The United States and other signatories of the Chemical Weapons Convention (CWC)1 have committed to destroying all declared chemical warfare materiel (CWM) by April 29, 2007.2 This materiel includes both stockpile materiel (all chemical agents and munitions available for use on the battlefield and stored at eight locations in the continental United States) and non-stockpile3 materiel, a diverse category that encompasses all other CWM, which includes other chemical munitions and containers of chemical agent. Much of this non-stockpile chemical materiel (NSCM) was buried at current and former military installations in 31 states, the U.S. Virgin Islands, and the District of Columbia (U.S. Army, 1996). Only a small fraction of buried NSCM in the United States has been recovered. Virtually all NSCM that has been recovered is stored at stockpile storage sites.
The Army’s baseline approach to destruction of stockpile CWM is to construct and operate state-of-the-art incinerators4 at stockpile storage sites. However, incineration at any location, as well as transportation of agent of lethal intent across state lines, has met with strong public opposition and is subject to increasingly stringent regulatory requirements. The U.S. Army has developed or is investigating a mix of
facilities and mobile systems that employ a variety of individual treatment technologies, including:
the Rapid Response System (RRS), a mobile system for accessing and neutralizing the contents of chemical agent identification sets (CAIS)5
the Single CAIS Accessing and Neutralization System (SCANS), a system for disposing of individual CAIS vials
the Explosive Destruction System (EDS), a mobile system for destruction of all but the largest (by size, volume of agent, or energy of dispersing charge) chemical weapons
the Donovan blast chamber (DBC), a system developed by a private company to treat conventional munitions, but which may have application to NSCM
the single-round container (SRC) and the multiple-round container (MRC) for moving chemical materiel to a more suitable location when necessary
two facilities, the Munitions Assessment and Processing System (MAPS) and the Pine Bluff Non-Stockpile Facility (PBNSF), based on cutting or drill-and-drain accessing of chemical agent, followed by chemical neutralization of agent and washing of hardware, arranged in a modular style and intended to process larger numbers of non-stockpile chemical weapons at a single site
stockpile facilities, an additional option for the destruction of NSCWM6 created in November 1999, when Congress amended the law to allow stockpile facilities to be used to destroy non-stockpile materiel
a tent-and-foam system for partially contained detonation of a chemical weapon judged too sensitive to move
various technologies that may be used to treat wastes resulting from the destruction of primary NSCM, known as secondary wastes
Before these systems can be operated, however, the Army must establish their technical effectiveness and safety, obtain the necessary regulatory approvals for operation at each site where NSCM is treated, and provide opportunities for public stakeholders to be involved in the decision-making process.
Accordingly, on March 16, 2001, the PMNSCM requested that the National Research Council (NRC) review the technical and operational plans for these facilities and mobile systems, make recommendations on their interrelationships, and assess the Army’s plans for obtaining regulatory approvals and for enhancing public involvement in the decision-making process.
STATEMENT OF TASK
To help optimize the technical performance, as well as the regulatory approval and public acceptance processes, of the Non-Stockpile Chemical Materiel Disposal program, the NRC will:
Evaluate mobile destruction systems and semi-permanent7 facilities being used or considered by the Army’s Non-stockpile product manager for the treatment of non-stockpile CWM and make recommendations on the systems and facilities that could be employed by the Army and their interrelationships. This analysis will specifically include consideration of issues and opportunities associated with the Explosive Destruction System (EDS), the Rapid Response System (RRS), the Munitions Assessment and Processing System (MAPS), the Pine Bluff Non-stockpile Facility (PBNSF), alternative treatments for neat chemicals, and selected aspects of the stockpile facilities.
Review and evaluate the issues and obstacles associated with the environmental regulatory approval process for successful employment of Non-stockpile Chemical Materiel disposal systems (mobile and semi-permanent) that the Army may encounter during its management of the Non-stockpile Program and offer recommendations that may make the regulatory approval process more efficient while reducing schedule risk.
Recommend areas in which further detailed study efforts would be particularly useful to the Product Manager.
Subsequently, it became clear to both the PMNSCM and the committee that the planning for the PBNSF and, to a lesser extent, the MAPS was not sufficiently evolved to allow an in-depth evaluation and analysis. At this writing, the PBNSF was still in the design phase, with key treatment technologies not yet selected; MAPS, while under construction, had not yet begun systematization and operational testing. Thus, the PMNSCM directed the committee to focus on the mobile systems and individual treatment technologies that will eventually be components of MAPS and PBNSF and to comment on how these components could be used efficiently in these two facilities.
This report begins by describing the non-stockpile chemical weapons materiel inventory, which contains unitary munitions and accessories dating back to World War I, binary munitions, and German munitions brought to the United States after World War II (Chapter 1). The non-stockpile inventory, which encompasses a greater variety of chemical agents than the stockpile inventory, includes blister, nerve, blood, and choking agents, as well as militarized industrial
chemicals and binary agents, and its condition is highly variable (some items have severely deteriorated during decades of burial).
The committee then assesses the tools, or specific options, available to PMNSCM to safely destroy these items. These tools, which include facilities, mobile treatment systems, and individual treatment technologies, are evaluated in Chapter 2 from the standpoint of their current status, as well as technical, regulatory, and permitting (RAP) and public involvement issues. The Army has prepared assessments of the potential health and environmental impacts of its transportable treatment systems (U.S. Army, 2001a), including risks during normal operations and from accidental release of hazardous substances. Similar site-specific assessments are generally required of the Army’s treatment facilities as part of the permitting process. The committee did not review the specific methodology or the regulatory assumptions used by the Army in assessing these health and environmental impacts because the overall risk assessment methodologies are of the kind typically used in U.S. regulatory and permitting programs.
In Chapter 3, the committee matches the treatment options with the materiel or munitions to be treated, identifies gaps in the program, and makes recommendations on the facilities, systems, and technologies. Chapter 4 examines RAP issues for waste management and identifies issues that, when resolved, will facilitate the RAP process in the future. Chapter 5 commends PMNSCM for its increased openness in providing information to a range of stakeholders and in developing relationships with them and notes areas that might be improved. Throughout the report, findings and recommendations follow each discussion. Appendix C evaluates the suitability of stockpile chemical disposal facilities for treating stored non-stockpile facilities. More detailed information about MAPS and PBNSF, two non-stockpile facilities, one under construction (MAPS) and one in design (PBNSF), is provided in Appendix D. Appendix E reviews the RRS and the EDS, two mobile systems for treatment of NSCWM. Appendixes F and G provide background information on regulatory and permitting issues and transportation of CWM, respectively.
Because the Army appears to be making excellent progress in destroying old production facilities, empty ton containers, and unfilled CWM delivery systems, these categories are not discussed in this report. Instead, the report covers subcategories of NSCWM whose destruction appears to pose the greatest challenges, including CAIS, recovered chemical munitions, binary CWM components, and chemical agent in bulk containers. Treatment of secondary waste streams generated in the treatment of this Non-Stockpile Chemical Warfare Materiel (NSCWM) is considered along with the treatment of primary waste.
The committee concurs with reports issued by other NRC committees (e.g., NRC, 1994) and reaffirms its own previous reports (e.g., NRC, 1999a)—namely that state-of-the-art incineration is safe and effective for the destruction of chemical weapons agent and energetics. However, the committee also recognizes that widespread opposition to incineration has led to considerable delays and additional costs. For that reason, it has worked with the Army to help evaluate alternatives to direct incineration.
The committee considered 10 categories of NSCWM that the Army currently faces or is likely to face in the future and examined the adequacy of the available treatment tools:
CAIS packages for in-transit gas shipment (PIGs)8
individual CAIS vials and bottles
small quantities of small munitions
chemical agent in bulk containers
binary chemical warfare materiel components
unstable explosive munitions that cannot be moved
secondary liquid waste streams
large quantities of NSCWM items currently in storage
large NSCWM items
large quantities of not-yet-recovered small munitions
The committee found that for the first seven categories, the Army has tools available or under development that should enable the destruction of NSCWM in an effective and timely way. However, significant additional investment or planning will be required to satisfactorily address the issues posed by the final three categories. Key recommendations relating to these categories appear below. The underlying discussions and findings, as well as additional findings and recommendations, appear in Chapters 1 through 5.
The following findings and recommendations do not in any way diminish the committee’s previous findings that state-of-the-art incineration is safe, robust, and effective (NRC, 2001a). PMNSCM has already invested considerable resources in developing treatment options to address many of the NSCWM treatment contingencies it may face. In some cases, this investment has yielded treatment systems that are ready for use; in others, treatment systems that are currently in the development pipeline should, upon completion, offer adequate capabilities.
The non-stockpile program also has available to it treatment facilities that were developed for the stockpile program, as well as commercial hazardous waste disposal facilities. To adapt these facilities for the treatment of NSCWM secondary wastes, equipment modifications or permit modifications may be required, but the technical feasibility seems
clear. The committee’s findings and recommendations relating to the 10 NSCWM treatment categories are discussed further below.
Ten Treatment Categories
Finding: The RRS is an expensive but adequate treatment system for CAIS PIGs and large numbers of loose CAIS vials and bottles. As other treatment options are also possible, this category appears to be well covered (Finding 2-7).
Individual CAIS Vials and Bottles
PMNSCM is developing the single CAIS accessing and neutralization system (SCANS) to treat individual CAIS vials and bottles recovered at remote sites. When fully developed, this system should be well suited to this task.
Recommendation: The committee recommends that PMNSCM continue to develop and optimize SCANS to increase the number of CAIS vials and bottles that can be cost-effectively treated with multiple SCANS units. If the development program results in a system that can be cost-effectively used for a large number of vials and bottles, the system should be fielded as rapidly as possible. This approach would allow reserving the RRS for treating very large numbers of CAIS and PIGs containing CAIS, which the SCANS cannot process (Recommendation 2-8).
Small Quantities of Small Munitions
PMNSCM has developed the transportable EDS9 as the workhorse system for destruction of both explosively and nonexplosively configured munitions in the field. The EDS-1 prototype was recently deployed to Rocky Mountain Arsenal, where it successfully destroyed 10 sarin bomblets. Improved versions of the EDS-1 as well as a larger EDS-2 are currently in development. Once these developments have been completed, it appears that this category will be well covered. The EDS system appears to be sufficiently flexible that it might also be used for other NSCWM treatment categories.
Recommendation: The committee recommends that the Army continue to implement the planned improvements of the EDS that increase explosive capacity and reduce processing cycle time. The Army should consider the applicability of the EDS as modules in facilities (Recommendation 2-5).
Chemical Agent in Bulk Containers
The non-stockpile inventory includes numerous containers of chemical agents of various types and sizes that have accumulated over the years. In general, these are stored at stockpile sites. There are many treatment options available for these bulk containers; the most obvious is to use the stockpile chemical disposal facilities (CDFs), although modifications may be required and permit modifications may be difficult to obtain.
In addition to the stockpile facilities, two experimental facilities have long been used to destroy a variety of chemical agents by chemical neutralization: these are the Chemical Transfer Facility (CTF) at Aberdeen Proving Ground, Maryland, and the Chemical Agent and Munitions Destruction System (CAMDS), at Deseret Chemical Depot, Utah. Although these are R&D facilities and therefore should not be used on a routine basis to destroy NSCWM, they might be considered as an option to destroy limited numbers of non-stockpile items that contain unusual chemical fills or that have a configuration that cannot be handled by other systems.
Further treatment options for non-stockpile bulk chemicals include direct destruction in a plasma arc system (see below) or even treatment in the EDS. With all of these options available, this category is well covered.
Recommendation: While recognizing that there are significant regulatory and public acceptability issues to resolve, the committee recommends that non-stockpile chemical materiel in bulk containers located at stockpile sites and suitable for destruction in chemical stockpile disposal facilities be destroyed in those facilities (Recommendation 3-1).
Binary Chemical Warfare Materiel Components
The entire non-stockpile inventory of binary CWM components is stored in canisters and drums at Pine Bluff Arsenal, a stockpile site. Options for treatment include destruction in the Pine Bluff Chemical Disposal Facility, direct destruction in a plasma arc system, or chemical neutralization followed by oxidative posttreatment of the neutralents. The high concentration of fluorine in the binary component DF raises concerns about corrosion in some treatment systems.
Recommendation: Additional testing of plasma arc technology should be done to ensure that proposed plasma arc
systems are capable of meeting requirements of the Environmental Protection Agency (EPA) and state requirements (Recommendation 2-10).
Recommendation: Ideally, the binary precursors methylphosphonic difluoride (DF) and ethyl-2-diisopropylaminoethyl methylphosphonite (QL) stored at Pine Bluff Arsenal should be destroyed directly, either by burning in the Pine Bluff Chemical Destruction Facility incinerator or by plasma arc treatment. If these facilities cannot handle the fluorinerich DF destruction products, the committee recommends that on-site neutralization followed by oxidative posttreatment of the neutralents be developed. The easiest posttreatment may be shipment to a commercial incinerator capable of dealing with high levels of fluorine (Recommendation 3-2).
Unstable Explosive Munitions That Cannot Be Moved
Open burning/open detonation (OB/OD) has been the traditional method of disposing of unstable munitions, including chemical munitions, but OB/OD is no longer considered acceptable for NSCWM by regulators except in emergencies. The Army has been exploring an alternative to OB/OD called the tent-and-foam system, which provides for partially contained detonation of unstable munitions.
Recommendation: The Army should complete the development and testing of the tent-and-foam system for controlling on-site detonation of unstable munitions (Recommendation 3-3).
Secondary Liquid Waste Streams
Treatment systems such as the RRS and EDS that rely on chemical neutralization of agents produce secondary liquid waste streams of two types:
neutralent waste streams consisting largely of organic solvents and agent neutralization by-products
aqueous waste streams, including rinsates, washes, and brine solutions
The Army’s plan for destruction of these wastes involves the collection of neutralized agent (neutralent), washes, and rinsates followed by treatment on-site or shipment to a commercial or federal treatment, storage, and disposal facility (TSDF) for final disposal. Disposal of these neutralents, washes, and rinsates would generally be by incineration. However, at least some of these liquids may be suitable for destruction by other technologies, existing or yet to be demonstrated. PMNSCM has undertaken a technology test program to test a large number of alternative technologies for destruction of these secondary waste streams.
Recommendation: The PMNSCM should continue its research and development program on chemical oxidation and wet air oxidation of neutralents and rinsates (Recommendation 2-12a).
Recommendation: Consistent with the committee’s earlier analyses (NRC, 2001a, 2001b), there should be no further funding for the development of biological treatments, electrochemical oxidation, gas-phase chemical reduction, solvated electron technology, and continuous SCWO technologies for the treatment of neutralents and rinsates. PMNSCM should monitor progress in technologies being developed under the Assembled Chemical Weapons Assessment (ACWA) program but should evaluate ACWA technologies for the treatment of non-stockpile neutralents and rinsates only if no additional investment is required (Recommendation 2-12b).
In the following areas, the committee judges the treatment options that are available or in the pipeline to be insufficient to permit the non-stockpile program to meet its goals. Additional investment or planning efforts are needed.
Large Quantities of NSCWM Items Currently in Storage
Some 85 percent of all recovered NSCWM in the United States is stored at Pine Bluff Arsenal. The Army has under design the Pine Bluff Non-Stockpile Facility (PBNSF) to destroy this material, with the assistance of an RRS and an EDS to treat CAIS and certain explosively configured munitions, respectively.
Recommendation: PMNSCM should develop a detailed, realistic timetable showing how the planned non-stockpile facilities at Pine Bluff Arsenal can achieve the throughput necessary to destroy the stored non-stockpile items by April 2007 and should communicate this timetable to all stakeholders (Recommendation 2-1).
Large NSCWM Items
Disposal of chemical projectiles larger than 155 mm and large (500 or 1,000 lb) bombs presents a special challenge to the non-stockpile program. Although such munitions are rarely recovered in the United States, they have been recovered as a result of U.S. activities in at least one foreign country, and it is likely they will be found on U.S. soil in the future.
Recommendation: PMNSCM should develop a strategy for treating chemical bombs and projectiles that are too large for treatment in the EDS, in the DBC (if successfully demonstrated), or in planned facilities. One option is to test the British drill-through valve (DTV) system, modify it if necessary, and prepare it for use on existing large NSCWM items and other such items that may be found in the future (Recommendation 3-4).
Large Quantities of Not-Yet-Recovered Small Munitions
Sites at which thousands of NSCWM items are believed to be buried present a special challenge to the non-stockpile program. Examples of such sites include Deseret Chemical Depot, Utah; Rocky Mountain Arsenal, Colorado; and Redstone Arsenal, Alabama. Use of one or even a few EDS units would be inefficient given their relatively low throughput capacity (currently one munition every 2 days). At present, the Army’s only option for cleaning up such a site would be the construction of a facility such as MAPS or PBNSF. However, such facilities are expensive and have a large environmental footprint. A transportable treatment system with a high throughput would be highly desirable to treat this category of NSCWM.
Recommendation: The non-stockpile program should continue to monitor the Belgian tests of the DBC. If the results are encouraging and it appears that the DBC can be permitted in the United States, it should be considered for use at sites where prompt disposal of large numbers of munitions is required (Recommendation 2-9).
Regulatory Approval and Permitting
Historically, establishing regulatory approval and permitting (RAP) requirements for new systems and technologies has been shown to be a resource-intensive and time-consuming process. Obtaining regulatory approvals is likely to be a critical factor in meeting the treaty deadlines for the destruction of NSCWM. Communication and cooperation with regulators (particularly state regulators), combined with an effective public involvement program, are essential for obtaining regulatory approvals in a timely manner. The committee urges the Army and states to enhance the existing cooperative efforts to define appropriate regulatory requirements for the technologies.
Communicate with Regulators
Recommendation: The Army should establish a prepermitting process to resolve RAP issues involving the Army, regulators, and the public for both mobile systems and non-stockpile treatment facilities. In addition, the Army should develop guidance on RAP for management of NSCWM. A guidance that is jointly issued by the Army and regulators, with input from the public, should be considered, and the committee recommends that it be of national scope (Recommendation 4-2).
Recommendation: The Army should examine funding provided to the states as part of existing cooperative agreements to ensure that they are sufficient to evaluate new or innovative NSCWM treatment technologies within a time frame consistent with CWC deadlines (Recommendation 4-5).
Recommendation: The Army and the states should continue to work together to achieve mutually acceptable regulations that define appropriate treatment for chemical agents and associated wastes. While state-specific treatment standards can be established, the committee recommends standards that are national in scope (Recommendation 4-6).
Develop Solid Working Relations
Recommendation: The Army should work with state regulators to tailor RAP mechanisms to the magnitude of the NSCWM recovery and treatment operations. For facilities, initial operations should be conducted under expedited RAP mechanisms (e.g., a Research, Development, and Demonstration permit); traditional Resource Conservation and Recovery Act (RCRA) permits, if necessary, should be employed after operations become routine. When mobile treatment systems or technologies are employed, and particularly for small or even moderate quantities of newly discovered NSCWM, expedited (non-RCRA permit) regulatory approval mechanisms under RCRA or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) should be used, as appropriate (Recommendation 4-1).
Recommendation: RAP for all of the Army’s chemical agent programs, including the non-stockpile program, should be seamless and transparent to the regulator and the public, who should “see” only one Army across all chemical agent programs at a specific location or operation. An installation-specific (or in the case of off-site NSCWM finds, operation-specific) core Army RAP team should be established for all chemical agent operations, including treatment of NSCWM. Installation or operation representatives should lead the RAP team at each location. The team should be directed by a central Army organization encompassing all chemical agent operations that require RAP so as to promote communication, continuity, and consistency among them. This organization should have the authority to establish RAP policy for all chemical agent operations nationwide (Recommendation 4-4).
Avoid Unnecessary Conservatism
Recommendation: The Army should reverse its classification of CAIS as recovered chemical warfare materiel (RCWM), thus avoiding additional time and cost for their destruction (Recommendation 4-3).
Recommendation: In states where secondary waste streams are regulated as acutely hazardous, the Army should work with state regulators to remove the designation “acutely hazardous.” For neutralents, the Army should work with state regulators to establish de minimis concentrations for the agents in waste streams, to be incorporated into the listing regulations, whereby the waste would no longer be considered as being associated with the parent agent waste. Further, the Army and the states should consider whether rinsates and cleaning solutions and residuals from the treatment of neutralent should be classified as hazardous waste at all (Recommendation 4-7).
Recommendation: Given the similarities between NSCWM secondary wastes and industrial hazardous wastes, the committee recommends that no additional prohibitions be placed on the off-site transportation of secondary wastes (Recommendation 4-8).
As noted in the committee’s three previous reports (NRC, 1999a, 2001a, 2001b), it is necessary and desirable that the Army proactively seek public involvement in policy decisions that once were considered to require only scientific judgment.
Recommendation: As with RAP activities, public involvement should appear seamless across Army programs and transparent to local and national stakeholders. The committee recommends that the Army establish central direction to ensure coordination of program and installation missions and to promote continuity and consistency in public involvement programs across installations and between program and installation staff (Recommendation 5-1).
Recommendation: The committee recommends that the Army expand its public affairs program to include involvement as well as outreach activities.10 Specifically, for the Army to gain from lessons documented in studies of the stockpile program, the committee recommends as follows:
The Army should direct installations to implement, in coordination with program staff, a strategy that includes development of public involvement mechanisms. Such mechanisms must be fully integrated with project schedules so that the public has a genuine opportunity to provide input to project decisions. Their goal must be to engage both the local public and other stakeholders in discussing and evaluating the various technologies being considered and to provide a continuing means of involving them in future planning efforts and project decisions.
The Army should conduct public involvement training for program and installation personnel, including commanders, public relations, and program technical staff. Such training must be more extensive than a one-day training course in risk communication and must be conducted very early in the program. The training should be provided on a continuing basis to ensure adequate preparation of newly assigned personnel.
NSCMP should consider how the program could more effectively use existing mechanisms, such as the Core Group, to include and engage citizens at the local, site-specific level as well as at the national level in identifying specific concerns and actively contributing to consideration of the trade-offs inherent in program decisions (Recommendation 5-2).