Evaluation of the Army's Draft Assessment Criteria to Aid in the Selection of Alternative Technologies for Chemical Demilitarization (1995)

As directed by Congress in 1985, the Department of the Army is carrying out a Chemical Stockpile Disposal Program to destroy the U.S. stockpile of chemical agents and munitions safely. The Army selected incineration as the preferred technology to accomplish this task because it can destroy agent-contaminated explosives, propellants, and dunnage as well as the liquid agents. High-temperature thermal treatment, which is also part of the so-called baseline system (i.e., incineration), decontaminates metal parts so that the metal can be recycled safely. In 1994, the National Research Council (NRC) Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee, a standing committee) reviewed the baseline system and recommended it as a safe and effective process for disposal of the stockpile.

The choice of the baseline system as the preferred disposal technology has become controversial (OTA, 1992). Some community groups and environmental organizations oppose it strongly. In 1992, to address growing public concern, Congress directed the Army to evaluate alternative disposal approaches that might be “significantly safer” and more cost effective than the baseline system and that could be used to complete disposal operations in time to meet a treaty requirement for the year 2004. In response to a congressional directive to the Secretary of the Army, and a request to the NRC from the Army, the Stockpile Committee evaluated potential alternative technologies. While the committee confirmed its earlier recommendations regarding the safety and effectiveness of the baseline system, it also recommended that the Army undertake accelerated research and development on neutralization-based alternatives.

After congressional approval, the Army began laboratory and engineering studies on two neutralization-based technologies—stand-alone neutralization and neutralization ¹ followed by biodegradation—in late 1994. The laboratory investigations have produced encouraging results, and the Army is focusing the engineering studies and scale-up experiments on a small set of technical approaches for use at the stockpile sites where chemical agents are stored only in bulk. Current work is centered on collecting the data needed to design pilot-scale demonstrations of mustard and VX disposal processes and to decide whether to build the necessary pilot demonstration facilities. Because the construction and operation of a pilot plant might cost up to $200 million, the decision will be made by the Defense Acquisition Board of the Department of Defense (DoD).

As part of the process leading to the decision in late 1996, the Army has issued a set of proposed assessment criteria. The Army asked that the Stockpile Committee assist in the decision-making process by evaluating the draft assessment criteria, which are detailed in the Army's April 26, 1995, document, Assessment Criteria to Aid in the Selection of Alternative Technologies for Chemical Demilitarization (U.S. Army, 1995a). The Army also requested that the committee analyze the research and development results in light of the final assessment criteria. The current report evaluates the Army's draft assessment criteria on the basis of both the technical requirements for a disposal technology and public concerns about agent-destruction technologies. A separate NRC report will evaluate the adequacy of the technical data that will be used as a basis for the decisions about demonstration facilities.

The committee recognized that other existing research and development programs also focus on destruction of chemical weapons. These include efforts in the U.S. private sector and a joint Russian-U.S. program for development of technologies applicable to the Russian chemical weapons stockpile. Criteria necessary for the evaluation of these programs were beyond the committee's current scope, although many

of the criteria discussed here may be applicable to other programs.

The stated goal in the Army's design of assessment criteria was to develop discrete and unambiguous criteria that would minimize bias in the assessment process. The Army developed 10 basic assessment criteria categories, which were then subdivided into 55 evaluation factors. A total of 169 specific assessment criteria, formulated as questions, were then developed to address the issues identified in the evaluation factors. These criteria are reproduced as Appendix C of this report.

The Stockpile Committee sought to define the critical factors that should underpin the Army's assessment criteria. To do so, the committee solicited written input from the Army, environmental organizations, state regulators, community groups, and interested individuals. Responses were received from approximately 40 organizations and private citizens. The greatest public concern was fear of long-term health effects from exposure to low-level emissions of agent or incineration byproducts during routine operation of an incineration facility. Similarily, the public was very concerned about the quantity, characteristics, and potential health and environmental impact of effluents from an alternative process (including atmospheric emissions, waste-water discharge, and solid wastes). A second major concern was potential adverse effects from the presence of a disposal facility, particularly an incinerator, in a community. This concern included fears of decreased property values, reduced salability of agricultural products, and adverse impacts on recreational areas such as the Chesapeake Bay. Communities were also concerned about the Government's commitment to decommission the disposal facility after destruction of the stockpile is completed. The communities preferred to avoid dual use processes that have the potential for importing other wastes.

On the basis of these concerns, as well as the generic technical requirements, the committee identified four factors that should provide the bases for detailed assessment criteria: process efficacy, process safety, schedule, and cost.

These four factors can be expressed as simple questions:

• Does the alternative agent-destruction process effectively meet agent-destruction requirements?

• Is the alternative technology at least as safe as the baseline system? ²

• What are the impacts of implementation of an alternative technology on the schedule for stockpile destruction?

• Is the alternative process cost effective?

In addition to addressing public concerns, the factors identified by the committee embrace the treaty requirements for irreversible destruction of agents, as well as the U.S. Public Law requirements for safety, cost effectiveness, and the ability to meet the schedule defined by the treaty. Therefore, they formed the basis for the committee 's evaluation.

In its evaluation of the Army's draft assessment criteria, the committee determined that the criteria address both the four critical factors and their subfactors; however, the committee believes that an increased level of detail is necessary if the assessment criteria are to elicit adequate information.

The committee also considered three specific questions in its evaluation of the Army's draft assessment criteria document:

1. Does the draft criteria document address, and give proper emphasis to, the factors that the committee considers central to the comparison between the alternative technologies and the baseline system?

2. Will use of the draft assessment criteria generate the data that the committee believes are necessary for making a decision on whether to proceed with pilot-scale demonstration for one of the alternative technologies?

3. Does the draft assessment criteria document raise other issues with respect to the decision process regarding an alternative technology?

This last question led the committee to offer advice on presenting the ways in which the assessment criteria will be used and on preferred ways for the Army to seek

community input on disposal technologies. Examination of the draft assessment criteria on the basis of the four critical factors and these questions led to the findings and recommendations presented in Chapter 6. These major themes are summarized below.

The numbered findings and recommendations can be found in Chapter 6. In summary, the committee believes that the Army has developed a reasonably comprehensive set of technical criteria for assessing neutralization-based alternative technologies and for facilitating a decision about whether that alternative should be demonstrated in a pilot-scale facility. However, the usefulness of the assessment criteria in addressing issues raised by the public can be improved by describing how the criteria will be used and how the alternative technologies will be compared to the baseline system (i.e., incineration). Given the significant stakeholder roles of local communities and environmental regulators, the assessment criteria should also be amplified to explicitly address their concerns about the health and economic effects of a disposal facility. These stakeholders can play a critical role in facilitating or impeding the implementation of any process, and efforts should be made to inform them of process selections and to seek their input on factors relevant to the decisions.

The Army's draft assessment criteria were developed to evaluate neutralization-based technologies. The committee's recommendations are focused on neutralization-based alternative technologies but can be applied to other technologies that the Army may consider in the future. However, additional criteria will be needed to deal with other destruction processes, applications at sites with agent contained in munitions, or destruction in a privately owned facility.

The findings and recommendations in this report are intended to improve the assessment criteria that the Army has issued in draft form. The committee anticipates that the final criteria will be modified to reflect the Army's consideration of the recommendations.