Review of the Army Non-Stockpile Chemical Materiel Disposal Program Disposal of Chemical Agent Identification Sets (1999) / Chapter Skim
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Executive Summary
Executive Summary
Pages 1-10
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From page 1... ...
When the study committee reamed that commercial facilities would probably dispose of CAIS by incineration, it decided to evaluate nonincineration aTtematives to incineration that would be consistent with the congressional mandate for reducing program costs, as well as evaluating incineration at commercial facilities. Nonincineration methods would address the concerns of some public groups, including some stakeholders from communities near CAIS sites, that oppose the use of incineration for destruction of any chemical warfare materiel, including CAIS.
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A consistent approach to regulating CAlS would be to classify the CAlS set or individual 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 3... ...
It is technically feasible to dispose of all known 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 destruction and removal efficiencies similar to those required for commercial incineration facilities permitted to treat nitrogen mustard, polychiorinated biphenyls, or dioxins.
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relative to highly hazardous industrial chemicals (e.g., agent-contaminated materials, highly toxic industrial chemicals, polychiorinated biphenyls, medical wastes, and other hazardous military wastes) that are routinely destroyed in commercial incineration facilities; (2)
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From page 5... ...
A preliminary cost estimate developed by the Agony and its contractor showed that commercial incineration of CATS 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 CAlS items, packaging, agent monitoring and other facility modifications, and staff training)
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From page 6... ...
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. Unfortunately, the Army's report to Congress did not include a detailed analysis of public acceptability issuesincluding how CATS disposal would be related to the overall strategy for the disposal of non-stockpile materiel from the public's perspective.
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From page 7... ...
NONINCINERATION-BASED OPTIONS Conclusion 12. The Army's Alternative Technologies and Approaches Program and Assembled Chemical Weapons Assessment Program have~ identified several nonincineration technologies for the disposal of chemical warfare agents, including sulfur mustard and possibly lewisite.
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From page 8... ...
The neutralization-based technology planned for the facility at Aberdeen Proving Ground may be appropriate for the disposal of CAIS 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 9... ...
The Army should develop, review with stakeholders, and then implement a written plan for public involvement designed to reach a range of stakeholders and concerned groups, including affected communities and tribal nations, state and federal regulators, concerned national and regional groups, and representatives of the waste disposal industry. In states with a chemical stockpile disposal facility, the Army should engage the affected communities in a discussion of alternatives, including the potential use of the stockpile facility for CATS disposal.
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