Defense Environment Alert
June 4, 2002

ARMY EIS EVALUATES DESTRUCTION TECHNOLOGIES FOR KENTUCKY SITE

The Arrny has released its environmental impacts analysis examining four different technologies for destruction of stockpiled chemical weapons in Kentucky. None of the technologies are expected to breach emission standards or exposure levels for human health, the draft environmental impact statement (EIS) says.

The Army does not cite a preferred technology for destruction of chemical agent at the Blue Grass Army Depot. The Kentucky depot is one of two sites where Congress in 1996 barred spending appropriations on construction of a baseline incineration facility until the effectiveness of alternative demilitarization technologies had been examined. Those alternative technologies have now been tested, and the draft EIS compares the environmental impacts of three of them with the Arrny's baseline incineration process. The other technologies evaluated are: chemical neutralization followed by supercritical water oxidation (SCWO), chemical neutralization followed by SCWO and gas phase chemical reduction (GPCR), and electrochemical oxidation.

The Blue Grass stockpile consists of mustard agent in 155-millimeter projectiles, GB nerve agent in M55 rockets and 8-inch projectiles. and VX nerve agent in M55 rockets and 155-millimeter projectiles, the draft EIS says.

The Army May 30 gave notice of the draft EIS in the Federal Register. The notice is available on InsideEPA. com. See page 2 for details.

The draft EIS looks at numerous potential environmental impacts of constructing, operating and closing a facility using the four destruction technologies. In evaluating the effects on human health, the Army found that incineration, based on operating experience at other chemical agent incineration facilities, would not exceed emission standards or exposure levels. It says the most recent of these analyses. at Anniston, AL, resulted in lifetime cancer risks of less than one in one million, below EPA's target of one in one hundred thousand. "For non-cancer endpoints, the results were higher than the target criterion, but alternative scenarios (to modify operational time or remove mercury through the pollution abatement system) produced results at or below the target criteria," the document's executive summary says.

"Based on limited demonstration testing," the non-incineration technologies are also not expected to exceed emissions standards or exposure levels developed to protect human health and the environment, it says.

Operating the baseline incinerator will produce low air emission levels, but they aren't expected to exceed standards, the executive summary says. And air impacts from the non-incineration technologies "would be similar to but less than those from a baseline incineration facility," it says. Specifically in looking at air quality criteria pollutants, incineration will likely produce low-level emissions of nitrogen oxides, sulfur dioxide, carbon monoxide, large and small particulate matter, and volatile organic compounds, the summary says. No exceedances of National Ambient Air Quality Standards are expected, except for small particulate matter, for which background levels already exceed the standards, it says. Further, negligible levels of heavy metals would be emitted, it says.

In looking at air quality hazardous and toxic substances, the summary says the Army, during incineration, will monitor the destruction of polychlorinated biphenyls in M55 rocket firing tubes and make sure they're in compliance with Toxic Substances Control Act requirements. Carbon filter banks will mitigate emissions of hazardous air pollutants, including chemical agent, during process fluctuations, it further says. If these filters fail, less than 3 percent of the allowable concentrations of these pollutants for general public exposure would be emitted, it says. The other methods would have similar impacts, the summary says.

The neutralization methods with SCWO, and SCWO plus GPCR would generate the largest quantity of hazardous wastes, the document says. Baseline incineration would likely generate 25 percent less than those methods, and electrochemical oxidation about 80 percent less, it says. Neutralization with SCWO would produce about 4.320 tons of hazardous solid wastes, neutralization with SCWO and GPCR would generate about 4,550 tons, incineration would produce about 3,530 tons, and electrochemical oxidation would result in about 770 tons, it says.

Water use among the alternatives would vary. "Annual process water requirements for each alternative are 18, 6.3, 18, and I million [gallons/year] for baseline incineration, neutralization with SCWO, neutralization with SCWO and GPCR, and electrochemical oxidation alternatives, respectively," the summary says. The area's existing water supply would be able to fulfill these needs, according to the document.

If a large uncontrolled accident occurred during operations using any of the methods or under continued storage, "significant environmental and health effects could occur," the summary says. Examples would be a lightning strike to a storage igloo or an earthquake. Because of the larger inventory of agent, continued storage would provide the worst-case scenario in such an event, it says. Off-post fatalities, under worst-case meteorological conditions, could be in the thousands for any of the methods or continued storage.

But a spokesman for the Chemical Weapons Working Group (CWWG) is critical of some aspects of the draft EIS. The source says that the EIS' statement that non-incineration alternatives will have equal or less air emissions than incineration "gives the reader absolutely no information" upon which to comment on that particular aspect of operations. None of the alternatives will have air emissions as great as incineration, he says.

The source is also "extremely skeptical" of the document's projected hazardous waste generation numbers.

CWWG plans to closely examine the numbers for incineration to determine whether they are based on actual experience or on assumptions made without empirical data. CWWG has long advocated the use of non-incineration technologies to destroy chemical weapons.