reclassifying chemical relics of the cold war
TRANSCRIPT
g o v e r n m e n t & p o l i c y
Reclassifying chemical relics of the Cold War Among the detritus of the Cold War are tens of thousands of chemical agent identification sets (CAIS) that the Army used from 1928 to 1969 to train soldiers to defend themselves against chemical weapons attacks. These kits now need to be destroyed. How to do so—a problem complicated by technical, legal, environmental, and societal issues—is the gist of a recent National Research Council study called for by Congress.
Most of the approximately 10,000 kits—more are expected to surface as Army bases close—contain glass vials of small quantities of the blister agents sulfur mustard (C1CH2CH2SCH2CH2C1) and lewisite (Cl2AsCHCHCl). The Army has classified the kits as chemical warfare matériel, which precludes their disposal at commercial hazardous waste facilities. Because they are considered nonstockpile matériel, the Army, by law, is not allowed to incinerate them at the eight U.S. installations slated to de
stroy the nation's arsenal of chemical weapons.
The Army's solution, which it documented in a report to Congress, is to employ what it dubs the Rapid Response System (RRS). This system is a mobile trailer unit that incompletely neutralizes a chemical agent. The Army then has to treat the remaining waste, usually via incineration. RRS is now undergoing testing.
The NRC committee has recommended that the Army rethink its classification of CAIS as chemical warfare matériel. If the Army determines that it cannot reclassify CAIS, then it should go to Congress and ask for legislation that will allow CAIS to be regulated as hazardous waste under the Resource Conservation & Recovery Act. The Environmental Protection Agency has evaluated CAIS chemicals and has concluded that they may be treated as hazardous waste under RCRA.
Reclassification, the committee concludes, would substantially reduce transportation and disposal costs and increase the likelihood and feasibility of
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CAIS disposal. Worker and public safety would not be compromised.
Chemical warfare agents in the kits are present in such small quantities that they are likely to pose less risk than do the much larger volumes of sometimes highly toxic industrial chemicals now being treated by the chemical industry and commercial hazardous waste treatment plants, the committee concludes. But the committee adds that the Army still needs to do a more complete risk assessment to document the anticipated safety of disposing of the kits.
Earlier, the Army had estimated that commercial incineration of the kits would cost substantially less than if it disposed of them. But the NRC committee found several problems with the Army's estimates and called for a more comprehensive cost analysis. And because of strong public opposition to incineration, the committee also urged the Army to consider other disposal options at either commercial or Army facilities.
In those states with a chemical weapons disposal facility, the Army should engage the public in discussions of CAIS disposal options, including the possible use of the stockpile incineration facility for the destruction of the kits. If an affected community agrees to the use of the facility for kit disposal, the Army should involve the community thoroughly in establishing specific conditions for the kits' destruction. Such community acquiescence may be more likely at the two U.S. sites that will employ neutralization rather than incineration as the destruction technology, the committee says.
Even with community agreement, the Army would still have to get Congress to amend the law prohibiting the use of the eight stockpile destruction facilities from destroying material other than chemical weapons, the committee emphasizes.
Few commercial firms may be willing to take on the Army's business even if further analyses find the commercial route to be the disposal avenue of choice, the committee warns. The amount of business would be relatively small, the firms may have to add equipment to handle arsenic-based lewisite, and public outrage over the disposal of chemical warfare matériel may ward off commercial takers.
Robert Jones, a spokesman for the Army's Non-Stockpile Program, tells C&EN that his group has just "received the NRC report and has not had the opportunity to review it in its entirety to provide a quality comment."
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4 4 JANUARY 17,2000 C&EN