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

The United States Army possesses a large stockpile of lethal chemical warfare agents contained both in munitions and in large bulk containers. These agents are stored at eight locations in the continental United States and on Johnston Island in the Pacific Ocean. As a matter of public policy, Congress has mandated (Public Law 102-484) that all these agents be destroyed by December 31, 2004. The destruction is intended to:

1. fulfill the U.S. commitments under the Chemical Weapons Convention of 1993 (United Nations, 1993), a treaty intended to stop the proliferation of chemical agents and to reduce the chance of their use by destruction of existing national stockpiles and by control of materials that might be used to produce additional agents; and

2. reduce the risks to the U.S. population from possible accidents involving the Army's stockpile of chemical weapons, most of which are 25–50 years old.

In choosing the technology to fulfill the congressional directives for disposal of its unitary chemical agents and munitions, the Army drew on its own experience, as well as that of other nations. In the early 1980s, the Army selected incineration as the preferred technology to destroy these lethal agents. In 1984, the National Research Council's (NRC) Committee on Demilitarizing Chemical Munitions and Agents reviewed the incineration process as part of a study on the status of the stockpile and the technologies for its disposal. In its report, the committee endorsed thermal destruction as a preferred means for the safe disposal of chemical agents and munitions (NRC, 1984). The Army undertook a major program to develop an integrated system based on disassembly of munitions and incineration of the chemical agents, explosives and propellants, and agent-contaminated metal parts and containers. The system, now known as the baseline incineration system, ¹ was tested in a pilot plant at Tooele, Utah, and in a full-scale prototype plant on Johnston Island in the Pacific Ocean southwest of Hawaii. The Operational Verification Testing Program carried out at Johnston Island was reviewed by a second NRC Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) (NRC, 1993a, 1994a). The Stockpile Committee concluded that Operational Verification Testing provided assurance that the baseline system is capable of the safe disposal of the Army's chemical stockpile. Concurrently, the Army has developed a comprehensive plan to use the baseline system to dispose of the entire stockpile at all eight sites in the continental United States by the congressionally mandated deadline.

The decision to use incineration to destroy the chemical agents has been controversial. Community groups, environmental organizations, and several local government officials have expressed concerns about possible adverse effects from incineration-based disposal operations on human health and the environment. These concerns relate both to the possible release of chemical agents through accidents and to potential health effects from continued exposure to low levels of gaseous emissions that could result from normal incinerator operations. Other concerns have arisen from possible adverse economic effects that a community might suffer from the presence of an incinerator.

In response to these concerns, the Stockpile Committee and the Army agreed in late 1991 that the matter of alternative technologies to incineration for the disposal of the chemical stockpile should be revisited. Consequently, the NRC Committee on Alternative Chemical Demilitarization Technologies (Alternatives

Committee) was established in early 1992. Then, in mid-1992, the Congress requested that the Army compare the baseline system with alternative technologies recommended by an NRC committee. Specifically, Public Law 102-484 (1992) required an evaluation of alternative technologies on the basis of safety, environmental protection, and cost effectiveness. Particular emphasis was placed on possible application at low-volume sites, that is, stockpile locations each holding less than 1,500 tons of chemical agent (NRC, 1993b).

The NRC Alternatives Committee evaluated about 25 alternative technologies (NRC, 1993b). The committee analyzed potential advantages and disadvantages of the technologies, but did not recommend any actions by the Army. Subsequently, the Stockpile Committee compared potential alternative technologies to the baseline incineration system, using minimization of total risk to the public as the prime criterion (NRC, 1994b). The committee confirmed its earlier recommendation that the baseline incineration system is safe and effective and recommended that the Chemical Stockpile Disposal Program continue on schedule with implementation of the system. The committee also recommended that the disposal program proceed expeditiously with research into neutralization as a possible technology for implementation at two bulk storage sites.

On the basis of information available at the time of the Stockpile Committee's 1994 report, no alternative disposal technology seemed to reduce agent-processing risk substantially at most sites. At two sites, however, neutralization-based alternative technologies appeared to have merit in terms of (a) safety similar to that of the baseline system, (b) possibly acceptable cost and schedule factors, and (c) potentially greater public acceptability. At these two sites—Aberdeen Proving Ground, Maryland, and the Newport Chemical Activity, Newport, Indiana—chemical agents are stored only in bulk containers. The disposal of agent from such containers is easier than from munitions containing propellants or explosives. In principle, a complete agent disposal system might be constructed at these sites without an incinerator. However, a disposal process for these two locations must consider management of the agent containers and nonprocess wastes (e.g., entry suits, analytical wastes) as part of the complete system. In the absence of adequate information on neutralization processes, the Stockpile Committee recommended that neutralization research be accelerated substantially.

In April 1994, the Department of the Army issued U.S. Army's Alternative Demilitarization Technology Report for Congress (U.S. Army, 1994a). A subsequent report (U.S. Army, 1994b) outlined an aggressive research and development program to evaluate two alternatives to incineration: “stand-alone” neutralization (for example, chemical hydrolysis) and neutralization followed by biodegradation. ² The program focuses on disposal of mustard agent and VX nerve agent, which are stored in bulk at the Aberdeen and Newport facilities, respectively.

After congressional approval, laboratory and engineering studies of the two neutralization-based technologies began in late 1994. The laboratory investigations produced encouraging results; engineering studies and scale-up experiments were focused on a small set of technical approaches. Work currently is centered on collecting the data needed to design the pilot-scale demonstrations of the VX and mustard disposal processes and to make a decision about building the necessary facilities. Because the construction and operation of a pilot plant might cost up to $200 million (U.S. Army, 1994a), the decision will be made by the Defense Acquisition Board of the Department of Defense.

The Army issued two drafts of the evaluation factors and assessment criteria that it contemplates using in the process leading to the Defense Acquisition Board decision. The initial draft, issued on December 7, 1994, was modified after review by the Citizens Advisory Commissions of Maryland and Indiana. The revised draft, dated April 26, 1995, provided the basis for the Stockpile Committee evaluation. Both drafts contain

discussions of the process and principles involved in the development of detailed criteria. ³

The starting points for the drafts were the legal and treaty requirements for irreversible agent destruction and for significantly greater safety, equal or better cost effectiveness, and the ability to complete the destruction process by December 31, 2004.

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's stated purposes for criteria development are (a) to provide bases for comparing alternative technologies; (b) to describe the selection process for public discussions; (c) to provide information for selection among technologies; (d) to provide feedback to the research, development, and engineering activities; and (e) to form a starting point for the design of a facility to implement agent disposal.

As stated previously, the Army report, U.S. Army's Alternative Demilitarization Technology Report for Congress, recommended research on two neutralization-based processes applicable for use at the Aberdeen and Newport sites. The recommendation for an intensive, focused research program was accepted by Congress and funds were appropriated to support an accelerated program of research, development, test and evaluation (RDT&E).

The Army's Product Manager for Alternative Technologies and Approaches (formerly the Applied Technology Branch), under the Office of the Program Manager for Chemical Demilitarization, has undertaken a focused program of research on the neutralization-based processes proposed for agent destruction. The program is intended to provide information needed to (a) decide whether these processes have significant merit for disposal of the agents stored at Aberdeen or Newport; and (b) provide the basis for design, construction, and operation of neutralization-based systems for disposal of mustard and VX agents. The time available for implementing the program is short, because of the constraint imposed by Congress that agent destruction is to be completed by December 31, 2004.

The decision about whether to construct a pilot-scale demonstration facility for a neutralization-based process is very significant because of the cost of construction and operation of the pilot facility. In addition, a decision to pilot will require redirection of the stockpile disposal plans at Aberdeen or Newport or both. The redirection also has the potential to extend the time required to complete disposal of the chemical agents at these sites, and this would entail continued risks and costs associated with agent storage.

The decision about whether to proceed with demonstration of an alternative technology is likely to be controversial because many see any alternative to incineration as highly desirable even though it may be difficult to confirm advantages in safety or environmental impact relative to the baseline system. The Army requested that the Stockpile Committee evaluate the criteria on which the decision to proceed with a demonstration disposal program using stand-alone neutralization or neutralization followed by biodegradation is to be based.

However, 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 specific to the evaluation of these programs were beyond the committee's current scope, but it was recognized by the committee and agreed to by the Army sponsor that many of the criteria could be applied to technologies other than neutralization. Criteria similar to those being developed for the Army's Chemical Stockpile Disposal Program may also be useful in the Russian Chemical Weapons Disposal Program, which may be financially supported by the United States.

The committee evaluated the Army's draft assessment criteria in light of input from many sources on the potential safety, health, environmental, and economic considerations of the alternative technologies. As the basis for its evaluation, the 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, regulatory organizations, community groups, such as Citizens Advisory Commissions, and interested individuals who live near the potential sites. Information obtained from these sources, as well as the generic technical requirements, led the committee to identify

four significant factors: process efficacy, process safety, schedule, and cost. These factors formed the basis for the committee's evaluation of the draft assessment criteria. They embrace the treaty requirement for irreversible destruction of agents; meet the public law requirements for safety, cost effectiveness, and ability to meet the schedule defined by the treaty; and address public concerns with regard to long-term health effects and adverse effects from the presence of a disposal facility.

In addition to the information sources discussed above, the committee 's judgments with regard to the adequacy of the Army's assessment criteria are based on its members' experiences in industrial process development and in oversight for the operational verification testing of the baseline system. The results of the committee's evaluation are presented in the following chapters.

Chapter 2 discusses the Army's Alternative Technology Research and Development program based on neutralization or neutralization followed by biodegradation of chemical agent residues. The principles and significant factors that should underlie the criteria for decision are presented in Chapter 3 , and the technical information necessary for decision-making is included in Chapter 4 . Chapter 5 evaluates the Army's draft criteria in light of the factors judged to be relevant and important by the committee. Chapter 6 summarizes the major findings arising from this evaluation and presents the committee's recommendations for modification of the draft assessment criteria.

This report also contains four appendices. Appendix A is an extract from Public Law 102-484; Appendix B contains a sample of the letter used to obtain public input to the evaluation and the list of letter recipients; and Appendix C contains the Army's assessment criteria. Biographical sketches of the members of the Stockpile Committee are provided in Appendix D .