Defense Environment Alert
an exclusive biweekly report on defense policies for cleanup, compliance and pollution prevention


Vol. 12, No. 7--April 6, 2004


MERCURY CONTAMINATION PROMPTS MAJOR CHANGE TO TOOELE FACILITY

The Army plans to add a major, costly modification to its long-running chemical weapons incinerator in Tooele, UT, in order to prevent significant emissions of mercury when it bums mustard agent munitions and storage containers, the Army's Chemical Materials Agency (CMA) announced last week. The action would add an agent neutralization process and mercury filters onto the incineration plant.

The Army's discovery of significant levels of mercury contamination in some of the mustard munitions and storage containers stored at Deseret Chemical Depot prompted the re-design. While containers without mercury contamination will be incinerated as usual, those with mercury - a heavy metal - will be processed differently, CMA says in a March 29 press release. The re-design is necessary because these high levels of mercury would largely exceed the Army's permitted emission levels for its incinerator.

But citizen activists say the plan signals flaws with the incineration technology and provides support for citizens' legal arguments over the Army's compliance with waste characterization requirements.

The modifications will cost up to $55 million and require "unprecedented cooperation" between the facility's contractor EG&G and other chemical demilitarization contractors, CMA says. "It's a pretty significant effort and it'll be the largest facility modification effort ever in an active chemical weapons disposal facility," said Gary McCloskey, EG&G's vice president and technical director in a March 29 press release put out by CMA's Deseret Chemical Depot, UT. The depot stores the containers and munitions that are incinerated at the nearby Tooele Chemical Agent Disposal Facility.

CMA believes about 20-30 percent of mustard bulk containers stored at Deseret have high mercury levels in their liquid contents or in solidified heels, a CMA spokesman says. The Army believes the contamination stems from production activities at the Rocky Mountain Arsenal (RMA), CO. The mustard agent stocks at Deseret came from RMA, which apparently placed the agent in recycled bulk containers, some of which previously contained mercuric chloride. These containers, apparently, were not completely cleaned before reuse, the spokesman says.

Other incinerator plants could face similar problems. Mustard stocks to be burned at the Army's Umatilla facility in Oregon also came from RMA, and incinerators for facilities in Alabama and Arkansas could face these same challenges, the spokesman says. But he says their furnaces already are being evaluated for possible modifications.

Mercury is unlikely to be a problem for processing at the Army's Aberdeen, MD, facility, however, because the facility, which neutralizes the agent rather than incinerates it, does not have air emissions, the facility's stocks are not from the RMA inventory, and the Army already tests for mercury in the neutralized hydrolysate before it is shipped for secondary treatment. That testing has not yielded high levels of mercury, he says.

In Utah, the Army plans to add mercury filters to one of its two liquid incinerators, and will use a neutralization process and other filters to deal with the mercury contamination. Each item in the mustard stockpile at Deseret will be evaluated to determine if unacceptable mercury levels are present, the spokesman says. Those within permitted levels will proceed as usual through the incineration process. Munitions with high mercury levels will be drained and then washed out to remove the solidified heel. The drained agent will then be sent to the liquid incinerator equipped with mercury filters.

Meanwhile, the washout mixture, which still contains agent, will be neutralized and the mercury content filtered out into a sludge. The wastewater byproduct that results from neutralization will then be incinerated in the liquid incinerator equipped with the mercury filters, to capture any residual mercury. The remaining mercury-laden sludge, once neutralized of any chemical agent waste, will be disposed of by a permitted hazardous waste disposal facility.

A spokesman for the Chemical Weapons Working Group (CWWG), a citizen coalition that supports nonincineration chemical weapons destruction methods, says the Army's plan at Tooele is "another indication" that the incineration technology, as designed, "is not capable of dealing with existing stockpiles" of chemical weapons. And it shows the Army's failure to fully understand the characteristics of agents stored at all of its sites, which are fundamental issues in citizens' continuing legal challenges to the operation of incinerators at four sites.

This is a "strong indication that our legal challenges under [the Resource Conservation & Recovery Act] and [National Environmental Policy Act] are sound and legitimate," the source says.

The CWWG spokesman also questions the wisdom of incinerating the neutralized wastewater, noting the problems that arise in incinerating liquids, such as impacts to downstream pollution abatement systems and monitoring capabilities. The source also questions why the Army does not just neutralize all of the mustard containers, noting that it seems to be another example of the Army's "fall on our sword mentality of sticking with incineration."

The CMA spokesman does not expect the effort to cause much delay in the Tooele facility's processing schedule.  The Army first discovered the mercury contamination in the late 1990s. It began to see "minor traces" at the Army's Johnston Island facility, which has completed its destruction campaign. "It came to a fore in Tooele," the spokesman says. "We've been working for several years on solving this complex mustard processing problem simultaneous with other efforts to keep the disposal program moving ahead," he says in a written response to Defense Environment Alert.