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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program 2 Disposal Alternatives Chemical warfare materiel has been disposed of in various ways. Accepted practices once included open-pit burning, ocean dumping, and, most commonly in the case of CAIS, burial, either as-is or following field neutralization. Today these methods are not allowed, and other alternatives for CAIS disposal must be considered. (Recovered chemical warfare materiel that is too dangerous to transport because of its deteriorated condition can be disposed of on site. In these cases, personnel from the Army's Explosive Ordnance Detachment use explosives to destroy the materiel and consume the chemical agents.) The Army's baseline plan for the disposal of CAIS involves the RRS, a transportable disposal system that would be moved to CAIS recovery and storage sites. The primary treatment step would be chemical neutralization; in the present plan, this would be followed by commercial incineration of the neutralization wastes. The Army is continuing the development of the RRS and has recently been permitted to begin testing operations. At the same time, the Army has explored the use of commercial facilities for CAIS disposal. Commercial facilities could be less expensive than the RRS, particularly for recovery sites with small quantities of CAIS. The Army documented its findings on using commercial facilities in its report to Congress (U.S. Army 1998a). The committee evaluated both the RRS and the use of commercial facilities for CAIS disposal, as well as other disposal alternatives. ALTERNATIVES CONSIDERED The following CAIS disposal alternatives are shown in Figure 2-1: Do nothing. Gather CAIS and store indefinitely. Use the baseline, mobile RRS for on-site treatment. Use the RRS in a fixed location. Develop a modified RRS (similar to the Expedient CAIS Disposal System [ECS] or EDS). Dispose of CAIS in commercial facilities. Dispose of CAIS in Army stockpile disposal facilities. Do Nothing One obvious disposal alternative is to do nothing (i.e., to leave the CAIS items buried and unrecovered). This alternative is usually one of the baseline options for the
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program FIGURE 2-1 CAIS disposal alternatives. IHF = interim holding facility; RRS = Rapid Response System; ECS = Expedient CAIS Disposal System; TSDF = treatment, storage, and disposal facility; EDS = Emergency Destruction System. cleanup of most hazardous waste. In some instances, for example when long-standing contamination will be remediated through natural attenuation or if the contaminants are immobilized in a controlled, secure, monitored, and properly permitted landfill, a ''Do Nothing" approach may be a viable alternative to expensive remediation that would have limited long-term benefits. If the CAIS were known to be buried in controlled and monitored burial sites that would remain indefinitely under strictly enforced institutional controls, then a Do Nothing approach might incur less total risk (and especially less risk to soldiers and civilian workers) than recovery, treatment prior to transport, and final disposal. However, the Do Nothing option is not viable for CAIS disposal for the following reasons: Although the hazardous chemicals contained in CAIS may be remediated through natural attenuation when exposed to the environment, the chemicals are most likely to be found intact in their original glass vials or bottles, or even in their original shipping containers. These chemicals are likely to maintain their original chemical characteristics for the foreseeable future. (Although the plastic caps on some CAIS bottles have been known to degrade over time, allowing some exposure of their contents to the environment, some agents tend to form gels, which limit natural attenuation, when in contact with soil and/or subsurface moisture.) In many instances, CAIS are recovered on sites scheduled for release to civilian use or public access. Burial sites on property that is being developed by the public (e.g., former defense sites) could present health hazards to the local populace. These sites must be actively remediated to protect the community. Small accidental CAIS discoveries present a health risk to the untrained public and must continue to be actively treated as quickly as possible by Army Technical Escort Units.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Because the Do Nothing option is not a viable alternative for the known circumstances of CAIS discovery, the committee considered only CAIS disposal options. Gather CAIS and Store Indefinitely The Army could undertake an active program to locate and recover all known CAIS items and store them indefinitely at a permitted storage site, either as found or following preliminary treatment with currently available neutralization technology. While the CAIS are in storage, the Army could conduct research to develop new disposal technologies within the constraints of programmatic and CWC treaty deadlines. Upon discovery, the CAIS would be characterized, the chemical warfare materiel separated and repackaged, and all of the items sent to a permitted storage site for processing and destruction at some future time. If no permit modifications are necessary to bring newly recovered CAIS into the states involved and if current storage permits apply, the permitting costs should be minor. Transportation costs of moving recovered CAIS would be about the same as the costs of moving the CAIS to a fixed RRS. Additional storage costs would be incurred, however. The cost of continued storage of 10 PIGs containing CAIS items is estimated by the Army to be $300 per day (at Fort Richardson, Alaska; Pine Bluff Arsenal, Arkansas; and Deseret Chemical Depot, Utah).1 At that rate, storage costs would be more than $100,000 per year. The cost of identifying and characterizing CAIS materials, separating the' industrial chemicals from the chemical warfare agents, and repackaging would be the same as for the RRS alternatives. Issues of processing cost and cost recovery would not apply. Baseline Rapid Response System The Army's baseline approach is the RRS for on-site treatment of CAIS items. The RRS is a mobile unit designed specifically to dispose of CAIS items at the locations where they are found.2 The RRS operations unit contains a series of linked glove boxes3 equipped to remove CAIS ampoules and bottles from their packages, identify their contents, and then segregate and repackage CAIS containing industrial chemicals for off-site commercial disposal. Only CAIS containing sulfur mustard or lewisite would be treated in the RRS. Within the glove boxes, the glass containers are crushed in a reactor containing a chemical that rapidly neutralizes the chemical agent. The contents of the reactor (reagent, solvents, agent degradation products, and glass fragments) are then transferred to a sealed container for treatment at a commercial TSDF before final disposal. The RRS has recently been permitted by the state of Utah to begin an initial test program with both simulants and chemical agents at the Deseret Chemical Depot. Once the RRS has been successfully tested, operational deployments can begin. One site considered for an early operational deployment of the RRS is Fort Richardson, Alaska, 1 The basis for this estimate is not detailed in the report (see U.S. Army, 1997a). 2 For additional details, see Appendix C and the Internet web site for the NSCMP: <http://www-pmcd.apgea.army.mil/text/NSCMP/IP/FS/RRS/index.html>. 3 A "glove box" is a sealable container with transparent sides or observation ports. It has two or more access ports to which long rubber or plastic gloves are attached for manipulating items inside the sealed space.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program TABLE 2-1 Commercial Incinerator Facilities with Hazardous Waste Permitsa Operating Facilities Facilities Permitted but Not in Operation Facilities with Permit Applications Pending Safety Kleen (Laidlaw Environmental Services), Bridgeport, New Jersey Giant Cement, Harleyville, South Carolina Organic Incineration Technologies, Fairbanks, Alaska Safety-Kleen, (Laidlaw Environmental Services), Clarence, New Yorkb Reynolds Aluminum, Gum Springs, Arkansasc Grant County Waste Management, Beverly, Washington Allied Chemical, Birmingham, Alabamad American Envirotech, Channel view, Texas Scientific Ecology Group, Oak Ridge, Tennessee Safety-Kleen (Laidlaw Environmental Services), Roebuck, South Carolina (scheduled for closure) Houston Chemical Services, La Porte, Texas Thermal KEM, Rock Hill, South Carolina (scheduled for closure) GTX, Morgan City, Louisiana LWD, Inc., Calvert City, Kentucky Atochem, Carrollton, Kentuckye Chemical Waste Management (TWI), Sauget, Illinois Chemical Waste Management Chemical Services, Chicago, Illinois (scheduled for closure) Waste Research & Reclamation, Eau Claire, Wisconsin Ross Incineration Services, Inc., Grafton, Ohio
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program Operating Facilities Facilities Permitted but Not in Operation Facilities with Permit Applications Pending Waste Technologies Industries (WTI), East Liverpool, Ohio Rhone-Poulenc Basic Chemical Co., Baton Rouge, Louisiana Safety-Kleen, (Laidlaw Environmental Services), Coffeyville, Kansasf Safety-Kleen, (Laidlaw Environmental Services), Aragonite, Utah ICI, Joplin, Missouri Huges Environmental, Brookville, Mississippi Clean Harbors, Kimball, Nebraska Safety-Kleen, (Laidlaw Environmental Services), Deer Park, Texas Chemical Waste Management Port Arthur, Texas Safety-Kleen, (Laidlaw Environmental Services), Clive, Utah (scheduled for closure) a These commercially operated incineration facilities have permits to receive hazardous wastes (as defined by EPA) from other sites. Each facility has site-specific requirements imposed by EPA or a state regulator. Neither EPA nor the committee has evaluated whether any of the existing permits would allow or prohibit disposal of CAIS at that facility. The committee received information from an NRC report reviewer that many additional operating cement kilns have permits to incinerate hazardous waste. b Limited to ignitable, corrosive, and reactive wastes. c Limited to F088 waste streams. d Limited to wood-preserving and coal-tar wastes. e Limited to high-BTU and high-tin waste streams. f Pending permit application for new unit. Source: Updated from EPA, 1999, with information from an NRC report reviewer.
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program where seven PIGs containing CAIS have been recovered. The Army compared the estimated risks and costs of RRS deployment to Fort Richardson with the risks and costs of transporting the CAIS items from Alaska to Utah for disposal in the RRS (U.S. Army, 1997a). The committee discusses this cost analysis in Chapter 4. Fixed-Mode Rapid Response System The committee also considered the use of an RRS in a fixed mode at one or more regional sites. Recovered CAIS items would be sent to the RRS(s) for disposal at these sites. The operation of the RRS itself would be identical to the mobile RRS option, except that the startup and shutdown phases would be simplified because the unit would remain in place. The transportation phase would be eliminated. Because the CAIS rather than the RRS and its associated equipment would be transported, there could be differences from the mobile RRS in costs, permitting requirements, risks, and public reaction. Modified Rapid Response System Modified RRS equipment could also be developed. One example is the ECS, which the Army is considering (U.S. Army, 1998b). The ECS is essentially a mobile glove box that can treat loose CAIS vials not found in PIGS. Once CAIS are recovered, regulatory requirements mandate that they be disposed of in less than 90 days or that a storage permit be obtained. The ECS would be deployed to a recovery location where CAIS items would be disposed of in less than 90 days. Use of the ECS is intended to eliminate the need for a storage permit. A mobile glove box such as the ECS would not have the characterization capability of the RRS. Therefore, CAIS recovery, personnel (Technical Escort Units and the U.S. Army Corps of Engineers) would have to be equipped with portable Raman spectroscopy to identify and separate chemical warfare materiel from industrial chemicals in unearthed CAIS vials and portable isotopic neutron spectroscopy for identifying the contents of PIGS (see Appendix C for details). Commercial Disposal The Army outlined an approach for disposing of CAIS at commercial facilities in its report to Congress and in a supplementary technical report (U.S. Army, 1998a; Amr et al., 1998). Excerpts of the Army report are provided in Chapter 4, which focuses on the commercial disposal as presented in the Army report. A list of commercial incineration facilities for the disposal of hazardous waste is given in Table 2-1. Additional facilities at various industrial and government sites only treat on-site waste materials. As explained in the discussion of the study task (see Chapter 1), the committee discovered during its investigation of the commercial disposal option for CAIS that commercial facilities would probably use incineration-based disposal methods. Therefore, the committee focused its evaluation of the commercial disposal option on incineration. Commercial disposal could involve either incineration-based or nonincineration-based disposal technology. Nonincineration methods include neutralization, biodegradation, wet-air oxidation, supercritical water oxidation (SCWO), and possibly plasma arc or
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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program other thermal methods. Incinerators are defined in 40 CFR 260.10 as "any enclosed device that: (1) uses controlled flame combustion and neither meets the criteria for classification as a boiler, sludge dryer, or carbon regeneration unit, nor is listed as an industrial furnace; or (2) meets the definition of infrared incinerator or plasma arc incinerator." In an evaluation of nonincineration alternatives, it is important to consider the complete disposal system because in some cases an initial nonincineration step in the process is followed by an incineration step. Nonincineration-Based Stockpile Disposal Facilities The facilities being developed for the Chemical Stockpile Disposal Program, which are specifically designed to destroy chemical agent materials (see Chapter 1), offer some potential technological and economic benefits for CAIS disposal. However, many public and stakeholder groups are opposed to using stockpile facilities for other purposes, and current legal restrictions prohibit using them for the disposal of any other wastes, including CAIS or other non-stockpile chemical materiel. Furthermore, Army officials have publicly assured local residents living near stockpile disposal facilities that no other material will be disposed of at these locations. Thus, there are significant nontechnical prohibitions, which would have to be appropriately addressed through a public involvement program and congressional action, against the use of stockpile facilities for CAIS disposal. The stockpile facilities of interest to the committee are those that use nonincineration technology for destruction of sulfur mustard or lewisite. The Army already has a pilot-plant facility, the Chemical Agent Munitions Disposal System in Utah, equipped to dispose of lewisite in the small quantities found in CAIS. This facility and the neutralization facility planned for Aberdeen Proving Ground, Maryland, also have or will have technology to destroy sulfur mustard. A significant advantage of these sites is that their use would ensure the use of an acceptable method with good process controls and appropriate safety precautions (monitoring of workers and effluent streams, safe reception and unpacking operations, etc.). Nearby communities and other interested groups may be amenable to the use of these facilities for destroying CAIS found at that site or even CAIS found elsewhere in the same state. Transporting significant numbers of CAIS sets or items from out-of-state sites seems more problematic. ALTERNATIVES SELECTED FOR ANALYSIS After reviewing all of these alternatives, the committee chose to focus on the following technical options: (1) commercial disposal by incineration; (2) baseline, mobile RRS; (3) fixed RRS; and (4) nonincineration-based methods.
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