Evaluation of the Army's Draft Assessment Criteria to Aid in the Selection of Alternative Technologies for Chemical Demilitarization (1995) / Chapter Skim
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5 SUMMARY AND EVALUATION OF THE ARMY'S CRITERIA DOCUMENT
5 SUMMARY AND EVALUATION OF THE ARMY'S CRITERIA DOCUMENT
Pages 25-38
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From page 25... ...
SUMMARY OF THE ASSESSMENT CRITERIA DOCUMENT The draft assessment criteria document consists of three substantive elements: a chapter describing how the assessment criteria were developed, a chapter summarizing the 10 basic criteria categories developed by the Army, and an appendix setting forth the assessment criteria formulated as 169 questions that the Army intends to use to decide whether to 25 implement an alternative technology. The Army's proposed assessment criteria are reproduced as Appendix C of this report.
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From page 26... ...
Public Law The Army will consider whether the alternative technology is significantly safer than the baseline system, is equally or more cost effective than the baseline system, and is suitable for completing stockpile destruction by December 3 I, 2004. The Anny draft assessment criteria EVALUATION OF ARMY DRAFTASSESSMENT CRITERIA document cites the National Research Council's 1994 report as indicating that no alternative can meet the requirements imposed by PL 102484 ARC, 1994b)
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From page 27... ...
Public Law 102-484 directs the Army to utilize an alternative disposal process at a site if it "is significantly safer and equally or more cost effective than the baseline disassembly and incineration process." The committee has interpreted "significantly safer" to mean reduction of total integrated risk to the public and to workers at a specific site. Thus, a disposal technology should be selected if it accelerates agent destruction and thereby reduces storage risk and cost—and if it does not increase risks during destruction.
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From page 28... ...
The treatment of this issue under evaluation factor 3.3.1 should be expanded to include air and water discharges, as suggested in the text of the assessment criteria document. Appropriate criteria should be developed to identify the risks associated with these process residuals and their ultimate disposal methods.
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From page 29... ...
These include on-site safety and health risks; community safety, health, and environmental risks; and storage risks. The Army's draft criteria examine many aspects of the safety issue—from the very broad question of whether the alternative technology is significantly safer than the baseline system (3.1.1.1)
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From page 30... ...
However, the criteria do not focus on whether any delay occasioned by implementing an alternative technology would result in a significant change in storage risk or whether any change would be offset by other factors associated with the alternative technology. In addition, the assessment criteria do not address the possibility of significant reduction of storage risk by early in situ detoxification of VX stored in bulk containers, as discussed in Chapter 2 of this report.
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From page 31... ...
Summary of the Discussion of Critical Factors Question In comparing the Army draft criteria document with the critical factors identified in Chapter 3 of this report, the committee found that the draft criteria document addresses most of the issues the committee considers to be important with respect to process efficacy, process safety, schedule, and cost. Many of the issues in these areas were covered quite thoroughly.
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From page 32... ...
In particular, the assessment criteria do not appear to recognize the possibility that alternative technologies may reduce storage risk, nor do they seek information on the potential schedule impacts of public opposition to a particular technology. With regard to monitoring issues, the assessment criteria are phrased In a way that does not allow for the possibility that monitoring needs for an alternative technology may be met by achievable advances in existing monitoring technology.
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From page 33... ...
3. Does the draft criteria document raise other issues with respect to the decision process regarding an alternative technology?
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From page 34... ...
Use of Information Nothing In the draft assessment criteria document indicates how the Army will use the information generated by the 169 assessment criteria to decide whether to demonstrate an alternative destruction technology. Describing a plan to use the answers to the questions posed by the assessment criteria is important to guide the decision-making process and to gain stakeholder understanding of the ultimate decision.
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From page 35... ...
A third effluent stream, the slag from the liquid incinerator, is not usually noted. A "level playing field" comparison of the baseline system versus an alternative technology must deal with aqueous effluent streams consisting of salts dissolved in water.
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From page 36... ...
, which apparently were suggested by the Citizens Advisory Commissions in Indiana and Maryland, are actuary directed to whether the alternative technology can destroy agent and can meet legal pennant requirements in the Citizens Advisory Commissions home states. While it is noteworthy that He Citizens Advisory Commissions regard these questions as the most important, these enters more appropriately belong in Be "Regulatory/Legal" basic category.
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From page 37... ...
The options for locating an alternative technology pilot plant are either at the Chemical Agent Munitions Disposal System (CAMDS) at Tooele Army Depot, Utah, or at Aberdeen for mustard and Newport for VX.
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From page 38... ...
The potential for extended use of a chemical demilitarization facility has been a concern to host communities. Facility decommissioning requirements and schedule may be significantly different for baseline system and alternative technology facilities.
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