Review of the Army Non-Stockpile Chemical Materiel Disposal Program Disposal of Chemical Agent Identification Sets (1999) / Chapter Skim
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3 Issues to Consider
3 Issues to Consider
Pages 38-52
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From page 38... ...
TECHNOLOGY The major technical challenge is to establish that a disposal process can destroy chemical agents safely, reliably, and effectively and that the destruction products can be disposed of safely, reliably, and effectively. Process Reliability and Effectiveness Any CAlS disposal method must demonstrate the capability of (~)
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From page 39... ...
A second issue is that two CAlS chemicals, sulfur mustard and lewisite, are classified as chemical warfare agents, while other CAlS chemicals are classified as industrial chemicals and hazardous waste. A third issue for CAlS disposal is that Army facilities built for the Chemical Stockpile Disposal Program are prohibited by federal law from being used to dispose of any materiel in the "non-stockpile" category, including CAlS sets, items, or chemicals.
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From page 40... ...
In surnrnary, the statutory and regulatory requirements under which CAlS 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 CAlS 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.
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From page 41... ...
Typical CAIS recovery sites, which involve multiple CAIS items, would far exceed these exemptions. Reportedly, some individuals have recognized the apparent inconsistency in the surety requirements between as-produced CAIS and buried/recovered CAIS, which may be as potent as the original CAIS chemicals.
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From page 42... ...
The cost of transport, as well as of segregating, characterizing, and repackaging recovered CAIS items are typically borne by the commercial hazardous waste disposal firm. In addition to the federal regulations for the transport of hazardous materials, state permitting authorities may impose additional requirements, which could increase costs.
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From page 43... ...
For CAlS disposal using commercial facilities, operating costs depend on the quantities of CAlS materials received, the costs of waste characterization, the operator's ability to process CATS items with other hazardous wastes rather than separately, facility preparation costs, specialized handling requirements, taxes and fees, waste stream disposal, facility decontamination (if required) , and direct labor and overhead associated with CAlS disposal.
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From page 44... ...
In Figure 3-1, the acute lethal concentrations of nitrogen mustard and other highly hazardous industrial compounds are compared with those of the chemical warfare agents GB, sulfur mustard, lewisite, and other CAIS components (cyanogen chloride and chIoropicrin)
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From page 45... ...
Lew~site is the sixth most toxic compound. Thus, the lethalities of the chemical warfare agents present in CAlS are equivalent to or greater than the lethaTities of these highly hazardous industrial chemicals.
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From page 46... ...
. If CAlS components continue to be classified as lethal chemical warfare agents, they will be subject to 50 USC 1512, in which case, the Army has defined the transportation requirements (Fatz, 1997~: Recovered non-stockpile CWM [chemical warfare materiel]
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From page 47... ...
Because the collection of original data on public views specific to CAIS disposal was beyond the scope of this study, the committee has heard from only a segment of the interested public and has not conducted an exhaustive survey. Although the committee s statements reflect that limited input, they are also based on the extensive experience of committee members and a body of literature, cited in the text, that documents public opposition to incineration and public views on alternative technologies.
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From page 48... ...
In assessing the relative acceptability of policy options, it is necessary to identify the particular publics involved, the issues that are important to them, their ability to influence policy, 4The NRC recently released a report on alternative (nonincineration) technologies for destruction of assembled chemical weapons (NRC, l999b)
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From page 49... ...
Among these groups were local, grass roots groups opposed to having a hazardous waste or municipal waste incinerator in their communities; established environmental groups, such as the Sierra Club, Friends of the Earth, and Greenpeace; and groups opposed to the incineration of chemical weapons in particular, such as the Chemical Weapons Working Group and, in the 1990s, the Non-Stockpile Chemical Weapons Citizens Coalition. Health-related concerns about emissions and/or formation of dioxins and furans that emerged in the 1980s have expanded and now include questions about the validity of Army estimates of the toxicity of chemical agents.
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From page 50... ...
A similar role is currently being played by the Chemical Weapons Working Group and the Non-Stockpile Chemical Weapons Citizens Coalition. Resolve the Issues Although the public acceptability of a disposal alternative can only be determined by the participants, a preliminary assessment of issues and Stakeholders can indicate how these issues may be resolved.
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From page 51... ...
The goal of this involvement program is to develop decisions that are publicly acceptable, as well as technically sound.s Although the mobile RRS, which is the baseline technology for CAIS disposal, uses neutralization as the primary technology, a nonincineration technology is not yet available for the disposal of RRS process wastes. The Non-Stockpile Chemical Weapons Citizens Coalition has expressed its desire that the Army use technologies other than incineration for the treatment of secondary wastes.6 However, it is not known when nonincineration technologies will become available, and there is no consensus among stakeholders on whether it would be preferable to store the wastes in the interim or dispose of them at existing incineration facilities.
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From page 52... ...
Army Corps of Engineers, the NSCMP, or the base commander. For example, who will pay the costs of commercial disposal of CAIS items found on an active or inactive military base?
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