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Disposal of Chemical Agent Identification Sets: Review of the Army Non-Stockpile Chemical Material Disposal Program
BOX 3-1 Case Study: CAIS Recovery at the Raritan Arsenal
A non-stockpile remediation action was conducted at the former Raritan Arsenal, New Jersey, from October 1995 through May 1996. Demilitarized and leaking chemical unexploded ordnance (UXO) and CAIS vials were discovered commingled at this site (DiMichele, 1999). The deteriorated and leaking UXO had contaminated more than 12 tons of soil with neat sulfur mustard and lewisite. The contaminated soil was treated on site by mixing it in a concrete mixer with a 10 percent calcium hypochlorite decontamination slurry solution for a minimum of 15 minutes. The treated soil was then packaged, shipped to a commercial disposal facility, and incinerated as hazardous waste.
Because of regulatory requirements, the intact CAIS vials containing sulfur mustard or lewisite were handled very differently from the soil. Because these vials are categorized as chemical warfare materiel, they were packaged in a protective overpack by personnel from the Army's Technical Escort Unit, temporarily stored in an interim holding facility, and then shipped to the Army's facility at Pine Bluff, Arkansas, where they are currently being stored, while awaiting disposal by the RRS or an alternate disposal method.
This case study demonstrates the inconsistency of the current regulatory requirements. Pure mustard agent that has leaked into the surrounding soil, which is extremely hazardous, can be treated on site and sent to a commercial hazardous waste incinerator for final disposal. CAIS in intact vials, which are by comparison easy to overpack and ship and were originally developed for use in training exercises, are subject to more stringent requirements. Had the CAIS vials been broken or leaking, the remains of the vials and the contaminated soil could have been shipped and disposed of in a commercial incinerator as hazardous waste contaminated media. If existing regulations were changed, intact CAIS sets or items could be handled in the same manner as leaking CAIS items and contaminated soil.
hazardous waste disposal requirements to be appropriate for handling CAIS chemicals safely. Furthermore, the permitting process under RCRA allows location-specific and chemical-specific conditions to be developed and made legally binding. Therefore, although CAIS may be stored, disposed of, or treated at a federally permitted hazardous waste TSDF, additional permitting requirements may also be imposed because of the specific characteristics of this waste.
In summary, the statutory and regulatory requirements under which CAIS are now treated as chemical warfare materiel were designed for munitions configured with agent and explosives or for large quantities of chemicals in bulk containers. The federally mandated system for cradle-to-grave handling, transport, and disposal of hazardous wastes already applies to CAIS chemicals and, in the committee's view, is a far more efficient and effective framework for CAIS disposal that would provide the same level of protection to workers, the public, and the environment. Shifting the framework controlling CAIS disposal from that of munitions and chemical weapons to one of characteristic hazardous waste under RCRA would therefore be reasonable and desirable. This shift may be feasible through a review and change in the Army's interpretation of the statutory language, or it may require clarification or amendment of that language by Congress.
Besides legal and regulatory requirements, the two principal components of CAIS, sulfur mustard and lewisite, which are currently classified as chemical warfare agents, are subject to administrative controls called "surety." Surety procedures ensure the safety,
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