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Comments and Recommendations on the Mitretek Assessment of ACWA Technologies for Treatment of Non-Stockpile Wastes and Chemical Materiel

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Comments and Recommendations
on the Mitretek Assessment of
ACWA Technologies for Treatment of
Non-Stockpile Wastes and Chemical Materiel

Non-Stockpile Chemical Weapons Citizens Coalition
November 1999

Background

Ever since the U.S. Army revealed its plan to dispose of the nation's stockpile
of chemical weapons, citizens living in communities near the weapons storage
sites have been concerned with the issue of how the weapons will be
destroyed. The Program Manager for Chemical Demilitarization's (PMCD)
proposed disposal technology, incineration, was unacceptable to nearby
communities. Incineration was known to release hundreds of toxic chemicals,
including live chemical warfare agents, out of the smokestack thereby posing a
risk to public health.

Due primarily to a decade of grassroots and political pressure, the Army and
private industry have made significant strides in the development of non-
incineration technologies which have the capability to destroy chemical
weapons while containing toxic by-products until they have been determined
acceptable for release into the environment. In 1996, Congress mandated the
creation of a program to identify and demonstrate of at least two non-
incineration technologies for chemical weapons disposal. This program, called
the Assembled Chemical Weapons Assessment (ACWA), included a dialogue
process by which affected citizens, state regulators and Department of Defense
officials cooperatively created technology selection criteria. A total of six
technologies passed ACWA's stringent selection criteria, and thus far three of
those technologies have been demonstrated. The remaining three will likely be
demonstrated in 1999-2000.

The Army's Non-Stockpile Chemical Materiel Program (NSCMP), having also
been forewarned by citizens that incineration is a publicly unacceptable
technology, is investigating the applicability of ACWA technologies for disposal
of non-stockpile materiel and residuals from primary non-stockpile treatment
processes. In 1999, Mitretek Corporation assessed the potential of various
ACWA technologies to meet the unique disposal needs of the NSCMP.

The Non-Stockpile Chemical Weapons Citizens Coalition (Coalition), a grassroots
network of concerned citizens living near known and suspected non-stockpile
sites in the U.S., advocates the use of safe, non-incineration technologies for
the disposal of non-stockpile materiel and its residual wastes, and citizen
involvement in choosing these disposal technologies.

General Comments

1. The report was not distributed to citizens in a timely manner.

The Report was released in May/June 1999 yet citizens did not receive a hard
copy until August 1999. Understanding that administrative delays occur, NSCMP managers were aware that citizens involved in the "Forum" as well as
the Coalition wanted the information as soon as possible. Providing at least a
written commitment to distribute the report would have been a simple,
courteous gesture.

2. There were few to no opportunities for citizen input to the Report, particularly regarding technology selection criteria.

Ironically, while Mitretek used selection criteria developed by the Assembled
Chemical Weapons Assessment (ACWA), created cooperatively with citizen
input, it altered the criteria for the non-stockpile assessment without citizen
input. Mitretek and NSCMP again knew that a group of citizens -- some with a
great deal of background with the ACWA program and other assessment
processes -- was willing and available to work cooperatively to review such
criteria, yet we were not consulted. Thus, Report references made to citizen
input are misleading as input only occurred at the vendor interview stage.

The opportunity for such input still exists (see recommendation #2) and
Coalition members again affirm our willingness to review technology criteria
and other assumptions for this and other future technology assessments.

3. Results from the ACWA program process and recommendations from the September 1999 ACWA Supplemental Report to Congress should be reflected in the Report, and should continue to be taken into serious consideration by NSCMP.

The ACWA program has, in the eyes of affected citizens, regulators and DOD
representatives participating in the process, been a success. NSCMP, to its
credit, has thus far sought to benefit from results of ACWA technology
demonstrations. The Coalition encourages continuing the relationship between
ACWA and NSCMP, and concurs with many recommendations from the ACWA
report. In particular, we encourage NSCMP to support the following, listed as
Recommendations for Continuity of the ACWA Program:

  • pursuing implementation of technologies that have been successfully demonstrated;

  • completion of additional demonstration of technologies which passed selection criteria;

  • demonstrations of unit operations submitted through the BAA;

  • continuation of the tradition of intensive public involvement in DOD programs;

  • consideration of using combinations of unit operations for destruction of materiel; and

  • encouraging the application of ACWA technologies for use in other clean-up and waste management programs.

    Technology-specific comments

    1. NSCMP should reject the use of incineration as a technology for any phase of chemical materiel destruction.

    The Report notes that the General Atomics and Parsons/Allied Signal processes
    would use incineration to dispose of certain items. The Coalition has
    consistently stated its opposition to the incineration technology. Communities
    across the U.S. have rejected commercial incinerators as a viable waste
    disposal technology, and industry is responding by withdrawing plans for new
    incinerator complexes. NSCMP should learn what private industry already
    knows, and should not rely on incinerators for any portion of a near-, mid- or
    long-term solution.

    2. The resource requirements and transportability factor criteria, taken out by Mitretek, are important criteria to citizens and public officers. These factors should be re-inserted into the Report and the technologies should be re-calculated accordingly.

    3. Some Assessment Results regarding public acceptance are inconsistent with citizens' and the results from ACWA demonstrations.

  • Both Eco Logic and General Atomics were found to have "good" public
    acceptance. The Coalition concurs that both of these technologies rank
    high in terms of public acceptance. However, Eco Logic may have an edge
    over General Atomics based on a history of good standing with a number of
    communities facing waste disposal problems. For example, some well-
    respected public interest scientists have stated their approval of the Eco
    Logic system. In addition, Eco Logic's experience with Department of
    Energy programs, and the fact that Eco Logic has been in commercial
    operations for years, should have resulted in a higher rating for process
    maturity.

  • The fact that General Atomics was accepted by the Newport, Indiana
    community is important but must be considered in light of the fact that the
    community was faced otherwise with the threat of an incinerator, and was
    not presented with a range of other technology options.

  • The Parsons/AlliedSignal technology should be more closely scrutinized in
    terms of public acceptance. The company's unwillingness to publish
    information in the Report, thereby not providing citizens with valuable
    information, should have negatively affected their ranking in terms of public
    acceptance. On the other hand, the recent vote by the Colorado Citizens
    Advisory Commission recommending this system for treatment of the
    chemical weapons stockpile in Pueblo may positively affect the public
    acceptance ranking.

  • It does not make sense that General Atomic was rated higher than Eco
    Logic in terms of off-site transportation accidents if the hydrogen is going to
    be produced on site or purchased locally, considering Eco Logic's proven
    track record of transportability. In addition, there is no explanation for why
    General Atomics is rated higher for RRS and MMD process waste than for
    NSCM waste in this category.

  • Based on the inability of the Burns & Roe technology to demonstrate well
    through the ACWA program, and the fact that the system produces dioxins
    and furans, the assumptions in the Report are inaccurate. Due to technical
    problems in demonstration, and the public perception that the plasma
    waste converter (PWC) technology is disturbingly similar to incineration,
    ACWA Dialogue members stated clearly that the system is highly unlikely to
    meet public acceptance. The Coalition concurs.

  • Generally speaking, the weight that public acceptance can bear in the
    technology decision-making process should not be underestimated. Higher
    levels of public acceptance can directly and positively affect cost and
    schedule estimates.

    4. Product estimates were given too little attention in the Report.

    Process by-products received little attention in the Report, apparently due to a
    lack of information. This is acknowledged in the Report. However, as the
    evaluation moves forward, by-products should be a primary consideration in
    technology assessment. This approach would be consistent with the Federal
    Government's mandate to aim for pollution prevention.

    5. Specific comments on technology systems:

  • The Burns and Roe Plasma Waste Converter (PWC) seems to base many of
    its safety assumptions on the fact that it operates at negative pressure. See
    for example page 5-19. This negative pressure assumption has proven to
    be extremely faulty for the baseline stockpile systems.

  • The Report admits that the Burns & Roe produces dioxins and furans but
    tries to justify it by saying it is in trace amounts. Considering that 2,3,7,8
    TCDD is a known human carcinogen and considering the general level of
    toxicity of dioxins and furans, the concept of trace amounts is scientifically
    indefensible.

  • It appears that AEA has been given a marginal rating for costs because it is
    in a dispute with PMACWA. See Page 5-54. This does not appear to be a
    fair evaluation consideration for PM-NSCM.

  • Figures 4-1 and 4-2 are presumably accurate but do not reflect whether the
    technologies can address NSCMP's needs. All of the vendors should be
    given an opportunity to prove that their products can meet their needs
    regardless of what they were tasked to do in ACWA. For example, Eco
    Logic's unit was designed to be part of a larger system for ACWA testing.
    However, this does not indicate in any way whether it can meet NSCMP's
    needs.

    Recommendations

    1. Any future technology assessment reports, including supplements or addenda to the Mitretek report, should automatically be made available to citizens via direct mail or through the NSCMP web site. Citizens and other stakeholders should be made aware of such reports via phone, fax or email as soon as the information becomes available.
    2. NSCMP and Mitretek should immediately involve citizens in reviewing, and modifying, if appropriate, technology selection criteria for assessment of ACWA technologies. It is not too late to revisit assumptions made in the first Report. The Coalition is committed to work independently and through the Keystone Center effort to accomplish this.
    3. The September 1999 ACWA Supplemental Report to Congress should be reviewed, with recommendations in that Report reflected in the Mitretek assessment for non-stockpile materiel. Likewise, information from additional ACWA technology demonstrations should be reflected in any assessment of applicability to RRS and MMD by-products and NSCM feeds.
    4. AEA's Silver II process should be demonstrated in addition to Eco Logic and General Atomics. It may be that AEA could be mated to a different accessing technology later on.
    5. The Burns & Roe plasma waste converter technology should not be tested because of its potential to produce dioxins and furans and because of its poor performance in ACWA.
    6. The Teledyne-Commodore should not be tested unless the apparent fundamental 'chemistry problems' are resolved.

    CWWG

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    Chemical Weapons Working Group
    Kentucky Environmental Foundation
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    phone: 859-986-7565
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