Review of the Army Non-Stockpile Chemical Materiel Disposal Program Disposal of Chemical Agent Identification Sets (1999) / Chapter Skim
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6 Conclusions and Recommendations
6 Conclusions and Recommendations
Pages 94-104
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From page 94... ...
A consistent approach to regulating CATS would be to classify the CAIS set or inclividual items from a set as a characteristic hazardous waste rather than as chemical warfare materiel or chemical agent. This approach is consistent with historical practice in environmental regulation, in which a waste is classified on the basis of the amount of chemical constituents it contains and the potential risks it poses.
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From page 95... ...
Transportability of RRS is a major advantage, but transporting and staffing costs are considerable; treatment of liquid wastes at commercial facilities adds to cost. Transporting CAIS to RRS with escorts is an added cost, but field staffing costs are lower; treatment of liquid wastes at commercial facilities adds cost.
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From page 96... ...
initial permitting. 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.
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From page 97... ...
. Sulfur mustard could be treated by the technology to be used in the chemical stockpile disposal facility being built at Aberdeen Proving Ground (Maryland)
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From page 98... ...
It is technically feasible to dispose of all CAIS items in commercial hazardous waste incineration facilities that have a permit specifically addressing wastes containing arsenic and that operate at the highest level of destruction and removal efficiencies for organic compounds. An example would be a permit specifying
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From page 99... ...
Recommendation 3. To provide a documented evaluation of the environmental and worker/public safety issues involved in the commercial incineration of CAIS, the Army should prepare a report that compares the relative risks to workers and the public of incinerating CAIS items with the risks to workers and the public of incinerating highly hazardous industrial chemicals at any facility proposed for CAIS disposal.
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From page 100... ...
A preliminary cost estimate developed by the Army and its contractor showed that commercial incineration of CAlS items could yield substantial cost savings compared with the RRS option. However, a number of items either were not included or were not adequately discussed in this preliminary cost estimate (e.g., permit modifications, transportation of CAIS items, packaging, agent monitoring and other facility modifications, and staff training)
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From page 101... ...
Conclusion S The commercial incineration option may encounter public opposition by various groups, which could lead to schedule delays and added costs similar to those experienced by the Chemical Stockpile Disposal Program.
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From page 102... ...
storage facilities to clarify their acceptance criteria for Chemical Agent Identification Sets or items from them. The project manager should also consider developing alternative storage facilities in case these facilities become temporarily unavailable.
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From page 103... ...
The neutralization-based technology planned for the facility at Aberdeen Proving Ground may be appropriate for the disposal of CAlS items containing mustard. The Army has explicitly promised concerned stakeholders not to seek to alter the federal law prohibiting the use of chemical stockpile disposal facilities for the disposal of other wastes, including CAIS.
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From page 104... ...
If the community agrees, which may be more feasible at facilities that use nonincineration technologies, the law prohibiting the use of chemical stockpile disposal facilities for any other purpose would have to be modified to allow CAlS disposal. An important current capability of the RRS is that it can characterize, separate, and repackage individual CAIS items.
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