Review of the Army Non-Stockpile Chemical Materiel Disposal Program Disposal of Chemical Agent Identification Sets (1999) / Chapter Skim
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4 Review of the Commercial Incineration Option
4 Review of the Commercial Incineration Option
Pages 53-74
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From page 53... ...
Table 4-l contains the committee's summary evaluation of the commercial disposal option, assuming that incineration is the technology employed. TECHNOLOGY Excerpts from the Army's Report to Congress 3.1 Treatment Technology This study assessed the capabilities of five commercial facilities using three treatment technologies incineration, neutralization, and a transportable gas phase chemical (hydrogenbased)
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From page 54... ...
Risks generally known and understood for commercial facilities; CAIS chemicals seem similar to other hazardous chemicals currently being incinerated; risks to workers in receive/unpack areas should be analyzed. Perceived public health issue concerning chronic risks from incinerator emissions; transporting large numbers of CAIS, or CAIS types containing large volumes of agent, may be an issue; priority should be on allocating resources for public involvement.
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From page 55... ...
At this time there are no known technical limitations that would prevent effective destruction of all CAIS materiel in commercial facilities, either incineration or non incineration based. Several commercial disposal facilities indicated a capability to destroy CAIS using procedures now in place for materials having comparable or more complex 55
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From page 56... ...
13) Committee Evaluation of Technology The Army's conclusion that technical limitations would not prevent the effective destruction of CAlS materiel in commercial facilities may be correct, especially for sulfur mustard.
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From page 57... ...
.2 Based on laboratory-scare experiments, lewisite appears to be as easy to burn as sulfur mustard (Brooks and Parker, 1979~. Although lewisite has only been burned on a modest scale in chemical weapons disposal operations (Petrov et al., 1998)
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From page 58... ...
However, in all these cases, continuous air monitoring for CAIS agents should be used in the receiving/unpacking area to ensure that workers are not exposed to unsafe levels of agent vapor. The Automatic Chemical Agent Monitoring SYstem (ACAM:S)
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From page 59... ...
The existence and conduct of this study have been briefed to and discussed with members of the public and Tribal, State, and Federal regulators in open forums, however, and venues are open for further discussions following this preliminary study. As stated above, with the exception of the hydrogen reduction system, all commercial facilities in this assessment are currently permitted (the hydrogen reduction system was permitted in a previous operation)
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From page 60... ...
Prices for commercial destruction of CAIStype material can be as low as a few dollars per pound, before the costs associated with the additional requirements identified in this report are imposed. While government equipment such as portable spectroscopy systems may be required at all burial remediation sites as appropriate due to the need to characterize and re-package CAIS components prior to shipment, the use of commercial facilities for ultimate destruction still offers substantial cost benefits.
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From page 61... ...
For example, the interviews with commercial firms did not address the costs of adding agent monitors and alarms for detecting agent leaks, costs of training workers to handle agent, costs of personal protective equipment and decontaminating it, costs of a public involvement program, costs of obtaining permit modifications to allow CAIS to be received and destroyed, reporting costs to state regulatory agencies, and possible costs of plant modifications, such as an unpack area for receiving CANS. The companies appeared to consider the processing of CAIS chemicals as comparable in cost to the disposal of other reactive hazardous wastes that they were permitted to process.
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From page 62... ...
Transportation of CATS to a Commercial Facility Assuming that the commercial transport of CAlS from a discovery site to a commercial facility is possible and that the carrier is not required by permit or law to follow unique procedures, with substantial cost implications, for transporting hazardous materials, transportation costs should not be a major component of CAIS disposal costs for a commercial firm. The issue of who would incur the cost of transporting CATS materials from the discovery site to the commercial disposal facility (the Army, a commercial carrier, or the disposal firm)
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From page 63... ...
If the CAIS items were characterized in the field, sorted into industrial chemicals and chemical agents, and then placed into "labpacks" or other overpacks by Army personnel, and if these costs were borne by the Army, this would reduce the costs of processing by commercial firms. The general question of when a commercial firm's responsibilities and costs would begin (upon CATS discovery, at the discovery site following Army characterization and packaging, or at the plant gate)
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From page 64... ...
Processing Rates Although cost is not directly proportional to the processing rate, the processing rate can affect the economic desirability of commercial processing. The commercial firms interviewed indicated that if CAIS were categorized as a hazardous waste that they were currently permitted to handle, they could commingle the CAIS items with other similar wastes; thus the cost of processing the CAIS would be negligible.
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From page 65... ...
This possibility should be explored in further discussions with commercial hazardous waste disposal firms. Recovery of Overhead and Development Costs In the interviews conducted with commercial firms, the costs of the design, engineering, fabrication, and upkeep of disposal facilities were not included in the cost estimates.
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From page 66... ...
However, because existing commercial facilities would be used, it is reasonable to assume that the risks of handling highly hazardous materials are already well known, well understood, and accounted for in the basic operations of these facilities. Depending on the facility, some hazards associated specifically with CAlS chemicals, such as the handling hazards mentioned above, may require additional risk analysis and facility preparation.
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From page 67... ...
4. The Army's public notification process is a potential deterrent for the commercial hazardous waste facilities that participated in this study.
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From page 68... ...
However, the report does acknowledge that public acceptance is one of the issues that must be resolved before a final determination is made to pursue the commercial disposal option. It also notes that "in general, the facilities are concerned about their public outreach efforts," and "if public notification is required, some TSDFs will withdraw from consideration." The report does not indicate how the proposed commercial disposal option is linked to broader, Tong-term program goals.
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From page 69... ...
Populations near an existing commercial disposal facility, near a site where CAlS are found or currently stored, or along proposed transportation routes will see themselves as affected because of
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From page 70... ...
Local and tribal populations can be categorized by location: near CAIS discovery sites; adjacent to transportation routes (if transportation of CAIS by private companies is legally acceptable) ; and near a commercial disposal facility.
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From page 71... ...
Key issues previously raised by these groups include potentially hail environmental and health effects from incinerator emissions, the assessment of incinerator emissions on the basis of Dial burns rather than real-time monitoring, and the presence of hazardous residues in the ash. The most serious concerns raised in the past have been the negative environmental and health effects of air emissions in particular, emissions of PCBs, dioxin, and dioxin-like compounds whose Tong-ter~n effects, singly or in combination, are uncertain or unknown.6 More recently, the Non-Stocl~ile Chemical Weapons Citizens Coalition has called into question the Army's previous estimates of the human toxicity of chemical agents and requested a 4Committee discussions with stakeholders from Pine Bluff, Arkansas and Tooele, Utah..
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From page 72... ...
Groups that share this attitude toward CATS disposal options are likely to take steps to prevent setting a precedent for incineration, based on their belief that delaying the disposal of CATS or of residual CATS wastes does not pose high risks and that it is better to wait for the development of a more acceptable technology than to choose incineration by default.~° From their perspective, the development of nonincineration technologies by the ACWA program holds out the hope that nonincineration technologies can be used for both the stockpile and non-stockpile programs, as well as for the disposal of other hazardous wastes nationwide. Commercial Disposal Facilities.
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From page 73... ...
First, CAlS are classified as lethal chemical agents that are subject to 50 USC 1512 and, therefore, subject to stringent requirements for transportation, disposal, and handling. Attempts to change existing laws and regulations to reduce the complexity and cost of commercial disposal (as suggested by Amr et al., 1998)
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From page 74... ...
One of the most significant parties will be the commercial firm. Given the relatively small amount of business and the potential for public controversy associated with the disposal of any chemical warfare materiel, commercial firms may not find CAlS disposal to be an attractive business option.
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