors but would introduce the new risk of accumulating hydrogen (from leaks). High concentrations of hydrogen could be an explosion hazard (NRC, 1996a). Two-stage Russian chemical agent disposal process. In the first stage of this process, the reaction of MEA or MEA-glycol mixtures with sulfur mustard cleaves the carbon-chloride (C-Cl) bonds in the agent molecule that are associated with its toxicity (Petrov et al., 1998). Similar reactions with lewisite break the arsenic-chlorine (As-C1) bonds associated with vesicant activity although they do not affect the immutable toxicity of arsenic. The MEA treatment is also said to be effective for mixtures of mustard and lewisite (Kovalyev, 1997). In the second stage of the disposal process, the viscous reaction mass from the MEA treatment is heated with bitumen. Moderately high temperatures (ca. 200°C) and vacuum are used to distill excess MEA for recycling. After cooling, the bituminous mixture forms a hard black solid that is said to be suitable for landfill disposal. This two-stage process may be effective for deactivating agent-on-charcoal and providing a matrix for landfill disposal. Testing would be necessary to establish that toxic materials do not leach from the bituminous product. SCWO (supercritical water oxidation). Oxygen dissolved in water at 400 to 600°C under high pressure is a powerful oxidant that destroys most types of organic

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program chemicals. SCWO technology is being tested by the Navy for disposal of shipboard wastes and is being demonstrated by the ATA Program for final treatment of the neutralization product of VX nerve agent. Another neutralization and SCWO facility is being funded by the ACWA Program (NRC, 1998). The Army has also contracted for a pilot-scale SCWO unit to be installed at the Pine Bluff Arsenal for the disposal of wastes from its smoke and obscurants program. SCWO has been demonstrated to destroy sulfur mustard with a 99.9999 percent DRE at laboratory scale (Spritzer et al., 1995). The Army has proposed that agent-containing charcoal filters from stockpile disposal facilities, such as Aberdeen Proving Ground, be disposed of by SCWO. The filter materials would be pulverized and fed as an aqueous slurry to a SCWO unit. The expectation is that this treatment would destroy both the charcoal and the adsorbed agent, producing carbon dioxide and an aqueous solution of inorganic salts. The latter could be retained to confirm complete destruction of the chemical agents. If this approach is successful, it would provide an attractive nonincineration option for the disposal of CAIS containing agent-on-charcoal material. For lewisite-on-charcoal, the aqueous arsenate product could be immobilized for disposal, as it is in the CAMDS process. Laws and Regulations The use of commercial facilities for CAIS disposal will require changes, clarifications, or more flexibility in existing laws and regulations. Current regulations and legal interpretations mandate that the Army maintain control of CAIS materials for transportation and disposal. Even if the transport and disposal of CAIS could be accomplished without Army facilities or personnel, and assuming that a commercial facility using nonincineration technology were available and had obtained, or could obtain, an operating permit, regulators might require modifications to the facility's operating permit. Army nonincineration-based facilities might also require changes to their operating permits. Use of the Army's stockpile disposal facilities for CAIS disposal, even those facilities employing nonincineration technologies, would require Congressional and executive action to modify the existing legal restrictions that prohibit their use for disposal of any non-stockpile materiel. Public acceptance of a plan for disposing of CAIS at stockpile facilities is likely to be a prerequisite for congressional action. Costs Permits and approvals will have to be obtained for any nonincineration disposal method. For new technologies, research and development permits may have to be obtained, and testing may be required prior to permitted operations. All nonincineration disposal options involve either bringing a portable disposal facility to CAIS or bringing the CAIS to a fixed disposal facility. In either case, costs similar to those for CAIS and RRS transport will be incurred. Also, the characterization, separation, and repackaging of CAIS items will be required unless all CAIS items can be processed together in the nonincineration facility. For CAIS found in metal overpacks, methods of accessing the CAIS items inside will be required, and estimates for these costs must be included in overall cost estimates. Other costs would be incurred for modifications to a facility already in operation if it is not equipped to receive and process CAIS. Costs for facility modification and personnel

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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program training for new facilities and equipment designed or easily modified to process CAIS may be minimal. Finally, disposal costs will vary with the alternative. The cost estimates for each CAIS disposal alternative must include indirect costs, such as management, overhead, depreciation, and maintenance. Environmental Impacts, Worker/Public Safety, and Risks The impacts of nonincineration-based disposal technologies on risks to the environment and the safety and health of workers and the public will depend on the particular technology and are difficult to predict for a general case. However, air emissions would generally tend to be less for nonincineration technologies than for incineration-based technologies. Water emissions, which are generally easier to monitor and control prior to their release than air emissions, would probably be greater. Public/Stakeholder Involvement Nonincineration-based disposal methods are likely to be more acceptable to many segments of the public, and public support could decrease the legal and regulatory delays before a nonincineration method could be in operation. Given the history of public reaction to the stockpile disposal program and the Army's public commitments on restricting the use of any stockpile facility, including nonincineration facilities, a well designed public involvement program to explore acceptability for use of stockpile facilities would be essential prior to any Army decisions. As discussed in Chapter 3, a public involvement program will also be appropriate if commercial facilities using nonincineration technology are being considered for CAIS disposal. Programmatic Considerations Incineration-based disposal methods are widely available in industry and at Army facilities. Far fewer nonincineration-based facilities could be used for CAIS disposal. Therefore, the selection of a commercial nonincineration facility or the development of a new nonincineration-based technology by the Army could lead to significant delays.