TL: CHEMICAL WEAPONS DEMILITARIZATION AND DISPOSAL SO: Pat Costner, US Toxics (GP) DT: April 11, 1992 Keywords: Chemical weapons disposal incineration toxics pacific problems army military us marshall islands gp / [part 1 of 2] CHEMICAL WEAPONS DEMILITARIZATION AND DISPOSAL: The Army's Experience at Johnston Atoll Chemical Disposal System by Pat Costner Greenpeace 11 April 1992 SUMMARY There is no question that the world's store of obsolete chemical weapons must be demilitarized. I.e., the potential for military use of these weapons must be eliminated. The components remaining after demilitarization -- nerve agents, propellants, contaminated peripherals, etc. -- must then be detoxified so that the separated components and/or the residues of detoxification can be released to the environment without damage to the environment or public health. In an effort to demonstrate the successful demilitarization and detoxification/disposal by incineration of obsolete chemical weapons, the Army constructed the Johnston Atoll Chemical Disposal System (JACADS). Instead, the history of the Army's operation of this facility demonstrates clearly that incineration is inappropriate for the detoxification/disposal of the components of demilitarized chemical weapons. * The demilitarization of chemical weapons at JACADS was accompanied by myriad problems, ranging from basic design flaws to repeated mechanical failures. Some, but not all, of these problems have been remedied. (Menke et al., 1991) * Detoxification/disposal by incineration suffered from an even broader range of problems. Some of these were resolved. However, many of the problems are due to the inherent limitations of combustion technology. For example, given the basic JACADS facility design, major malfunctions during the separation process led to incinerator upsets with accompanying increases in stack emissions of unburned agent and products of incomplete combustion. Many other problems known to be endemic to incineration simply were not addressed by the Army. * Analytical systems used to detect unburned nerve agent in the incinerator stack, other on-site monitors and monitors at the perimeter of the facility had high rates of various malfunctions. Consequently, no means were available for providing sound estimates of stack emissions or fugitive emissions of active nerve agent nor were means available for adequate identification and quantification of other chemicals released from the stack. * During the GB campaign, the Army failed numerous times in its efforts to isolate active nerve agent from the work environment and public domain: on 32 occasions, active agent was released into the corridors frequented by workers; on 15 occasions, active agent was detected in the life support air system; on five occasions, identified as "likely" false positives, active agent was detected by perimeter monitors; on at least one occasion, active agent was evidently released from the incinerator stack, although the stack monitor was not functional during this event. DEMILITARIZATION: SEPARATION OF NERVE AGENTS FROM OTHER WEAPONS COMPONENTS Demilitarization of chemical weapons is, at its simplest, the mechanical separation of nerve agents from other weapons components -- metal housings, propellants, etc. At JACADS, the demilitarization of M55 rockets containing the nerve agent GB was carried out at JACADS, as follows: (Menke et al., 1991) "* The rocket drain station of the rocket shear machine (RSM) is used to drain agent from the rockets by punching precisely located holes through the exterior of the shipping/firing tube and the rocket. The agent is drained from the rocket and then pumped to an agent storage tank. * The rocket sheet station of the RSM then shears the rocket into pieces ..." INCINERATION: DETOXIFICATION/DISPOSAL OF NERVE AGENTS AND OTHER WEAPONS COMPONENTS The products of the demilitarization operation -- nerve agents, shipping tubes, explosives, propellants and associated materials -- are detoxified and partially disposed of by three incinerators: (Menke et al., 1991) * Liquid Incinerator (LIC): The LIC is designed to burn nerve agents -- GB, VX and mustard -- as well as liquid laboratory waste. Spent decontamination liquid is also evaporated in the LIC; * Deactivation Furnace System (DFS): The rocket pieces, rocket shipping tubes, explosives and propellants are fed into the DFS; (after leaving the DFS, the rocket pieces are placed on a heated discharge conveyor (HDC) to ensure their decontamination); and * The Dunnage Incinerator (DUN): The DUN is designed to burn both non-contaminated and contaminated dunnage from the munitions processing operations -- wooden rocket pallets and mortar shipping boxes, charcoal and HEPA filter media from the JACADS air filters, used DPE suits, and demister candle filter media. The underlying premise of the Army's decision, in 1982, to use incineration for the disposal of nerve agents and the detoxification of other residuals from demilitarization of chemical weapons was based, in large part, on the then-common assumption that hazardous waste incineration was a well-defined, mature technology. A mature technology is, of course, a technology that is productive, safe for workers and protective of human and environmental health. At the time of the Army's decision, there was an obvious dearth of documentation on incinerator performance, safety and impacts. During the years since the Army selected incineration as the appropriate method for detoxification/disposal of the components of demilitarized chemical weapons, numerous studies and reports have been published, describing various limitations of incinerator performance and, to a much smaller extent, impacts. As detailed in a 1991 Greenpeace review of hazardous waste incineration, "Playing With Fire: Hazardous Waste Incineration," this technology was, and still is, practiced and promoted, not because it is a proven, mature technology, but because it is expeditious, relatively inexpensive and liability-free for the generators of the materials incinerated. I.e., the pollutants emitted from incinerator stacks and those deposited in the ashes and residues of pollution control systems cannot be traced back to the generators of the waste. (Costner and Thornton, 1991) This incineration critique as well as a second 1991 Greenpeace report, "Alternative Technologies for the Detoxification of Chemical Weapons: An Informational Document," offer ample documentation that even "state-of-the-art" incinerators release unburned wastes, metals and products of incomplete combustion (PICs) in stack gases, ashes and residues of pollution control systems. (Costner and Thornton, 1991; Picardi et al., 1991) Of particular importance in relation to the incineration of chemical weapons, however, is the impossibility of predicting incinerator performance and preventing incinerator upsets: "The complexity of the incineration process, the differences in incinerator designs, and the difficulties in monitoring operating conditions make the accurate prediction of absolute incineration performance an essentially impossible task ... Only a very small fraction of the total volume of waste needs to experience ... less than optimum conditions to result in significant deviations from the targeted destruction efficiencies." (Dellinger and Lee, 1986) Also of great importance to the incineration of chemical weapons is an extensive study by the U.S. Environmental Protection Agency (USEPA) of hazardous waste incinerators, which documented their limited ability to destroy chemicals present at relatively low concentrations: (Kramlich et al., 1989) * For those chemicals present in wastes at concentrations of 10,000 parts per million (ppm) -- 1.0 percent by weight -- or below, incinerators do not achieve a destruction and removal efficiency (DRE) of 99.9999 percent; * For those chemicals present in wastes at concentrations of 1,000 ppm or below, incinerators had difficulties in achieving a DRE of 99.99 percent; * For those chemicals present in wastes at concentrations of 100 ppm or less, no incinerator was able to achieve a DRE of 99.99 percent. These limitations are especially pertinent to performance of the Deactivation Furnace System (DFS) and the Dunnage Incinerator (DUN), in which relatively low concentrations of agent, propellants, etc. are burned. Further, even if the Army's three-incinerator system were able to achieve a DRE of 99.99999 percent, as reported for the LIC, during every moment of operation with all nerve agents fed into each of the incinerators, the quantities of unburned agents released in stack emissions are sufficient cause for concern for public health and the environment. For example, at this DRE, at least 3.5 grams of active agent GB were released in the LIC stack emissions at JACADS when 75,000 pounds of GB were burned. Based on an acute lethal dose of 140 micrograms per adult (Picardi et al., 1991), 3.5 grams of GB, if delivered directly, is a lethal dose for 24,000 people. For another example, if 1,500 1-ton containers of mustard gas are burned, with the LIC achieving a 99.9999 percent DRE at all times, approximately 3 pounds (1,362 grams) of mustard will be released, intact, in stack gases. Mustard is carcinogenic; it is a powerful blistering agent; and it is highly persistent in the environment. (Picardi et al., 1991) The following caveat, offered in A USEPA study is, of course, applicable to all three incinerators -- the MPF and DUN, as well as the liquid incinerator (LIC): "One present concern for application of incineration technology is that the hazard associated with a waste stream may not be removed even though the original waste compounds are destroyed. Transformation of the waste into hazardous products of incomplete combustion (PICs) can potentially aggravate the hazard associated with the waste stream. For example, a hazardous but nontoxic waste can be partially transformed into chlorinated dibenzo-p-dioxins or dibenzofurans upon incineration." (Kramlich et al., 1989) As detailed in the Greenpeace report on hazardous waste incineration, chlorinated dioxins and furans are formed when carbon and the halogen, chlorine, are present in the waste fed into incinerators and other combustion systems. (Costner and Thornton, 1991) When other halogens, such as bromine and, possibly, fluorine, are present in the materials burned, other halogenated dioxins and furans are also formed. Further, when both chlorine and sulfur are present in the waste, the sulfur analogs of the polyhalogenated furans, polychlorodibenzothiophenes, are released in stack emissions. (Buser et al., 1991) Polyhalogenated dioxins and furans will undoubtedly be among the products of incomplete combustion released during the incineration of chemical weapons components, just as they are among the "thousands of different compounds" that are, according to USEPA, typically found in the stack emissions of hazardous waste incinerators (USEPA, 1990) As shown below, the nerve agents and other materials to be fed into the Army's three-incinerator system contain the elements that are the basic building blocks for these complex, highly persistent, bioaccumulative organohalogens: * The nerve agent GB (Sarin) contains both carbon and the halogen, fluorine, in its molecular structure; * HD (mustard) contains carbon, chlorine and sulfur; and * The decontamination solution, which is fed into the LIC with the nerve agents, also commonly contains chlorine. In summary, the incineration of nerve agents and other chemical weapons components will result in the direct dispersal of the following materials into the public domain via incinerator air emissions and fugitive emissions: * Active agents; * Products of incomplete combustion, including the chlorinated dioxins and furans and their analogs; and * Metals, including those identified in the agents -- aluminum, iron, nickel and copper -- and the relatively large quantities of lead found in propellants and detonators. These same substances will be distributed among the incineration system's ashes and the residues of pollution control devices. These ashes and residues require further disposal, primarily burial in landfills. INCINERATOR PERFORMANCE AT JACAD During the period of July 16, 1990, through February 27, 1991, some 7,490 M55 rockets containing approximately 75,000 pounds of the nerve agent, GB, were demilitarized and the resulting products of demilitarization treated, in part, by incineration at JACADS. (Menke et al., 1991) According to the MITRE report, "Evaluation of the GB Rocket Campaign: Johnston Atoll Chemical Agent Disposal System Operational Verification Testing," the demilitarization units and two of the three incineration units (DFS and LIC) were functional for 500 hours during this seven-month period. The DUN was not fully operational during this time. (Menke et al., 1991) JACADS accomplished 500 hours of active demilitarization and incineration, accompanied by a cumulative downtime of 929 hours, as shown in the attached pie chart. I.e., the JACAD System was shut down almost twice as often as it was functional. The average "mean time between failures" for JACADS, as a whole, was 5.6 hours. (Menke et al., 1991) As the chart shows, the JACADS demilitarization systems accounted for only 3.6 percent of JACADS' downtime, while more than 50 percent of downtime was attributed to the incinerators -- LIC and DFS only, since DUN was operated only in test and start-up mode. The "mean time between failures" for the LIC was 28.9 hours and, for the DFS, 6.26 hours. (Menke et al., 1991) According to USEPA's Science Advisory Board, "Even relatively short-term operation of incinerators in upset conditions can greatly increase the total incinerator-emitted loadings to the environment." (USEPA, 1985) Among the factors leading to incinerator upsets are sudden variations in waste feed rates, including waste feed cutoffs and startups. (Costner and Thornton, 1991) These occurrences were so frequent as to be the standard operating mode at the JACADS incinerators. For example, during the 500-hour operating period when agent GB was burned, the network of monitors for detecting GB releases triggered 776 major process alarms, an average of 22 per day. Major process alarms are those "that are so important that agent or spent decon processing is stopped." (Menke et al., 1991) The MITRE report explained these alarms as follows: "The majority of these alarms were for high CO concentration in the [LIC] secondary chamber exhaust gases. There was no significant change in the number of alarms throughout the campaign." (Menke et al., 1991) The concentration in stack gases of carbon monoxide (CO) is commonly used as a surrogate indicator of incinerator performance because high CO levels increase during major upset conditions, which are also accompanied by high PIC emissions. I.e., high CO levels are associated with high rates of PIC emissions. (USEPA, 1990) However, one USEPA contractor warns, "Under some failure conditions, PIC yields may be high while CO formation has yet to reach its maximum." (Dellinger and Lee, 1990) According to the MITRE report, the LIC also suffered 90 burner lockouts and 40 fuel flow shutdowns during the GB campaign. (Menke et al., 1991) In other words, the LIC operated in a continuous upset condition during the GB campaign. Even if major upsets at incinerators could be avoided by flawless maintenance and consistent operating conditions, localized and short-term variations from ideal combustion would still occur constantly within the incinerators. These transient departures from ideal conditions can decrease an incinerator's destruction efficiency, increasing releases of both unburned wastes and PICs. According to one analysis, deviations from intended combustion conditions are caused as follows: "[They] usually are a consequence of a rapid perturbation in the incinerator operation resulting from a rapid transient in feed rate or composition, failure to adequately atomize a liquid fuel, excursions in operating temperature, instances where the combustible mixture fraction is outside the range of good operating practice, or inadequate mixing between the combustibles and the oxidant... The amount and composition of PICs will depend in a complex and unpredictable way on the nature of the perturbation." (USEPA, 1989a) Even during the trial burn to demonstrate compliance with federal incinerator regulations, the feeding of GB to the LIC was interrupted because of major process alarms. Stack sampling was discontinued with each interruption and resumed only after the incinerator had achieved a steady state. (SRI, 1991) Consequently, the concentrations of PICs in the stack gases were not determined for those periods when their concentrations could be expected to be highest. I.e., the quantities and types of PICs identified during the LIC trial burn are not representative of those emitted during normal operations which, at JACADS, includes frequent cutoffs and restarts of the nerve agents fed into the incinerator. In an assessment of incineration, USEPA found, "Very few tests have been conducted to identify and quantify PICs from hazardous waste combustors under nonoptimum conditions." (USEPA, 1989b) The relationship between incinerator performance during brief trial burns and that achieved during routine operations has been characterized as follows: "The trial burn data only indicate how well the incinerator was operating during the time that the data were being taken, typically only a period of a few days. No information is obtained on how the incinerator might respond if fuel, or especially waste, conditions change. ... It is difficult to generalize the results of a trial burn to predict how the composition of the incinerator exhaust will change under these varying conditions." (Staley, 1986) Further, the PICs identified during the LIC trial burn were limited to only a fraction of those chemicals on USEPA's Appendix VIII list, some 300 manufactured chemicals that are listed because of their production quantities and toxicities, not because of their occurrence in incinerator stack gases. (SRI, 1991) There has been no full identification of the mass of pollutants known to be present in stack gases in any trial burn at any hazardous waste incinerator, nor is this likely to be achieved: "PIC emissions are composed of thousands of different compounds, some of which are in very minute quantities and cannot be detected and quantified without very elaborate and expensive sampling and analytical [S&A] techniques. Such elaborate S&A work is not feasible in trial burns for permitting purposes and can only be done in research tests. Very few research tests have been conducted to date to identify and quantify all the PICs in a typical emissions sample, and whenever done were unsuccessful because sampling and analysis techniques are not available to identify or quantify many of the potential compounds emitted, nor are toxicity data available for all the compounds." (USEPA, 1990) The continual instability of the LIC during the 500-hour operational period was most readily demonstrated by numerous releases of nerve agent GB. According to the MITRE report, "[t]he control of the LIC primary chamber pressure was difficult throughout the GB campaign. On page 3-73, the MITRE report describes the release of agent from the LIC on 32 occasions: "[P]ressure fluctuations when the LIC was processing agent allowed agent to be released into the LIC room and adjacent observation corridor on fifteen separate occasions." (Menke et al., 1991: page 3-73) "On 17 separate occasions [during agent purging operations] the pressure in the primary chamber [of the LIC] fluctuated sufficiently to enable agent to enter the LIC furnace room and subsequently migrate into the adjacent observation corridor." (Menke et al., 1991: page 3-76) A minimum level of oxygen must be maintained in an incinerator in order to achieve adequate combustion. (Staley, 1986) The LIC incinerator "went outside the RCRA permit limits [for oxygen concentration] 25 times during processing operations." I.e., the oxygen level in the LIC dropped below USEPA's legal standard 25 times while burning GB. This same deviation from the oxygen standard occurred 496 times "outside operations" when munitions were not being processed. Likewise, the DFS incinerator violated the RCRA oxygen standards twelve times while GB was being burned. According to the MITRE report, when oxygen levels drop too low, "complete combustion of the materials (including agent) would not be ensured." The low oxygen levels in the LIC's primary combustion chamber were associated with the following circumstances: (Menke et al., 1991) "Problems controlling O2 level were frequently encountered on start up when switching from propane to fuel oil, at high agent feed rates, and whenever the agent fed was terminated abruptly." USEPA, however, offered the Army a novel interpretation of the law on behalf of JACADS: the RCRA violations were redefined as `exceedances,' since hazardous feed was stopped after each violation. I.e., if the waste feed was stopped after the violation took place, then the violation did not take place. The `exceedances' of the LIC and DFS, as well as those of the DUN, are presented in the table below: (Menke et al., 191) "JACADS "RCRA Permit Exceedences/Violations (sic)" No. of No. of Exceedences Exceedences No. of Furnace Item Limit Outside Ops During Ops Violations LIC CO <200 ppm 5 min 77 3 0 O2 5-10 percent 496 25 0 DFS CO <200 ppm 5 min 168 0 0 O2 6-14 percent 299 12 0 DUN CO <200 ppm 5 min 166 - - O2 8-14 percent 180 - - The MITRE report explained the `exceedances' by the LIC and DFS as follows: "It should be noted that examination of the circumstances of most of the exceedances shows that virtually all were associated with transient conditions in the furnace. Such conditions may arise, for example, from a changeover from one fuel to another, introduction of agent into the furnace with reduction of the standby fuel, or termination of agent feed with a fuel increase; or operating component failure." (Menke et al., 1991) The general performance of the LIC during the 500-hour operational period was described as follows: "The LIC failed to meet the maximum feed rate design goal of 1,050 lb/hr. Although it did operate for three hours at 1,000 lb/hr. The RCRA trial burn established a maximum operating rate of 750 lb/hr. By the end of the GB campaign, instrument and equipment (gear pump) problems limited the LIC feed rate to less 300 lb/hr (sic) (corrections to these problems were scheduled for installation after the GB campaign)." (Menke et al., 1991) Further, experience showed that the planned evaporation of spent decontamination solution in the LIC's secondary combustion chamber could not be accomplished while agent GB was being burned. Attempts to accomplish agent incineration and `decon' evaporation simultaneously caused plugging of the continuous emissions monitor probe. It was also found, perhaps not unexpectedly, that salts from the spent `decon' melted and collected on the walls of the LIC's secondary combustion chamber. Subsequently, the melted salts flowed down the walls, since the salt removal system was inoperable during GB campaign, and collected in the sump at the bottom of the combustion chamber. After processing 11,000 gallons of `decon,' the sump was full: "The removal of the salts was difficult and time-consuming since the material was a glass-like substance in the bottom of the secondary chamber and had to be chipped out manually." (Menke et al., 1991) The DFS suffered a remarkable series of major equipment failures -- more than 50 percent of the kiln bolts stretched or broke on three occasions. Further, the performance of the DFS did not meet expectations, as described in the MITRE report: "... [T]he operation of the DFS was considerably below expectation. ... [A] substantial number of problems can be attributed to a failure to incorporate lessons learned from prior experience, and a lack of sufficient opportunity to operate, test, and fix the DFS as a system (i.e., fed chute, gates, rotary kiln, HDC) with simulant-filled rockets prior to the start of OVT. (Menke et al., 1991) AGENT MONITORING AND RELEASES AT JACADS The ability to detect releases of nerve agents with great accuracy and reliability is, of course, a pivotal issue in the demilitarization of chemical weapons and the disposal of related residues, including active agents. Within JACADS there are some 100 locations, including personnel areas, the common stack and the furnace rooms, that are equipped with agent monitors. These monitors are of two types: * the Automatic Continuous Air Monitoring System (ACAMS), which provides a measurement of agent concentration every 2-10 minutes, "almost real-time," with a limit of quantitation for agent GB of 0.00006 mg/m3, or about 10 ppt; (SRI, 1991) and * the Depot Area Air Monitoring System (DAAMS), which samples the air for up to 12 hours and, consequently, does not provide real time exposure information. (The DAAMS does apparently have lower detection limit than ACAMS.) (Menke et al., 1991) It is noteworthy that, contrary to standard practice, no detailed explanations of the reliability, precision and accuracy of either ACAMS or DAAMS is given in either the trial burn protocol (SRI, 1990) or the trial burn report for the burning of agent GB in the LIC. (SRI, 1991). In the absence of such data, a thorough assessment of their capabilities is not, of course, possible. =======[#]======= TL: CHEMICAL WEAPONS DEMILITARIZATION AND DISPOSAL SO: Pat Costner, US Toxics (GP) DT: April 11, 1992 Keywords: Chemical weapons disposal incineration toxics pacific problems army military us marshall islands gp / [part 2 of 2] A review of the occurrence and explanations of alarms from the monitors in the stack shared by the LIC, DFS and MPF suggests that the reliability of these monitoring systems is, at best, questionable. For example, among 62 alarms from the stack monitors, the following causes were detailed for 41 of the alarms: (Menke et al., 1991) "6 furnace transients 14 interferents 7 malfunctions 10 electronic 3 unexplained 1 confirmed agent release" These data suggest that either or both ACAAMS and DAAMS suffer from high rates of dysfunction and a disconcertingly high susceptibility to non-agent influences. Certainly, a malfunction rate of almost 20 percent is unacceptable, as is a sensitivity to interferents that accounts for 34 percent of responses. Given monitors of such poor reliability, the placement of apparently only one monitor in the common stack seems more an attempt to avoid detecting stack releases of agent than an effort at detection. For example, during the one confirmed agent release listed above, the "stack ACAMS (ACAMS-129) was effectively not reading agent during the incident." (Menke et al., 1991) Despite the absence of a functioning stack monitor, the one confirmed agent release from the common stack was reported as a maximum of about 22 percent of the Allowable Stack Concentration (ASC), which is 0.0003 mg/m3, or 52 parts per trillion (ppt) (SRI, 1991) for about one hour. (Menke et al., 1991) I.e., at a stack flow rate from the LIC of 437,000 dry standard cubic feet per hour, as measured during the trial burn (SRI, 1991), approximately 816.9 micrograms (ug) per hour of agent GB were released into the air. For humans, the oral TDLo for GB is 2 ug/kilogram (kg) of body weight. (Flamm et al., 1987) Other alarms signaling potential release of agent outside containment areas were reported during the 500-hour operating period as follows: * Heating, ventilation and cooling (HVC): 3 alarms, all false positives; * Lab Vent: 3 alarms, 1 agent release, 2 false positives; * Perimeter: 5 double positives, but cited as "likely" false positives; and * Unpacking Area: 2 "false positives" As the data indicate, false positives (false alarms) have occurred with considerable frequency at JACADS. Although the MITRE report describes several mechanisms for identifying false positives, no such information is offered for identifying false negatives (failures of monitors to detect agent). COMPARISON OF JACADS WITH U.S. HAZARDOUS WASTE INCINERATORS The difficulties the Army encountered with the JACADS incinerators are, in many ways, entirely typical of the problems encountered by U.S. commercial hazardous waste incinerators. In a report released jointly by USEPA and the Occupational Safety and Health Administration in May, 1991, USEPA reported a "significant number of automatic waste feed cutoffs at half of the hazardous waste incinerators inspected." As at JACADS, automatic waste feed cutoffs at these facilities are commonly triggered by excessive CO levels and by oxygen levels that are too low: "The number of waste feed cutoffs reported during a 30-day period varied from 0 to 13,325 (at a facility with four incinerators), with an average, among 16 incinerators, of 38 waste feed cutoffs per day per incinerator." (OSHA/USEPA, 1991) At some incinerators, USEPA also found a high rate of opening of emergency by-pass systems: stack gases were vented directly to the emergency by-pass systems, circumventing pollution control systems. These "dump" stacks are often opened when excessive pressure builds up in incinerator combustion chambers. During a 6-month period, the number of times emergency by-passes were opened at the facilities inspected ranged from 0 to 867 (at a facility with four incinerators), with an average, among 12 incinerators, of 80 times in 6 months, or approximately once every three days. (OSHA/USEPA, 1991) Existing and potential uncontrolled releases of hazardous wastes from hazardous waste incinerators were documented in a 1990 report by the U.S. General Accounting Office (GAO). GAO reported that, among the 115 hazardous waste incinerators thus far assessed by USEPA, the Agency has found "sufficient evidence of a release or potential release of hazardous waste to warrant an RFI [investigation] to confirm the release and/or characterize the hazardous release." (GAO, 1990) WORKER SAFETY While achieving 500 hours of demilitarization and incineration, the JACADS workforce accumulated 1944 hours of lost-time accidents. I.e., every hour of active demilitarization was accompanied by 3.9 hours of injury-related lost-time among the workers. No OSHA inspections are reported for JACADS. However, during 62 inspections of 29 hazardous waste incinerators, OSHA inspectors identified 320 violations. More than 66 percent of these were regarded by the agency as "serious." (OSHA/USEPA, 1991) At JACADS, active agent GB escaped from the LIC into corridors routinely used by workers on fifteen to seventeen occasions. Also on fifteen occasions, agent GB was detected in the life support air system. (Menke et al., 1991) REFERENCES (Buser et al., 1991) Buser, H-R, Dolezal, I.A., Wolfensberger, M., and Rappe, C., "Polychlorodibenzothiophene, the Sulfur Analogues of the Polychlorodibenzofurans Identified in Incineration Samples," Environ. Sci. Technol., Vol. 25, No. 9, 1991, pp. 1637-1643. (Costner and Thornton, 1991) Costner, P., and Thornton, J., "Playing With Fire: Hazardous Waste Incineration," Greenpeace U.S.A., Washington, D.C., May, 1991. (Dellinger and Lee, 1986) Dellinger, B., and C. Lee, "PIC Formation Research Status and Control Implications." In Remedial Action, Treatment, and Disposal of Hazardous Waste, Proceedings of the Sixteenth Annual RREL Hazardous Waste Research Symposium. EPA 600/9-90/037, U.S. Environmental Protection Agency, Cincinnati, Ohio, August 1990. (Flamm et al., 1987) Flamm, K.J., Kwan, Q. and McNulty, W.B., "Chemical Stockpile Disposal Program: Chemical Agent and Munition Disposal, Summary of the U.S. Army's Experience, " Report No. SAPEO-CDE-IS-87005 (GAO, 1990) U.S. General Accounting Office (GAO), "Hazardous Waste: Status and Resources of EPA's Corrective Action Program," GAO/RCED-90-144, Washington, D.C., April, 1990. (Kramlich et al., 1989) J.C. Kramlich, E.M. Poncelet, R.E. Charles, W.R. Seeker, G.S. Samuelsen, and J.A. Cole, "Experimental Investigation of Critical Fundamental Issues in Hazardous Waste Incineration," EPA/600/2-89/048, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina, September 1989 (Menke et al., 1991) J.L. Menke, H.M. Carlson, M.H. Flinn, S.R. MacRae, D.M. Medville, and D.J. Tripler, "Evaluation of the GB Rocket Campaign: Johnston Atoll Chemical Agent Disposal System Operational Verification Testing." MTR-91W00039, MITRE Corporation, McLean, Virginia, June 1991 (OSHA/USEPA, 1991) Occupational Safety and Health Administration and U.S. Environmental Protection Agency, "USEPA-OSHA Joint Task Force Report on Evaluation of Compliance with On-Site Health and Safety Requirements at Hazardous Waste Incinerators," U.S. Department of Labor, Occupational Safety and Health Administration, and U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C., May 23, 1991 (Picardi et al., 1991) Picardi, A., Johnston, P., and Stringer, R., "Alternative Technologies for the Detoxification of Chemical Weapons: An Informational Document," Greenpeace International, Washington, D.C., May, 1991. (SRI, 1990) Southern Research Institute, "Sampling and Analytical Protocol for the Resource Conservation and Recovery Act (RCRA) Trial Burns and the Toxic Substance Control Act (TSCA) Demonstration Burn at JACADS," Southern Research Institute, Birmingham, Alabama, September, 1990. (SRI, 1991) Southern Research Institute, "Results of the RCRA Trial Burn for the Liquid Incinerator at the Johnston Atoll Chemical Agent Disposal System," SRI-APC-91-190-6967-006-F- R4, Birmingham, Alabama, June, 1991 (Staley et al., 1986) Staley, L., M. Richards, G. Huffman, and D. Chang, "Incinerator Operating Parameters Which Correlate With Performance," EPA/600/2-86/091, U.S. Environmental Protection Agency, Washington, D.C., October 1986. (USEPA, 1985) U.S. Environmental Protection Agency Science Advisory Board, "Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport, and Fate Committee, Science Advisory Board," U.S. Environmental Protection Agency, Washington, D.C., April 1985. (USEPA, 1989a) U.S. Environmental Protection Agency Science Advisory Board, "Review of OSW's Proposed Controls for Hazardous Waste Incinerators: Products of Incomplete Combustion," U.S. Environmental Protection Agency, Washington, D.C., October, 1989. (USEPA, 1989b) U.S. Environmental Protection Agency, "Background Document for the Development of PIC Regulations from Hazardous Waste Incinerators, Draft Final Report," U.S. Environmental Protection Agency, Washington, D.C., October 1989. (USEPA, 1990) U.S. Environmental Protection Agency, "Standards for Owners and Operators of Hazardous Waste Incinerators and Burning of Hazardous Wastes in Boilers and Industrial Furnaces; Proposed and Supplemental Proposed Rule, Technical Corrections, and Request for Comments," 55 FR 82, April 27, 1990. =end= =======[#]=======